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The Coalition's Response

Comments by
THE NATIONAL COALITION TO SAVE OUR MALL

On the
Washington Monument Permanent Security Improvements Environmental Assessment Dated: April 2002

-June 17, 2002-

TO:
Arnold Goldstein, Superintendent
National Capital Parks - Central
National Park Service - National Capital Region
Fax: 202-426-1835
Email: NACC_Superintendent@nps.gov

GENERAL:

The Environmental Assessment (EA) issued by the National Park Service (NPS), with the cooperating agency the National Capital Planning Commission (NCPC), presents findings and conclusions based on inadequate documentation and unsubstantiated assessment of actual structural and human impacts associated with the preferred solution Alternative A, the singular below-grade design.

The EA indicates that several technical studies are still underway, including geotechnical and cultural landscape reports. Yet it concludes that environmental consequences are of a minor nature even though it clearly identified for more comprehensive analysis geophysical resources (substance concerns), visual/scenic resources (aesthetic concerns) and visitor experience (resource integrity concerns). Under these circumstances, the findings of the EA are premature and lack adequate basis upon which to base the conclusion(s) of minimal impacts recommending limited mitigation measures.

We believe that this project -- involving massive excavations into the historically unstable soils, cutting through the 120-year old Monument foundation, walls encircling the grassy mound, and a totally new visitor experience -- would have significant adverse effects on the Monument, Monument grounds, and the human environment. In addition, it would have significant adverse effects on the National Mall as a whole, and on the historic L'Enfant and McMillan Plans. Any project that is controversial and will have serious adverse effects on physical, historic, and cultural property requires a full Environmental Impact Statement (EIS). This is necessary in order to assure conformance with all applicable environmental laws, Section 106 of the National Historic Preservation Act and Section 4(f) of the Department of Transportation Act, affecting public park lands, recreation and wildlife areas or historic sites of national significance.

The inadequacy of the EA and the growing public controversy surrounding the project, especially the tunnel, further makes an EIS a necessity.

INADEQUACIES:

The EA does not adequately identify the historic properties affected.

The crucial Cultural Landscape Report (CLR), which would fully identify the historic properties, is not yet completed. The preliminary CLR documents we received from NPS on June 12 - a timeline of Washington Monument history and historic plans and drawings - are partial and do not include the all-important analysis that is needed in order to evaluate the conclusions of the EA.

As the Scope of Services for the CLR makes clear that, "A cultural landscape report (CLR) is the primary guide to treatment and use of a cultural landscape… It makes recommendations for treatment consistent with the landscape's significance, condition, and planned use." The CLR is intended not only to identify the properties, but also to provide design guidelines for any proposed changes.

Once the CLR is completed and the historic properties are fully identified and proposed changes fully analyzed, a new environmental document should be prepared. The absence of a completed CLR for the EA should not be allowed to short-circuit the Section 106 and NEPA process.

The bibliography does not cite the important study Improvements to the Washington Monument Grounds from the 1930's which documented the unstable soils and Monument foundation and which caused Congress to reject construction of the terraces and steps proposed in the McMillan Plan of 1901-1902. On what basis did the NPS abandon that cautious approach?

The EA does not fully identify the project's design and misrepresents the design, and so is inadequate.

The plans, elevations, sections, and vista analyses do not show the full scope and size of the project. For example, views of the tunnel do not show the configuration of tunnel switchbacks that will be required to conform with the Americans With Disabilities Act. Nor do they show the location and configuration of emergency exits along the length of the tunnel. What are the criteria by which NPS evaluated the impacts?

The EA provides simulated views that minimize, almost to the point of invisibility, the 3-foot tall bermed walls and ha-has. However, the walls have undergone major redesign. The latest design concept presented in May to the Commission of Fine Arts has exposed stone walls, and most of the berms have been eliminated. How does NPS draw conclusions about vistas with inaccurate and outdated drawings?

Other design changes, including to the Lodge, made incrementally over the past four months, are not shown or analyzed in the EA. Aspects of the project have undergone changes so significant that the project has become a new design concept. As such, it warrants a new, more expansive environmental study.

The EA does not adequately identify and analyze physical, cultural, and visitor impacts including the regulations intended to treat mobility-impaired persons using manual or motorized wheelchairs as pedestrians.

Lacking data and information from the incomplete geotechnical, cultural landscape and other studies, the EA offers opinion and conjecture or simply ignores impacts.

Serious concerns raised by the public over the past 5 months are not adequately answered. What is the basis for NPS conclusion that excavations would require "minor cuts", "minor soil disturbance" and "negligible change in bearing force of the Monument on the underlying clay layer"? The EA does not provide adequate new data to overturn the long history of concern and caution regarding the Monument grounds' unstable soils, dropping water table, and settling of the Monument. How did the NPS draw conclusions without such data? How did the NPS determine that the Monument's 120-year-old concrete foundation could be cut, and whole sections removed, without affecting the Monument?

Given the new finding of high concentrations of arsenic in the fill layer -- soil that will have to be disturbed and probably replaced with clean fill -- on what basis did the NPS determine that a major decontamination process within 200 feet of the Monument would not adversely affect the Monument?

How will the project affect the Jefferson Pier, which lies approximately the same distance from the Monument as the proposed walls? And what are the cumulative effects of the project in relationship to the 7.4-acre World War II Memorial just across 17th Street? The WWII Memorial receives barely a mention, even though that huge expanse of stone, concrete, and asphalt will have a dramatic impact on the vistas and public uses of that part of the Mall and the Monument grounds.

Visitor impact is inadequately analyzed. For example, 5-35 states that "The addition of an underground visitor screening facility would not change the essential components of ascending the Monument, but it would alter how the visitor prepares for the tour." This is false, since visitors, who now walk up to the Monument doors, enter, and board an elevator, would instead have to descend underground and walk through a long, increasingly narrow tunnel. Is this the experience the public should be exposed to?

As for Historical Resource Impacts (5-17), the EA appears to defer evaluation to the consultation process being undertaken under Section 106. That process, however, requires that a full and detailed documentation and evaluation of the project be made in the EA, taking into consideration the views of Section 106 participants.

Mitigation measures promising continued study of effects (5-20) should not be substituted for the information and analysis lacking in the EA.

The EA fails to consider credible alternatives to Alternative A

The alternatives examined are limited to one above and one below grade build solutions. The EA's background indicates that for the nation's foremost memorial to George Washington, over the years, "various iterations of design concepts" for changes to the Monument and Grounds "have maintained the spirit of the L'Enfant Plan by maintaining the primary structures and monuments `as dominant elements in the landscape` and fitting the plans to the site's topography". Yet only one below grade design solution is examined. There are other below grade design solutions which merit examination as part of the EA.

The only above grade proposal is Alternative B which, however, is not a credible alternative since, as the EA notes, it does not meet the NPS's security needs. There are other above grade design solutions which merit study as part of the EA.

3-5 states that "Alternatives Considered But Eliminated" originated during planning efforts over the past 30 years. But those efforts were primarily concerned with accommodating tourists. Now, post 9/11, security needs are very different. 1-2 states that the projects primary purpose is "Improvement of Security." The EA needs to consider a full range of options that directly address security of the Monument and visitors and explain how those options were chosen and accepted or rejected.

There are open questions regarding security. How did the NPS choose walls instead of bollards that, placed at street level, would stop a vehicle from getting anywhere near the Monument? The walls on the other hand allow vehicles within 400 feet. With what criteria did the NPS judge bollards were less acceptable than 3-foot high stone walls that will cut across the grassy open space and impede pedestrian movement? How did the NPS establish the underground elements as the security solution to screening visitors? In 1973, when the underground visitor center and tunnel were first designed, that appeared to be a preferred solution. But in era of suicide bombers, placing crowds of people in an underground, enclosed space where emergency escape is considerably more complicated than above ground seems questionable.

The glass addition to the Lodge and the skylights above the underground spaces would almost appear to be more a security lapse than a solution. How did the NPS determine that tourists would be better off underground, and under glass, if a terrorist were to charge the Monument grounds?

What if there is a fire underground? An explosion? Wouldn't the effect of such a disaster in an underground and enclosed space be worse than above ground? Couldn't a blast or cave-in of the unstable soils around the Monument threaten the Monument's fragile stability? With what criteria did the NPS evaluate these questions?

SPECIFIC INADEQUCIES:

• In the environmental consequences matrix, Visitor Use and Experience, no assessment is made of total time visitors are confined to an underground enclosed space.
• The enclosed elevator in the monument will continue to only take 70 seconds to rise to the top; the duration of the underground experience will be much much longer and has not been addressed.
• Page 4-8, Current Studies of Soils and Groundwater, indicates engineers "predictions" rather than engineering analysis. Using words such as "would not likely dewater the clay layer" is not instructive. Proposed construction adjacent to the nation's foremost memorial to George Washington, a 550-foot high neoclassic obelisk, the tallest structure in the National Capital, needs more definitive analysis.
• Section 4.1.5, Hazardous Materials, is superficial. "Best management practices" need to be specifically identified in order that nothing is overlooked and no mistakes are made.
• Archaeological Resources contain vague language such as "most likely" and "would likely". This very historic site needs a more definitive study with definite conclusion and not vague references. No investigation concerning possible Indian burial grounds is included. This location was the edge of the Potomac River in 1862 and burial grounds have been identified along the original Potomac shoreline.
• The Structure and Its Engineering, pages 4-22 and 4-23 have no discussion about its historically unstable foundation.
• Proposed changes to the Monument Lodge, a contributing resource to the historic Grounds, are considered minor impacts. Very little evidence is presented to make such a finding. The Historical Structure Report, which will provide the needed information, will not be completed, according to NPS Task Orders, until late August.
• Figure 4.2.2-1, page 4-31, is very difficult to read and compare with proposed Alternative A.
• The Cultural and Ethnographic Resources, pages 4-32 and 4-33, do not include a discussion of the Alternate's impact on the cultural landscape "Public Stage" that is basic to the historic Grounds.
• There is no indication in the Recreation section 4.4.2, pages 4-48 and 4-49, of how much of the Grounds area will no longer be accessible to the public if the security proposals are constructed.
• Page 5-1 indicates that Alternate A would "slightly reshape" the Grounds mound. Cut and fill operations would be conducted. Where is the basis of this conclusion? How much reshaping is proposed? Page 5-2 indicates slopes would be retained between 3 percent and 8 percent. Any slope above 3 percent is visible to the naked eye. Again the EA concludes that this would be a "minor impact". This is an unsupported value judgment.
• The Geology Impacts, pages 5-3 and 5-4, neglects to provide the basis for negligible impact findings. Conclusions on the substrate impact are vague and indicate "not likely to be significantly modified or unbalanced". No evidence is presented to make a definitive conclusion. The mitigation elements mentioned on page 5-6, indicate that "Extensive and detailed geotechnical investigations and calculations are being undertaken prior to initiation of construction". Such a mitigating stipulation makes the EA findings PREMATURE.
• The Structural Integrity discussion on page 5-18 and 5-19 are speculative. Using terms such as "portends well" raises unanswered questions.
• Mitigation stipulation on page 5-20 indicating that the NPS "will continue engineering analysis to ensure that excavation and construction through the foundation will be conducted without harm to the Monument's integrity". This underscores that the EA conclusions are PREMATURE. The EA invites trust instead of demonstrating reliability.
• The conclusion on page 5-21 that Alternate A`s proposal would help preserve the cultural landscape quality of the Grounds is limited to one design solution ONLY. There are always less intrusive design solutions possible. Not enough design alternatives have been studied in the EA.
• The scale for the Simulation views, pages 5-25--5-32, are inadequate and do not show the proposed skylights. Simulation # 4, although mentioning the completion of the German-American Friendship Garden, does not show the garden. The brown barricades on the simulation diagrams are not described and no scale is provided. Simulation #7 does not indicate ground level skylights.
• Section 5-3, Visitor Use and Experience, does not provide all the "Certain assumptions were made". It was assumed that the visitor facility would accommodate the number of visitors acquiring tickets. Such an assumption needs to be related to the space provided in the design. This is not documented.
• Page 5-33 indicates minor impact of the change on the desired visitor experience. Visitor satisfaction would remain stable. How was this measured?
• Pages 5-35 -5-37 deals with the tour of the Monument. No assessment of the new underground center and its relationship to the uplifting experience of the Monument is provided.
• Page 5-37 admits that the underground facilities would "change the experience", "overall adverse impacts…would be minor". There is no basis for this conclusion. This is simply a judgment by the consultant team preparing the document.
• Page 5-37, second full paragraph, indicates, "This circular return would result in minor negative impacts…" Further design improvements could solve these negative impacts.
• Cumulative Impacts identified on page 5-38 are vague and provide no studied basis.

Chapters 6 and 7, Environmental Consequences for Alternatives B and C, contain very general statements including unsubstantiated opinions and offer little basis for the conclusions reached.

Chapter 8 is incomplete because the Section 106 consultation is not complete.

With all of the above mentioned inadequacies the EA should not be presented to the NCPC for consideration as part of any further design review. Instead, a full Environmental Impact Statement (EIS) needs to be initiated, including the completion of all necessary studies. When a final finding of no significant impact is based on a full EIS, then preliminary and final design requests should be made.

Comments submitted on behalf of The National Coalition to Save Our Mall by:

George H. F. Oberlander, Treasurer

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