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March 12, 2007

Ms. Susan Spain
Project Executive
The National Mall Plan
National Park Service
900 Ohio Drive, SW
Washington, DC 20024-2000

RE: National Park Service / National Mall Management Plan

Dear Susan:

Thank you for the opportunity to comment during the scoping phase of planning for the National Mall management plan. The following comments are submitted on behalf of the National Coalition to Save Our Mall and our more than 1500 friends nationwide. The Coalition is a non-profit grassroots citizen’s organization dedicated to the enhancement and protection of the National Mall.

We welcome the NPS effort and we look forward to the opportunity to engage in meaningful public discussion and exchange of ideas with NPS planners, the professional community in Washington that has shown a strong interest in Mall matters, and national groups who represent the Mall’s national constituents. As I mentioned to you during our conservation at the "Welcome Pierre!" event a couple of nights ago, those of us devoted to making the Mall an even better place for future generations have historical knowledge and expertise, connections to other local and national citizens groups, and practical know-how we would like to contribute to the NPS plan.

The National Mall is the landscape and architectural representation of American founding ideals and national identity. It is the symbolic heart of the capital and the nation. It is an economic engine for the city and region. In the 20th century the public made it the central civic stage for our democracy. Yet, the last 100-year vision for the Mall, the McMillan Plan, is now over a century old. The nation and the city of Washington need an updated 100-year plan for the Mall as a whole for the 21st century. And given the Mall’s evolving function as civic stage, the public needs to have a strong and meaningful voice and role in creating a 100-year plan.

The task is, at it was a century ago, much bigger than any one existing government body can undertake. Because Mall management and oversight is fragmented among many agencies and Congressional committees, and the public has no meaningful role in either management or oversight, the Coalition believes that Congress needs to create an independent National Mall Commission. The Commission can be composed of nationally recognized cultural leaders able to help the nation create a vision and plan for the National Mall as a symbol of national identity. The NPS plan can be an important component of that larger 100-year vision.

The Coalition has assembled materials from a number of our reports, public forums, and correspondence that we believe identify some of the questions and topics that need to be addressed.

SCOPE
We need to be certain that the scope of the planning efforts includes the entire symbolic core, not only the areas under NPS jurisdiction (see Attachment #1 (PDF, 120k) — "January 13, 2007 letter to Vikki Keys/NPS, from Thomas Jensen/Sonnenschein Nath & Rosenthal, LLP"). We have drafted a flow chart of the complex management, oversight, and review authority for the Mall (see Attachment #2 (PDF, 484k)— "Who’s in Charge of the National Mall?"). How will NPS deal with the five other agencies with jurisdiction over parts of the Mall, the eight Congressional committees with oversight, and the eight review agencies?

MALL DEFINITION
Much of the confusion in Congress and among government agencies, the media, and the public about who’s in charge of the Mall comes from the lack of definition of its physical boundaries and its purpose. The NPS’s assertion that it alone has jurisdiction over the Mall appears to be based in a definition that limits to the Mall to the strip of grass and "memorial parks" under its jurisdiction but which excludes the Smithsonian museums, National Gallery of Art, the Capitol, and other areas. Yet even within the NPS documents there are different and even contradictory definitions of the Mall, as shown in the attached compilation of statements (see Attachment #3 (PDF, 12k) — "Questions About the National Park Service’s Comprehensive Management Plan"). What definition of the National Mall is NPS using for its plan? What is the basis of that definition? How does it relate to the historic L’Enfant and McMillan Plans on which the Mall is based?

OTHER MALL-RELATED PLANS
Besides NPS, other agencies are currently working on plans that have a direct or indirect bearing on the Mall. We have compiled a list of current planning initiatives by various government agencies, including DC Govt., NCPC, and the Architect of the Capitol (see Attachment #4 (PDF, 124k) — "Mall Related Planning 2007"). How will NPS coordinate its plan and goals with those others that have their own separate and different goals?

URBAN PARK
The Mall needs to be considered a prime city park, not just an iconic national park. The Center City Action Agenda and the DC Comp Plan (shown in Attachment #4 (PDF, 124k) — "Mall Related Planning 2007") make clear the Mall’s centrality to the city. We need to be certain that the city is actively engaged, a contributing member to the NEPA and planning process. How will NPS engage DC Government as well as local citizens in meaningful dialogue?

EIS
An EIS is needed, not simply an EA, for this project. In the past 40 years since the NPS updated its Mall management plan, the Mall has undergone dramatic changes with the addition of memorials, museums, and security enhancements. EAs were done for some of these projects, but no EIS. Some projects have proceeded with even an EA. A new and potentially disastrous threat to the Mall’s physical and cultural integrity is flooding, as documented in NCPC’s new draft report on flooding and stormwater. The NPS should undertake a full EIS so that any planning could be based on a full and complete evaluation of current conditions and future potential adverse effects on the Mall.

PUBLIC INVOLVEMENT- LOCAL
Because the Mall functions today as more than a collection of monuments and memorials, or a grand landscape, the public needs to be given a meaningful role in decision making. So far, there has been a symposium where the public was only allowed to ask questions but not engage in discussion. And there have been a number of open-house type public events. But those events, where NPS officials stand with maps and plans and invite public comment, limit input by the public to reacting to NPS concepts. They do not allow citizens to engage in discussion with NPS planners and with one another. The NPS should provide a forum setting that allows better dialogue. For example, the Coalition has participated in other 106 and NEPA projects with NCPC and Smithsonian which typically bring together citizens with planners around a table for an open exchange of ideas and discussion

PUBLIC INVOLVEMENT — NATIONAL
While we are aware of the difficulties of engaging the national public in a consultation, some additional means should be sought beyond a national PR campaign in the media and a website. The kind of comment gained from this kind of campaign is limited to superficial points. A website is not an adequate forum for informing the nation’s public and encouraging an exchange of ideas beyond a spontaneous response to a questionnaire. How is NPS going to actively interact with the public and encourage discussion?

HISTORIC PRESERVATION
What is the period of significance that is the historic basis for the NPS National Mall Plan? NPS maps and materials all show individual monuments and memorial parks, however the historic plans conceive the Mall as a unified whole, including the open space. What is the significance of the L’Enfant Plan to this Management Plan? The McMillan Plan? The NPS Skidmore Owings Merrill (SOM) Plan from 1960s that some NPS documents refer to as the NPS master plan?

PUBLIC USE AND RECREATION NEEDS
Our 2004 public forum report (The Future of The National Mall at http://www.nationalmall.net/reports/reports.html) underlines a strong need for food and transportation. These concerns and many others have been continually echoed by citizens through correspondence, radio talk shows, and public forums. For the Coalition’s "Citizen’s Guide to Recreation on the National Mall" we identified problems and proposed solutions (outlined in Attachment #5 (PDF, 24k) — "Research Findings for the Citizens Guide to Recreation on the National Mall").

A basic summary of all these public use needs not presently met includes:

o Bike racks, pedestrian trails, and amenities along these trails
o Good, green grass that can accommodate people and activities
o Multiple types of transportation beyond "interpretive" Tourmobiles, such as a convenient and low cost shuttle
o Better signage and maps along the Mall
o Clean bathrooms which are convenient for pedestrians
o 24-hour services so the Mall does not completely shut down at night in some areas — shelter, restrooms, convenient first aid, and police presence day and night
o Recycling bins
o Good food in small carts situated where people walk and bike
o More and improved recreational spaces
o Play areas for families and kids
o Better maintenance of existing facilities
o More tree cover in many areas to increase cooling
o WiFi throughout Mall
o Lots of moveable chairs and tables near food as well in well-spaced resting areas
o Regular public surveys and meetings which meaningfully gather and implement ideas from citizens

Again, on behalf of our 1500 members, thank you for making public comment a part of the National Park Service Mall Management Plan development process.

Sincerely,

W. Kent Cooper, FAIA
Vice Chair and Third Century Coordinator

Judy Scott Feldman, Ph.D.
President and Chair

attachments

cc: Ms. Mary McVeigh
National Park Service
Attn: National Mall Plan
Public Comments
Denver Service Center
12795 W. Alameda Parkway
Denver, CO 80225-0287

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