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NATIONAL PARKS CONSERVATION ASSOCIATION
Protecting Parks for Future Generations

June 21, 2002

Mr. Arnold Goldstein, Superintendent via email and fax
National Capital Parks – Central (original mailed)
National Park Service – National Capital Region
900 Ohio Drive SW
Washington, D.C. 20024-2000

Dear Mr. Goldstein:

Re: Washington Monument Permanent Security Improvements Environmental Assessment (EA), April 2002

Thank you for developing this draft EA and extending the public comment period. On behalf of the 350,000 members of the National Parks Conservation Association, I urge you to make no decisions concerning the proposed visitor center underneath the Washington Monument and related elements on the Monument grounds until technical studies still underway when the draft EA was released are completed and reviewed with adequate notice by the public. Given the controversial nature of the proposal and the incomplete nature of the EA, we respectfully request that the National Park Service (NPS) undertake a complete Environmental Impact Statement.

In this centennial year of the McMillan Commission, we are reminded of the critical roles of both a compelling and broad vision for America’s National Mall, and of meticulous attention to the details of projects implementing that vision. Without a broad vision, individual projects combine to form an incoherent whole. Without proper and reasonable attention to detail, one project may unintentionally sabotage the overarching vision. The Washington Monument is literally and figuratively at the center of the vision for the National Mall; because of its physical and symbolic prominence, proposed changes demand the highest level of reasonable deliberation and analysis.

Based on our review of the draft EA, we specifically request that the NPS prepare an EIS that addresses the following concerns:

1. An EIS should include two or more underground alternative designs and two or more above ground alternative designs, including plans, elevations, sections, and vista analyses that clearly show the full scope, size, and details of the proposed project, in addition to the “no action alternative.” The draft EA provides only one underground and only one above ground alternative, and lacks key details such as the location and configuration of emergency exits along the length of the proposed tunnel, and how they would appear at Mall level. The draft EA does not show design changes made incrementally over the past few months including changes to the Lodge. “Alternatives considered but eliminated” (Section 3-5) includes decades-old efforts considered primarily to accommodate visitors, not to increase security.

2. An EIS should provide detailed technical information not provided in the draft EA, and critical to determining a preferred alternative. For example, it should include engineering analysis of potential impacts on the Monument from the probable need to remove and replace soils contaminated with arsenic under Alternative A. The draft EA notes at 5-6, “Extensive and detailed geotechnical investigations and calculations are being undertaken prior to initiation of construction.” It notes at 5-20, the “NPS will continue engineering analyses to ensure that excavation and construction through the foundation will be conducted without harm to the Monument’s integrity.” These two statements underscore the premature nature of the conclusions drawn in the draft EA, and the need for a complete EIS.

3.The EIS should detail on what basis the NPS determines that one design will provide more security than another. For example, the EA does not provide information as to why the NPS prefers walls that would allow vehicles within 400 feet of the Monument to street-level bollards that would stop a vehicle much further away.

4.The EIS should analyze the potential destabilizing impacts an explosion in the underground facility could have on the Monument. The draft EA provides no such analysis.

5.The EIS should provide detailed information on the impacts on visitor use and experience from the alternatives. For example, the EA provides no assessment of the total time visitors would be confined to an underground enclosed space in Alternative A. While the EA does note that the underground facilities would change the visitor experience, it concludes that the adverse impacts would be minor. There is no basis for this conclusion other than opinion. A reasonable opinion would be that this is a significantly altered experience compared to the dramatic visual impact of walking up to the world’s largest freestanding stone structure, the Washington Monument at ground level. Section 5-3 assumes that the visitor facility would accommodate the number of visitors acquiring tickets, but does not document the relationship between those numbers and the space provided in the design.

We respectfully request a minimum of 90 days for public review and comment, and include at least one public hearing in Washington, D.C..

Thank you for your consideration of our views. Please include us in the list of organizations and individuals to whom you provide advance notice of future NPS actions concerning this plan.

Sincerely,

(signed)

Joy M. Oakes Mid-Atlantic Director

cc: The Hon. Eleanor Holmes Norton
The Hon. Donald Murphy, NPS
Mr. Terry R. Carlstrom, Regional Director, NPS National Capital Region
Mr. George Toop, NCPC
Mr. John L. Nau, ACHP
Mr. Don Klima, ACHP
Ms. Martha Catlin, ACHP
Mr. Gregory McCarthy, DC SHPO
Ms. Ann Hughes Hargrove, Committee of 100 for the Federal City
Mr. David Bell, DC Preservation League
Mr. Robert Nieweg, NTHP
Mr. Jim Dougherty, Sierra Club
Judy Scott Feldman, Ph.D., National Coalition to Save Our Mall
Ms. Marcia Argust, American Society of Landscape Architects
Ms. Dorothy Miller, Commissioner, ANC-2A

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