September 17, 2007
Dear Coalition Friends,
The National Park Service (NPS) has announced its intent to prepare an Environmental Impact Statement (EIS) and Plan for the National Mall, in accordance with the National Environmental Policy Act of 1969. See the Federal Register: September 6, 2007 (Volume 72, Number 172)]. According to the notice, Information related to public involvement opportunities will be provided at the following park Web site.
The National Coalition to Save Our Mall takes some credit for this positive turn of events.
On November 30, 2006, shortly after the NPS announced its initiation of a Mall plan, Coalition board member, attorney Thomas Jensen, wrote NPS then-Superintendent Vikki Keys asking, "Is the National Park Service conducting this process pursuant to the requirements of the National Environmental Policy Act (NEPA)?...I have been unable to locate any public notice...has the NPS invited...any other federal, state, District of Columbia, regional or other government entities to participate in the effort as "cooperating agencies"? ...how does this planning process relate to the several other NEPA-based planning efforts currently underway for particular topical or geographic segments of the Mall, such as the transportation plan?" The wait was more than ninths months, but the upshot is the announcement that NPS intends to begin the EIS process.
Prior to the EIS announcement, the NPS held one public symposium on its Mall plan, in November 2006, where the public was allowed to ask questions but not to engage in discussion. Otherwise NPS has collected public comment through a comment page on its website .
Now with announcement of the EIS, we expect to see a more open and public process. We will keep our readership informed so that we all can play an active part in the public consultation and review of alternatives.
Several questions we and other organizations raised about the project earlier this year will need to be answered from the beginning of the NEPA process. A key question concerns how the NPS will deal with the problem of divided management and oversight of the National Mall -- see our flowchart of the multiple Congressional committees, government agencies, and review bodies with jurisdiction over the Mall, click on "NEW: Who's in charge of the National Mall?"
Here are some excerpts from our March 2007 letter to NPS. You can read our entire letter, and comments by the National Parks Conservation Association and the Guild of Professional Tour Guides of Washington, DC, here .
SCOPE
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...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...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...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... 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.
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) 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...
We'll let you know when we learn of the next steps in the process.
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