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Concerns about the Park Service's
Washington Monument Security Improvement Project
July 2003
THE TUNNEL, PUBLIC SAFETY, AND THE STABILITY OF THE MONUMENT
- Blast expert and President of the D.C. Society of Professional Engineers, Dr. Robert Hershey, P.E., has testified repeatedly - as well as sent a letter to National Capital Planning Commission (NCPC) Chairman John Cogbill -- stating that the tunnel will be a public safety hazard creating a new security problem, but his comments have been ignored or dismissed without discussion by NPS. Is public safety not an equal goal of the security improvement project? Could public safety issues force the NPS to reconsider the tunnel and all the related portions of the design?
- Public and media ridicule of the controversial tunnel concept has fallen on deaf ears. Even NPS's own report on the tunnel concept, originally proposed in 1973, stated that it would be "expensive and oppressive." Why does NPS refuse to consider alternatives proposed by the Coalition, the Committee of 100 on the Federal City, and other participants in the public consultation process?
- Compounding the problem, the NCPC "accepts" Park Service conclusions regarding contested environmental and public safety information, instead of evaluating the quality of those conclusions and taking into consideration public comments. As a result, there has been a serious lack of oversight and cross-checking of Park Service data, facts, and conclusions.
- The NPS plan is doable but is it worth the risk? The NPS's engineers evaluate the feasibility of the design but they do not - and are not expected to - weigh the risks. However, there is a long history of geotechnical concerns about the stability of the Monument. In 1930 Congress took the important role of setting up an independent engineering commission to evaluate the risks involved in carrying out the McMillan Plan's design for steps and terraces on the Monument Grounds. Based on the recommendations of that commission - and despite conclusions by architects and an engineer that the McMillan Plan was doable and safe - Congress decided that the plan was too risky and should not be implemented. Then there is the "subsidence" component - the structure could sink or settle due to loss of support. The Coalition believes that Congress should appoint an engineering commission to evaluate the risks of the current tunnel plan before providing funding for its construction.
HISTORIC PRESERVATION
- The Park Service's "Security Improvement" design -- locating barrier walls on the open public space and constructing a new 60-foot addition to the Monument Lodge -- is in direct conflict with the L'Enfant and McMillan (and SOM) concepts of the Mall. However, NPS has refused to consider additional reasonable alternatives to its preferred plan.
- The NPS did not submit the project for review before the National Capital Memorials Commission (NCMC) and so avoided or ignored this important step for determining whether the project conforms with the Commemorative Works Act and its provisions protecting the L'Enfant and McMillan Plans and the Mall's open public space (see Park Service Conflict of Interest below).
- However, even the NPS has in the past criticized similar curvilinear schemes as contrary to the L'Enfant Plan. NPS's 1981 Development Concept Plan and Alternatives report, in its review of the various historic design schemes for the Monument since 1791, criticized the 19th century Downing Plan's "curvilinear walks" on the Monument grounds as having "obliterated the formal east-west axis of the L'Enfant plan."
- Why is the NPS resurrecting an unacceptable design concept instead of considering alternatives that would preserve the L'Enfant plan? Even worse than the curved walkways, why is the Park Service also designing curvilinear barrier walls that will further desecrate the L'Enfant axis by physically blocking access and vistas?
TIMETABLE FOR DESIGN APPROVAL AND CONSTRUCTION
- Deputy Director Don Murphy was unrealistically optimistic when in testimony before Congress on March 19, 2003, he stated that NPS would be seeking final approvals for the plan in May. In June 2003 the National Capital Planning Commission (NCPC) gave final approval only for the landscape portion of the plan. Major portions of the project - including the underground components - have not yet received preliminary or final design approval. If they are rejected, that would require redesign of all of the interrelated parts of the whole.
- The timetable released on May 14, 2003 by NPS regarding approvals already granted is incomplete and misleading in that it lists "approved" for portions of the project which have received only preliminary, not final, approval. Preliminary approval can be rescinded by requiring design changes in the project for final design review.
- In response to Congressman Dicks' Question 1 regarding removal of the jersey barriers, NPS writes that it "anticipate[s] construction starting on the Washington Monument in October 2003." Given the delay in design development, review, and approval, this does not appear to be realistic.
- The Commission of Fine Arts (CFA) expressed disapproval of the tunnel concept in early 2002, and since then the NPS has not submitted the project to CFA for additional public review. Deputy Director Murphy did not tell Congress about this potential roadblock to swift approval.
SOLE-SOURCE CONTRACTS FOR $40 MILLION SECURITY/VISITOR PLAN
- NPS insists that the project is a security screening facility, and not a visitor facility, so as to assure continued funding. However, the design is based on a 1973 concept for a visitor center (revised in 1981, 1989, and 1993) that was never funded by Congress. Blast experts have stated that the new tunnel component, instead of making the Monument safer, will in fact create a new public safety hazard. The Coalition is concerned that NPS's desire to realize its decades-old visitor center concept is driving this project, and not security and public safety considerations.
- NPS justifies its sole-source, noncompetitive contracts for this project on National Emergency grounds. In fall 2001, NPS modified a 1998 maximum $5 million contract for "preservation" into a $40 million contract for "security improvements." (The Coalition obtained the contracts, task orders, and modifications through the Freedom of Information Act.) However, the Monument is secure right now -- as NPS stated in its written response to the House Interior Appropriations Subcommittee and as Park Police Chief Chambers testified in 2002 - and the public is justified in questioning whether the public interest is being well served by the noncompetitive contracts.
- The Jersey barriers may be unsightly, but the public may object as well to the NPS's plans to place equivalent 30" high stone walls in the open landscape around the Monument, instead of more appropriately at sidewalk level. Have the signed contracts prevented the NPS from considering alternatives to its preferred plan?
PARK SERVICE CONFLICT OF INTEREST
- The Park Service representative administering the Washington Monument project also serves as Chairman of the National Capital Memorials Commission (NCPC) and votes on the project as commissioner on the National Capital Planning Commission. The Park Service representative has refused to recuse himself from voting on the project at the NCPC when asked to do so by the Coalition. Significantly, he has cast the deciding vote in favor of the project on at least one occasion. This is clearly a case of conflict of interest.
- Instead, the Chairman of the NCMC - the same Park Service representative sponsoring the Washington Monument project and who votes on design review at the NCPC - apparently determined that the CWA does not apply. However, the Coalition believes that the Commemorative Works Act does apply and that the proposed plan violates its provisions (see above, Historic Preservation)
- It is important to note that while the Park Service states that the Commemorative Work Act does not apply to the Washington Monument visitor/screening center, both the NPS and the NCMC have opposed the proposal for a Vietnam Memorial Visitor Center on the grounds that it would violate the Act.
- As a result of its determination that NCMC would not review the project, the Park Service avoided the important initial step in the review process regarding the project's compliance with provisions of the Commemorative Works Act that protect the L'Enfant and McMillan Plans and the Mall's open public space. Again, this is a case of conflict of interest and a failure to follow the required review process.
- The Coalition is asking the Senate Subcommittee on National Parks to hold a public hearing on the project's conformance with the Commemorative Works Act.
PROJECT COSTS
- Since 2001 the National Park Service (NPS) has spent approximately $4.7 million on design development for only a portion of the entire project.** As of June 2003, NPS has not yet completed design of the major underground portions of the project, including the visitor center and the 500-foot long tunnel. How many millions more will be spent on design development alone?
- NPS is spending hundreds of thousands of dollars on studies whose data, analysis, and conclusions will not and cannot be used in decision-making. For example, the NPS "accepted" a $230,000 environmental document (an Environmental Assessment) in April 2002 and then issued a Finding of No Significant Impact (FONSI) in July 2002. However, these final decisions on the impact of the project were made before its subcontractors had even begun work on two crucial supporting documents - the $378,043 Cultural Landscape Report and Historic Building Survey. (Of course, this also helps explain the gross inadequacy of the environmental document.)
- In addition, although approvals have not yet been given for the underground portions of the projection, NPS has already signed contracts totaling $410,000 covering exhibit design for the underground visitor center.
- Have cost estimates been prepared? In response to Congressman Dicks Question #2 as to the $17.5 million for the 2004 appropriation that would be used, NPS does not actually say, but implies that it will cover only a portion of the cost of the barrier system and visitor screening facility. Does NPS know the cost of the entire project? The May 2002 Value Analysis for the project states that the project budget is $34.25 million but then says "Unfortunately, at the time of VA study, Grunley-Walsh had yet to prepare a cost estimate." What additional costs can be expected as the NPS continues with design and then construction? What is the estimated cost of the "expensive" tunnel portion?
**The Coalition obtained the contracts, task orders, and modifications for the project through the Freedom of Information Act out of concern that NPS's sole-source contract, signed in fall 2001 before any design review or public consultation had been initiated, predisposed it to refuse to consider alternatives to its controversial preferred design.
For more information and documentation supporting these statements, contact:
Dr. Judy Scott Feldman, Chairman, National Coalition to Save Our Mall, 301-340-3938
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