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August 2, 2001

Jerusalem Bekele
Program Manager
Dept. of Health, Water Quality Division
51 N Street, N.E., Suite 5010
Washington, DC 20002

Dear Ms. Bekele:

The National Coalition to Save Our Mall, a coalition of citizens organizations, WWII veterans, architects, historians, and concerned citizens dedicated to preserving and protecting the National Mall in Washington, has serious questions about the environmental effects of the American Battle Monuments Commissionıs (ABMC) World War II Memorial, which will be placed some 15 feet , in saturated soil comprising the water table at the construction site, at the historic Rainbow Pool.

We urge that you and the appropriate agencies of the D.C. government consider the issues raised in this letter when reviewing applications for permits relating to construction of the memorial. The National Park Service did not prepare an Environmental Impact Statement in support of the proposed memorial project, notwithstanding the evident serious health and environmental hazards associated with the project. Further, there is substantial evidence that the taxpayers of the District of Columbia will bear the costs associated with the of long-term problems wrought by the ABMC project.

When the NPS issued a Finding of No Significant Impact (FONSI) in 1998, that determination was based on a 1998 Environmental Assessment of a design different from that currently scheduled for erection on the Mall. The current design is substantially different from the original, but NPS failed to conduct new studies or prepare a full EIS. A new report prepared in 2000 by ABMCıs consultant, TAMS, revealed high concentrations of arsenic and other contaminants (excerpt attached). As of last December, there was still no plan to deal with the contaminated soil and groundwater at the Rainbow Pool site. With just a few weeks remaining before commencement of groundbreaking at the site, EPA is just now reviewing construction plans.

In the absence of an EIS, the publicıs environmental concerns, many of which were raised in 1997, remain open questions. Those concerns include health issues, environmental, traffic, public safety, and the crush of additional visitors to the central axis of the Mall, which has been a concern of the National Park Service for years. NPS does not have the funds or personnel to properly maintain the Mall. Parts of the Mall are restricted to visitors to permit recovery of the grass. International water specialist Lisa Jorgenson has raised serious concerns about the effect of the Memorial on the Washington Monumentıs foundations (comments attached). The foregoing constitutes ample reason to ask the DC government to use due diligence in reviewing permit applications relating to the WWII Memorial. Would you please favor us with the analysis of the factors relied upon in granting or denying applications for permits, e.g., in which respects the memorial project conforms or fails to conform to specific laws and regulations governing the following issues:

Flooding and Pumping

• The WWII Memorial will be built in a 25 year flood plain and will be prone to frequent and sometimes catastrophic flooding;
• The subterranean memorial will require constant pumping of water under the foundations in order to maintain its structural integrity and prevent invasion of water;
• That water, and the excess waters accumulated during heavy rains and floods, will be pumped either directly into the Tidal Basin or into the city sewer system and the Blue Plains Sewage Treatment Plant;
• Global warming will only aggravate the flooding problem in coming years.

CLEAN WATER AND HEALTH

• The soils and groundwater at the Rainbow Pool site are contaminated with high concentrations (above EPA safety levels) of arsenic and other toxins. The Army Corps of Engineers failed to find arsenic in its 1997 report. (This part of the Mall west of the Washington Monument is composed of fill that was dredged in the 1880s and 90s from the Anacostia and Potomac river canals at the Navy Yard, which is an EPA Superfund site.)
• Contaminated soil will have to be removed (the Memorial plaza will be 15-foot deep and larger than a football field) and dumped in an as-yet unnamed landfill.
• Contaminated groundwater will be pumped from beneath and around the site during excavation and continually once the project is completed. If it is pumped into the Tidal Basin, any small town downstream should know that their water intake will be affected. If it goes into the storm sewers it will end at Blue Plains. (Anyone who bought a low flow toilet and shower to control volume should know that constant pumping of water at the WWII Memorial will negate any savings.)

TRANSPORTATION AND TRAFFIC ON 17TH STREET The crush of visitors and tour buses at the Mall continues to grow, especially at the recent memorials. NPS stated in the 1998 EA that there will be no problem with tour bus traffic, so long as one bus arrives at the Memorial site about every ten minutes. Who will control the extra busses lined up on 17th Street? What is to prevent buses from lining up along 17th Street, blocking the Mall's open vista and interfering with traffic on this major rush-hour artery? 17th Street will become a construction site for three years. Who will control traffic in and around the area?

SAFETY AND SECURITY

• A long ramp leads from 17th Street down into the Memorial plaza, with no provision for bollards or other obstacle that would stop a vehicle;
• Large gatherings of people inside the subterranean, enclosed plaza could be subject to a panicked "wave effect" and injury;
• Air vents over the pump stations could become a draw for homeless people;
• In summer the subterranean granite enclosure would trap heat and block breezes, creating an oven-like environment dangerous for children or the elderly;
• A special policeman will be required to patrol the subterranean granite plaza, since the site is distant from the patrol that covers the Lincoln memorial and Vietnam and Korean veterans memorials.

THREAT TO THE WASHINGTON MONUMENT AND 17TH STREET AREA

• The effect of continual pumping of the site could undermine the foundations of the Washington Monument. The proposed sub pumps at the WWII Memorial would be placed well below the level of the Monument's foundations. The constant pumping would create soil compaction and subsidence;
• The NPS's EA did not evaluate this impact and its possible long-term effect on the whole area around the Monument;
• The EA states that helicopter landings will be moved from the Rainbow Pool to the Washington Monument grounds, however no plan has been approved, nor have the effects of building a new helipad and roads off 17th Street been evaluated.

HISTORIC RAINBOW POOL AND OLMSTED TREES OF THE LINCOLN MEMORIAL

• The WWII Memorial calls for the destruction of the historic Rainbow Pool which is a completed element of the historic Lincoln Memorial grounds and of the McMillan Plan of 1901-1902, as documented in two NPS reports. ("The Reflecting Pool and Rainbow Pool...are integral components of the designed historic landscape of the Lincoln Memorial" East and West Potomac Parks Historic District Revised National Register of Historic Places Nomination, 1999, p. 15; see also Cultural Landscape Report West Potomac Park Lincoln Memorial Grounds, 1999)
• Earlier this year the Court granted us a Temporary Restraining Order because NPS plans to cut the roots of the historic Olmsted elms within 25 feet, in violation of the 35-foot standard set forth in the 1998 EA, which would lead to the deterioration and death of those trees. Nevertheless, the NPS plans to carry out the root cutting in December.

ECONOMIC IMPACT ON D.C. TAXPAYERS

• The cost of all unforeseen effects that directly impact city streets and facilities - flooding, traffic congestion, new demands on Blue Plains Treatment Plant, need for additional policing and security measures - will be borne by local residents.

NPS and the other sponsors of the Memorial have paid scant attention to these and other serious matters. We urge you to take the initiative on behalf of D.C. residents. It would be advisable to consult with structural engineers familiar with groundwater and flooding problems in Washington engineers retained to design the foundations for the Ronald Reagan International Trade Center, and the engineers who manage the pumping at the Commerce Building and Reagan Center. That consultation should relate to the subsurface conditions at the Washington Monument as well as the WWII memorial. We urge you to read the attached statements about potential hazards prepared by an international water specialist, Lisa Jorgenson. Her concerns made know to the advisory agencies during 1997 and 1998 have never been answered by the agencies and ABMC appears to be unconcerned.

Finally, it should be noted that Public Law 107-11 passed by Congress to expedite the Memorial does not exempt the Memorial from EPA, D.C. Government, or other review. The law states in Section 2 that "Elements of the memorial design and construction not approved as of the date of enactment of this Act [May 2001] shall be considered and approved in accordance with the requirements of the Commemorative Works Act (40 U.S.C. 1001 et seq.) and in Section 1, that "design modifications, if any, [shall be] approved in accordance with applicable laws and regulations." At final approval last November and December, the Memorialıs designers testified that plans for treating the contaminated soil and water had not yet been drawn up. Therefore, your review must be guided by all applicable laws.

Thank you for your prompt attention to this most urgent question. We look forward to seeing the answers to these serious concerns. If you have questions or wish to review the documents we have accumulated on these issues, please call me at 301-340-3938.

Yours truly,

Judy Scott Feldman, Ph.D.
Co-Chair

cc: William Ruby, Environment Specialist, Water Quality Division
Congresswoman Eleanor Holmes Norton
Mayor Anthony Williams
Congresswoman Connie Morella
Chris Westergard, Maryland Environment Dept.
Mark Haddon, Smithsonian Environmental Research Center
Vickie Apostolopoulos, National Trust for Historic Preservation

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