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| NATIONAL COALITION TO SAVE OUR MALL January 2, 2003 Ms. Patricia Gallagher, AICP Dear Patty:
We are writing specifically to ask that you reopen the public comment period for the Finding of No Significant Impact (FONSI) for the Washington Monument Security Improvement project, which the NCPC issued on December 16, 2002. According to the December 23 postmark on the notice, the NCPC mailed out the FONSI one week after it was issued and signed, and only one day before the deadline for public comment on December 24 (Christmas Eve). With the crush of holiday mail, that made it impossible for the public to have received it, much less to be able to prepare any timely response. Additionally, we are surprised to see that you signed the FONSI on December 16, the same day that the NCPC released the Notice of Public Availability. What is the point of the public comment period if those comments can have no effect on your FONSI? We are disappointed that at the December 13 Section 106 meeting at your offices no mention was made to the Concurring Parties of the impending FONSI. The fact that the NCPC Executive Director signed the FONSI just three days after that meeting is especially troubling. At that meeting serious environmental questions and concerns were raised but not answered concerning the adequacy of the NPS's environmental assessment and engineering reports, as well as the NPS's Peer Review study. These are NEPA issues, not simply process matters as it pertains to the National Historic Preservation Act, as representatives of the NPS have implied. But the NCPC's FONSI does not take them seriously. For example, NCPC's FONSI acknowledges that "the Coalition has identified limitations of the EA" and then states that "the Commission staff does not believe the EA….is fatally flawed or deficient." What does that mean? Does it mean that the EA is flawed? On December 23, 2002, the Advisory Council on Historic Preservation issued comments to the National Park Service that appear to directly contradict NCPC staff's view that the EA provides sufficient and adequate information to evaluate the project. The public consultation process - and the legitimacy of the Programmatic Agreement to which NCPC and the Coalition are Concurring Parties - is only as good as the parties wish to make it. In our view, the surprise FONSI shows a lack of good faith. We respectfully ask that you rescind the FONSI and reopen the comment period to allow meaningful input by the public. May we suggest that you reexamine the adequacy of the NPS's EA and FONSI, and the NCPC's FONSI, with close attention to the National Park Service's Director's Order #2 and #12. We think it is important also that you consult with the Advisory Council on Historic Preservation regarding the adequacy of the EA and your FONSI. Due to the scheduling of the January 9 presentation, a prompt decision and response to this letter is appreciated. Yours truly,
cc. John V. Cogbill III, NCPC |
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