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NATIONAL COALITION TO SAVE OUR MALL
113 N. Washington St., #479 Rockville, MD 20850
www.savethemall.org (301) 340-3938

July 25, 2002

Chairman John V. Cogbill, III
Chairman, National Capital Planning Commission
401 9th Street, NW
North Lobby, Suite 500
Washington, D.C. 20576
VIA FAX: 202-482-7272

Dear Chairman Cogbill:

Now that the National Park Service’s controversial Washington Monument project has been taken off the August 1 agenda, we urge the NCPC to hold a special public hearing to evaluate the Environmental Assessment’s adequacy. Only after that review is concluded and public concerns are addressed should NCPC be prepared to consider “preliminary design review”.

Before that hearing, we respectfully request a meeting with you and other commission members to discuss possible solutions for dealing with the inadequacies of the Section 106 and NEPA processes for this NPS project.

The need for a delay is plain. The NCPC environmental review for the project is not yet completed. The EA prepared by the NPS with the collaboration of the NCPC is inadequate and flawed. We pointed out various deficiencies and questions in our comments submitted to the NPS in June (attached). The EA has also been criticized by the National Trust for Historic Preservation, the National Parks Conservation Association, the Committee of 100 on the Federal City, and ANC2A-05 (attached). The FONSI issued on July 22 fails to adequately respond to these public comments. It is, therefore, again premature, inadequate, and unsupportable.

With respect to the additional alternatives attached to the FONSI, please remind the staff that the environmental procedures call for treating alternatives examined in a comparative and equal fashion with the preferred alternative. This is called for 40CFR Sec. 1502.14.

In addition, we agree with the Committee of 100 and ANC2A-05 Commissioner Dorothy Miller that the Section 106 process has not shown “substantial progress”, as required by the Programmatic Agreement (letters attached). No NCPC meeting should be scheduled – even if requested by the NPS -- until the concurring parties agree that substantial progress has been made and the 106 is complete.

The NPS has restricted public access to data, making it difficult to review the project’s changing design. The design continues to undergo revision, and NPS provides only the minimal 5 days for comment. We are particularly disappointed, as an interested consulting party in the 106 process, that the NPS no longer notifies the National Coalition of the consultation meetings and of revisions to the project. As a result, we have been unable to participate in the most recent meetings and exchanges of information. Whether that is because we have not yet signed the PA, we do not know. In our letter to John Parsons we stated that we were not prepared to sign “at this time.” However, we continue to be very interested in participating in the public process and regret that we will no longer have the opportunity to study documents and drawings before they are presented at the NCPC hearings. It is difficult to provide serious and thoughtful comments in such an impromptu situation and at the distance the public sees the drawings in the commission’s chambers.

Mr. Chairman, the Section 106 and NEPA processes are only as good as the people and agencies want them to be. Almost six months have passed since the NPS rescinded its premature original FONSI on the Washington Monument project. But little has changed during that period. The project continues to move forward, despite public controversy, inadequate engineering study, lack of important documentation (including the Cultural Landscape Report), and serious questions about whether the solution may be a great security hazard than the current situation at the Washington Monument. You have, no doubt, read the opinion of Bob Hershey, President of the local Engineers Society, who has publicly stated that the tunnel is the wrong way to go. The NCPC has an important role in guiding the NPS to fulfill its responsibilities under the law.

Please contact us soon about the possibility of a meeting with you. You can call me at 301-340-3938 or call George Oberlander at 301-654-6637.

Sincerely,

(signed)
Judy Scott Feldman
Chairman

5 Attachments

cc. John Fowler, ACHP
Fran Mainella, NPS
John V. Cogbill III, NCPC
Harry Robinson, CFA
Congresswoman Norton
Gregory McCarthy/David Maloney, DCHPO
Richard Moe, National Trust
Ann Hargrove, Committee of 100
Dorothy Miller, ANC2A-05
Joy Oakes, NPCA
other concurring parties

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