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| National Parks Conservation Association September 19, 2002 Mr. Harry G. Robinson III, Chairman Re: Proposed National Park Service Washington Monument “Security Improvements” Project Dear Chairman Robinson: NPCA commends the Commission of Fine Arts’ critical review of this project, which demonstrated that the required historical and cultural landscape studies had not been completed. Currently, these studies are still unavailable, however, the NPS is asking the Commission – on Thursday, September 19, 2002 – to approve new modifications to the continually evolving design. NPCA respectfully requests that the Commission make no final decisions until its decisions can be informed by completion of the required historical and cultural studies, and by public comment on those studies. The Washington Monument is a central symbol of America’s capital, and a central element of America’s town square, the National Mall. Changes to meet security concerns and to enhance the visitor experience must be carefully evaluated, including by the public. NPCA is concerned that the current project proposed by the NPS would have an adverse impact on the integrity of the National Mall, and on the historic L’Enfant and McMillan Plans for the nation’s capital for which the Commission has oversight. Without the analysis that the still-unavailable cultural and historical landscape reports will provide, no one can fully understand the extent or nature of the impact the proposed changes will have on the National Mall. The National Historic Preservation Act’s Section 106 process must be completed prior to final decisions, but it remains incomplete. Consulting parties to the Programmatic Agreement have not been able to gain access to crucial information or to agree to the NPS’s designs for the tunnels, walls, and changes to the historic Lodge. Alternatives to the proposed designs – such as the Committee of 100’s alternative submitted by architect and historic preservationist Don Hawkins – must be given serious consideration, yet to date such alternatives have been ignored. Moreover, consulting parties received the NPS’s latest changes to the project on Wednesday, September 11, with a deadline for comment Monday, September 16, inadequate time in which to analyze the latest changes. It would be premature to approve the NPS’s plans based on historic preservation grounds alone. One alternative NPCA recommends be analyzed is to locate a visitor center near but not on the National Mall, a center that would interpret all of the Mall’s monuments and memorials, and could also provide security screening prior to visitors being transported via shuttle to the Washington Monument. To our knowledge, this alternative has not been given consideration or thorough analysis. Such an alternative would address the issue of the eventual cumulative clutter that will result if separate interpretative facilities for the Mall’s monuments and memorials are sequentially proposed and built one by one. Finally, NPCA is concerned about the NPS’s issuance of their Finding of No Significant Impact (FONSI) in light of its failure to directly respond to public comments regarding the inadequacy of its Environmental Assessment of the project. The FONSI fails to answer concerns about the project’s feasibility and its impact on the environment. The NPS would be amending the National Register qualities of the National Mall, the Washington Monument Grounds, and Washington’s historic plans. This lack of response is troubling. In closing, we urge you to make any decisions about this proposal informed by the results of studies currently incomplete, and by the public’s response to those studies. Thank you for your consideration. Please feel free to contact me with any questions or concerns. Sincerely,
cc: CFA Commissioners |
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