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Testimony before the National Capital Planning Commission
On the National Park Service's
Washington Monument Security Improvements Project
January 9, 2002

My name is Judy Scott Feldman. I am Chairman of the National Coalition to Save Our Mall, a citizens group dedicated to preserving the National Mall as the monument to democracy it is intended to be. Because of our mission and expertise on Mall issues, we had hoped we might be given more than 5 minutes, but our request was denied. The Coalition submitted four questions to NCPC yesterday and attaches comments on the EDR at the end of our testimony, which we hope you will read in full before making any decision. In my remaining time, I will summarize some of our major points.

First, I want to point out that the Coalition has been participating in the public consultation (Section 106) process with the National Park Service (NPS) since January 2002, along with the NCPC, the National Trust for Historic Preservation, the Committee of 100, ANC2A-05 and others. The frustration is palpable in those consultation meetings. The NPS promises and then doesn't deliver crucial reports. Park Service representatives refuse to examine other reasonable alternatives to their plan, dismissing our suggestions out of hand with a "that's not possible" or "we've already considered that and rejected it" or deliberately misinterpreting suggestions in such a way that they sound ridiculous and not worthy of consideration.

This has happened with all major elements of the design, and especially with regard to the greenhouse addition to the Monument Lodge. So we were surprised to receive in the mail the day after Christmas the notice that NCPC Staff had issued its own Finding of No Significant Impact (FONSI). What changed? The staff report correctly states that the NPS's plans are inadequate and they have not provided sufficient data to evaluate the entire project. Staff also observes that all parts of the design are interrelated and that they need to be evaluated as a unified program. So why does staff accept NPS's inadequate Environmental Assessment and recommend piecemeal approval of parts of the design? No part of the project should be approved at this time, including the walls, in our view, since the feasibility of this controversial plan is still in question.

The walls may look attractive but their effect on the public uses of the Monument grounds cannot be evaluated until the Cultural Landscape Report is completed in March or April. The NPS considers the walls security measures, but as presently configured to the sides of the Lodge, they will not protect the Lodge and tunnel entrance to the Monument from a truck attack from 15th Street.

At a meeting the Coalition attended on Jan. 7 with Regional Director Carlstrom and Deputy Chief Dwight Pettiford of the Park Police, one of NPS's security experts, it became clear to us that this and other security issues had not been thought through. Why does this matter to NCPC? Because if the Security Program has to change, then the Design Solution has to change as well. It is simply premature to approve any part of the design today.

Moreover, staff has done a poor job of evaluating the EA by taking the NPS's conclusions at face value and dismissing the Coalition's and others' serious questions and concerns. In our testimony we provide examples of its inadequacy, but let me just mention just two. The Coalition thinks that the controversial tunnel will degrade the visitor experience but the EA concludes that "visitor access would be improved." Where is the data to support that conclusion? (Here I would refer you to "Subterranean Blues," an article by Catesby Leigh in the current Weekly Standard.) The EA does not mention, let alone analyze as required by CEQ, past, present, and future conditions caused by cumulative effects of construction on the Mall: A. World War II Memorial ongoing construction, B. closing all or parts of the Monument grounds to build this project, C. future construction of the Martin Luther King Jr. Memorial, and D. future construction of the NPS's preferred Education Center at the Vietnam Veterans Memorial. Instead, the EA concludes "minor" impacts or even, astonishingly, "positive impact." How can the NPS and the NCPC conclude that there will be "no significant impact" when the heart of our National Mall will be carved up and closed off into separate "sacred" zones, and the historic open character and public uses of this unique public forum changed permanently?

A project of this scale and with such drastic adverse effects on the Monument grounds and the entire Mall requires a full Environmental Impact Statement. It is equally, if not more important than the closing of Pennsylvania Avenue for which NCPC correctly insisted on an EIS.

INADEQUATE ENVIRONMENTAL ASSESSMENT (EA)

The FONSI states that that the EA is "not fatally flawed or deficient." Does that mean it IS flawed? Is this the meager standard to which we hold the Park Service when it is evaluating major changes to public lands, and in particular the Washington Monument? This is unacceptable.

For many months now, the Coalition has raised questions about all major elements of plan and the EA's inadequate evaluations of them.

• For example, we worry that the walls could damage the historic open character of the landscape and impede public gatherings. The EA, though, under Historic Resources, finds instead "positive historical impact." How was that judgement made?
• We commented that the greenhouse addition to Lodge would be an eyesore, a new brightly lit element on Mall's main axis, detracting from main axis and Monument. Under Visual Resources the EA concludes "positive impact." The Monument grounds would look better, according to the EA. Why? Because visitors who now line up at the Monument plaza would be queued out of sight.
• We have asked if we risk destroying symbolism of monument and of the Mall as a whole by fortifying it and forcing visitors to burrow underground to enter. Again, please read Catesby Leigh in current issue of Weekly Standard. That aspect was not even evaluated in the EA, although it is fundamental to what CEQ calls the "human environment." Moreover, it cannot be adequately evaluated until the cultural Landscape Report is completed next April.
• We think the tunnel will degrade the visitor experience but the EA concludes that "visitor access would be improved."
• What about the potential dangers of digging a tunnel in the Monument's historically unstable soils? The EA concludes that there will be "minor cut and fill"…"Minor soil disturbance" and concludes that "the geology of the Monument Grounds would not be affected by development under Alternative A" (the NPS's plan). This conclusion was drawn, mind you, in April 2002, three months before the first engineering reports were completed. The fact that later engineering reports appear to support that conclusion does not retroactively legitimize its premature and unwarranted finding.

The so-called alternative in the NPS's EA is not a reasonable alternative at all, as required by NEPA. Its above-ground, double-fenced security pathway would block off the Monument grounds to pedestrians, and malefactors could violate the pathways by throwing weapons over its glass walls to screened visitors inside. The NPS has not followed its own policies with regard to evaluating credible other options. The DO-12 Handbook is clear that, "Alternatives that …do not resolve the need for action and fulfill the stated purpose in taking action to a large degree, should be eliminated as unreasonable before impact analysis begins." (DO-12, 2.7)

These are just a few of the reasons that the EA is woefully inadequate. What information it does provide on major excavations and changes to the grounds and visitor experience should lead to an EIS, not a FONSI. NCPC accepts the EA. But we would urge Commissioner to consult the ruling of Judge Louis Oberdorfer on July 2, 2002, regarding the NPS's insufficient EA for the Rock Creek Cell Towers. The judge ruled that the EA is insufficient and must be redone because the Park Service did not take a hard look at some impacts, did not consider impacts of construction and maintenance, and did not look at reasonable alternatives. The Coalition believes that the Washington Monument EA suffers from the same deficiencies.

SECURITY

The NPS plan is a Security Plan. However, there are serious security questions that remain unanswered. For example, while the walled walkways may protect the Monument against a truck bomb, they will not protect the Lodge, which would be the new entrance to the Monument. Screening visitors in a glass building seems a bizarre if not downright dangerous solution. The tunnel which would confine up to 500 people in an enclosure with exits only at two ends, could in fact make the Monument LESS, not more, secure.

The NPS's rationale for the tunnel is "Time and Distance" - the further screening occurs from the Monument's entrance, the more time there is for security personnel to respond in an emergency. That is not a hard and fast rule, however, since several alternatives considered by NPS in its FONSI included screening at the Monument's base and they were deemed "acceptable" from a security standpoint. Just recently we have learned that new Interior Department guidelines state that screening should occur as close as possible to the building entrance. That would suggest that the tunnel is actually less acceptable than screening right at the Monument door, which is how it is done currently with the temporary addition to the Monument. A better design has been suggested by the Committee of 100's Don Hawkins.

ALTERNATIVES

For one full year now the NPS has refused to evaluate alternatives suggested by the Coalition and others. The FONSI states that NPS considered and rejected other alternatives. But the Coalition never saw these until after the NPS issued the FONSI, when it was too late. We believe that there are other, better alternatives and that they need to be evaluated before any approvals can be given.

• We see in the EDR, for first time, that NCPC is presenting several better alternatives to the NPS's greenhouse Lodge addition, which has been sharply criticized by all. NCPC should not stop there. They, NPS, and all consulting parties should be looking at alternatives to all parts of the plan, including the walls and the tunnel.
• The Coalition believes that the Committee of 100 alternative is a simple, secure, and "invisible" solution to the NPS's security needs. It calls for placing screening machines into the existing door, and then reopening the old western door to be used as an exit. It would eliminate the need for the tunnel and the size of the visitor center could be greatly reduced.
  
  The NPS has stated that the C100 alternative won't work and that distance screening is required. But that appears to not be exactly true. The NPS's FONSI mentions more than one alternative that includes screening at the base of the Monument and calls that solution "acceptable."
  
  In the past, the NPS has rejected this solution stating that it didn't allow for "Time and Distance." The NPS's proposed design, however, only provides distance at the entrance, not at the exit. Visitors will exit through the existing door. And pedestrians will still be allowed on the Grounds and can walk up and touch the Monument. The Time and Distance principles is applied inconsistently in the NPS's plan and so is not the best solution.
• We have asked about using bollards or walls at street level to deter truck bombs. NPS rejects bollards, but that is based on a proposal rejected by CFA in 2001 that located the bollards -- perversely -- on the grass in place of the Jersey walls - making the Grounds look like a cemetery.
  
  But what about placing them at sidewalk or street level, as the Coalition has asked? That option has not been considered, although it would be less obtrusive that current plan and leave Monument grounds open, instead of interrupted and blocked by proposed walls. Bollards - including retractable bollards -- are good enough for White House and Lafayette Park and NPS has proposed them for the Jefferson Memorial. Why are they rejected out of hand at the Washington Monument?
• Instead of a tunnel, visitors could be shuttled above ground by trolley from a remote screening location to the Monument door. No new roads would have to be cut, as NPS claims. Special vehicles could be designed - and at far less cost than the tunnel - that would transport the 25 passengers for elevator and which would fit within existing walkways. These vehicles could be electric-powered, small, quiet, and unobtrusive. This solution is certainly less damaging to the Monument grounds than digging a tunnel.
• The Coalition doesn't understand why NCPC staff fails to even propose the Olin plinth wall solution from its Urban Design and Security Plan for Independence and Constitution Avenues. Continuing those walls or elements on the cross streets would create a unified security design for the Monument Grounds and the entire Mall. In addition, that would protect the Lodge and the rest of the Monument Grounds, where large public gatherings often take place. The Coalition believes the NCPC solution is superior to the NPS's plan.

You may not like any of these alternatives but there are probably others which would satisfy NEPA requirements of an "alternative that causes the least damage to the biological and physical environment; it also means the alternative which best protects, preserves, and enhances historic, cultural, and natural resources' (Q6a)" (Director's Order-12, p.23) Until, however, the NPS takes a close look at credible alternatives the Coalition and others have suggested, it will be impossible to determine which design causes the least damage to the environment. The Section 106 consultation is where we are trying to do that, and until that process is complete, NCPC should not be making a decision on this one design.

The NPS's unwillingness to evaluate other reasonable alternatives suggests that the NPS, having established its Preferred Alternative, simply went through the motions of considering alternatives in order to attempt to satisfy NEPA. The DO-12, however, expressly cautions against such actions: "Agencies often mistake this winnowing process as one that allows them to choose only their favorite alternatives for analysis without having first completed NEPA. Rather, it is a procedure for eliminating infeasible or duplicative alternatives while still leaving a 'full spectrum of reasonable choices' ready to undergo the objective environmental analysis that NEPA dictates." This is another reason that NCPC should defer any decision on the NPS's proposal at this time.

POTENTIAL THREAT TO THE MONUMENT'S STABILITY

Finally, in considering the NPS's design, one of the most important questions has not been given the attention it requires: the potential threat posed by the tunnel to the Monument's physical integrity and stability. For many months the Coalition has raised this question; this was one of the four questions we sent Commissioners yesterday. NPS's engineers believe the project is feasible and NPS representatives have stated that the Peer Review supports that conclusion, but that is not clear to us. The Peer Review actually recommends that further studies be done. The Coalition agrees. Historically, Congress and structural engineers have been cautious about any actions that would cut into the soils around the Monument. This alone is a reason for NCPC to insist on an EIS for this project.

However, NPS did not provide those studies for the Peer Review team to evaluate. Why are they important? Consider the 1933 report to Congress. In that report, engineering studies by the Director of Public Buildings and Public Parks and others differed on the safety of carrying out all or portions of the McMillan Plan concept for the Washington Monument, some arguing it is safe, others more cautious. But the 1933 reports concluded that "The results of the core borings made it manifest that this plan would seriously endanger the stability of the Monument…Only two solutions seemed to offer any promise of success: a. To underpin the Monument to bedrock…[or] b. To dismantle the entire Monument, construct a new foundation to bedrock and rebuild the Monument thereon" (Report, p.12).

The McMillan concept was, of course, different from the current tunnel proposal. In some ways the current plan is even more drastic, because it requires actually cutting a large hole through the Monument's concrete foundation. The risk is a matter of judgement and in 1933 Congress said no.

In 1962 engineer Edward Barber made a study of "safe limitations on grading or new construction." His cautious assessment was challenged by the 1973 report supplied to the Peer Review team: "While we are generally in agreement with compressibility properties of the underlying clay chosen by Barber for his studies, we feel that selected limitation on tilt of the Monument is much too conservative to be realistic." It is clear from this statement that while engineers can agree on the technical data, when it comes to evaluating risk that is a matter of judgement. The Coalition believes the risk has not yet been properly evaluated and the project could threaten the Monument's stability.

Rather than take undo risk with the tunnel, NPS should consider the possibility of closing the Monument to visitors, if only temporarily when the threat is greatest.

CONCLUSION

The Commission should, in the Coalition's opinion, defer any decision about the project at this time and instead insist on an EIS. The NPS should be directed to follow the Programmatic Agreement and do a proper 106 consultation, including consideration of other credible alternatives that would have less drastic negative impacts on the Monument, the grounds, and the whole Mall. Mr. Parsons and the NPS security expert have both stated that the Monument is secure right now; the only "emergency" is an aesthetic one. Replacing the unsightly Jersey barriers and temporary screening building can wait, however, until we have the best security and design solution for this great prominent symbol at the heart of the National Mall.

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