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Advisory Council on Historic PreservationDecember 23, 2002 John G. Parsons REF: Construction of Permanent Security Improvements Dear Mr. Parsons: Thank you for your reply to our request of November 14, 2002 to Mr. Terry Carlstrom, for clarification of the status of Section 106 consultation pursuant to the Programmatic Agreement for the referenced undertaking among NPS, the Advisory Council on Historic Preservation (ACHP), the District of Columbia State Historic Preservation Office (SHPO), the National Capital Planning Commission (NCPC), and concurring parties. We have reviewed the information provided, including the materials submitted to NCPC for consideration at their Commission meeting of January 9, 2003, and also supplied to the Agreement's signatories and concurring parties, pursuant to Stipulation 3 of the Agreement. In addition, on December 16 and 17, we participated in discussions among NPS, the District of Columbia SHPO, NCPC, and the project architects concerning anticipated modifications to the current proposal, toward reducing the proposal's effect upon the Washington Monument and grounds. Our responses to the information reviewed are as follows: 1. Filing of original Agreement with the ACHP: We appreciate receiving the original copy of the final Agreement as requested; however, it is our understanding that NPS will be providing one additional original signature page, representing the concurrence of the Washington National Monument Society. 2. Schedule of formal reviews: Your letter informed us that the next anticipated formal project review will be before NCPC on January 9, 2003. However, based on discussions at the meetings of December 16 and 17, we understand NPS plans to present, for discussion purposes only, one or more variations on the proposal for the Monument Lodge, as submitted to NCPC and the consulting parties pursuant to Stipulation 3 of the Agreement. We note that Stipulation 6 of the Agreement provides for notification to signatories and concurring parties when there is a change to "previously reviewed components of the Undertaking." While this stipulation applies to the changes represented in the current submission to NCPC, it does not cover the variations to the design NPS plans to introduce for discussion. To ensure that Section 106 consultation includes all design proposals currently under consideration by NPS, we request that NPS provide copies of these alternatives to the signatories and concurring parties at least three days prior to the scheduled meeting on January 9th, thereby allowing the parties to respond to any new direction in project design that may now be under consideration. 3. Schedule of documentation to be developed: We requested clarification of the status of documentation referenced in Stipulations 8, 9, and 10, including schedules for interim drafts as needed for decision making. Your response indicates that no further information regarding either the historic Monument Lodge structure or the Washington Monument grounds historic landscape, has been made available pursuant to Stipulation 8 since the interim memoranda that were prepared by NPS staff in July 2002. Completed documents, according to your letter, are not expected until March and June 2003, respectively. We have consistently supported the principle contained in Stipulations 8, 9, and 10, whereby decisions are to be based on information as it becomes available and as drafts of studies are accepted by NPS. However, if the Agreement's terms are to be met, the project must meet the Secretary of the Interior's Standards, to the extent feasible, as stated in Stipulation 1. An evaluation of the project's success in meeting this requirement is seriously impeded at this time because no additional information has been made available for evaluating National Register issues as they relate to the project's design and its conformity with the Standards. Importantly, the Agreement recognizes that security measures may place demands on the design that could interfere with the project's ability to conform with the Standards. However, the Agreement requires that all such decisions be made with full consideration of effects to historic properties. Although the development of additional variations to the proposed design presents a situation that was not anticipated in the Agreement, we commend NPS for responding to comments by the signatory and concurring parties through development of additional design schemes, whose merits may now be considered by participants in the Section 106 process. We particularly wish to encourage certain design directions that we understand now to be under consideration, including: minimizing the size and scale of the above ground features such as the addition to the Monument Lodge, including eliminating or minimizing the skylight above the underground visitor facility; and creating an architectural design more in keeping with the existing historic setting, a goal which, in our view, could be advanced through creating a simpler version of the model of a more traditional addition that we viewed on December 16 and 17 at the offices of Hartman-Cox Architects. We note that, although the Secretary's Standards recommend distinguishing new construction from old in order to prevent creating a false sense of history, the major emphasis of the Standards is on compatibility of new elements with the historic character of buildings and landscapes into which they are being introduced. The currently proposed design, as represented by the submission materials to NCPC for review on January 9, does not, in our view, achieve that compatibility with the Monument Lodge, the Washington Monument and grounds, or the National Mall. We look forward to working further with you and thank you for your continued cooperation in implementing the Agreement for this undertaking. Sincerely, Don L. Klima |
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