ACHP Finds Proposed WWII Memorial Incompatible With Historical Site

After holding an unusual public hearing (August 28, 2000) on the proposal to build a World War II memorial in the middle of the National Mall, the presidentially-appointed U.S. Advisory Council on Historic Preservation on September 5th made its recommendation to Secretary of the Interior, Bruce Babbitt.

DC Congresswoman Eleanor Holmes Norton held a press conference on September 6th on the House Triangle to support the recommendations of the ACHP.

Honorable Bruce Babbitt
Department of the Interior
1849 C Street, N.W.
Washington. D.C. 20240

Dear Secretary Babbitt:

On July 25, 2000, we notified you that the Advisory Council on Historic Preservation Council l would provide formal comment under Section 106 at the National Historic Preservation Act on the proposed development of the National World War II Memorial. To accommodate scheduling, needs of the National Park Service, I convened a panel of Council members, consisting of myself, Vice Chairman Stephen B. Hand, expert member Bruce D. Judd, FAIA, and Paul W. Fiddick, representing the Secretary of Agriculture. On August 28, 2000, the panel conducted a public meeting to hear the proponents’ presentation of the project and to receive public testimony. The panel has now prepared comments on behalf of the full Council, which I am pleased to provide to you.

First, the Council notes its strong support for a long overdue memorial to honor those who served in the Armed Forces during World War II and to commemorate our country’s participation in the war. There is no question that this defining event of the twentieth century, and the American people’s pivotal role in it, warrant commemoration by memorial commensurate with their effort and sacrifice. Nevertheless, the Council believes that the World War II Memorial, as now proposed, has serious and unresolved adverse effects on the preeminent historic character of the National Mall. We believe this is due in part to the National Park Service’s (NPS) approach to the requirements of Section 106 and the limited nature of public involvement in the site and design selection process.

At the heart of our procedural concern is how the NPS conducts its Section 106 responsibilities when following the process established under the Commemorative Works Act to guide the siting and design of memorials. As this case demonstrates, among the most critical issues faced by NPS and its partners under the Commemorative Works Act is that of site selection. For many years, the Council has encouraged the NPS to involve the Council in the early stages of memorial development when there can be meaningful consideration of alternatives. Regrettable, such early consultation on the World War II Memorial did not occur. The NPS did not consult with the Council on either site selection or the design competition. When the NPS did bring the Council into the process in July 1997, the most critical aspects of the memorial proposal were firmly set. Consequently, only limited opportunity has existed under Section 106 to consider alternative sites or designs

This concern about coordination and early Council involvement is relevant not only to the present case but to all memorial proposals subject to both the Commemorative Works Act and Section 106. The NPS is currently revising the procedures under the Commemorative Works Act, and we request that you ensure that the resulting process integrates Section 106 effectively into the planning and development of fixture memorials. The Council is prepared to work with the NPS to achieve this objective.

When major changes to an exceptionally significant American landmark like the National Mall are contemplated, it is essential that citizens be given an opportunity both to understand these changes and to express their views on them. As the emerging public discourse on the proposed World War II Memorial indicates, proponents and opponents alike share a reverence for our Nation’s democratic ideals as represented on the Mall as well as a universal desire to commemorate the American experience in World War II. Unfortunately, the agencies that oversee planning and design issues within the District of Columbia rarely extend public involvement to a national scale. As challenging as this may be, however, expanding the public dialogue is the only way to ensure that decisions of such import are not looked back upon with regret. A model for such a process is the public outreach initiative concluded recently by the NPS as part of its responsibilities under both Section 106 and the National Environmental Policy Act for the White House Comprehensive Design Plan. It is worthy of consideration when similar proposals about the future of national icons are contemplated.

For public involvement in the Section 106 process to be successful, and for effects to historic properties to be properly considered, it is also necessary that appropriate information be available to all. In 1994, the Council requested the NPS to develop a cultural landscape study of the Lincoln Memorial grounds to help better understand the effects of the future development plans on this highly sensitive area The NPS agreed to prepare it within two years. Although completed in August 1999, the NPS did not release the resulting Cultural Landscape Report: West Potomac Park, Lincoln Memorial Grounds until July 2000. Both the report and the recent revisions to the National Register nomination for the East and West Potomac Park Historic District are excellent studies that provide needed insight into the qualifying characteristics of those important historic properties and possible effects of the World War II Memorial proposal. Regrettable, the information came too late to affect significantly the current proposal.

The National Mall is a site unique in American history. It is an architectural and landscape expression of great beauty, rich with historical association. But more than that, it has come to symbolize our National’s democratic ideals, Its open vistas and traditional uses have enabled it to serve as truly common ground for all Americans. These values invest use of the proposed Rainbow Pool site with some unusually difficult design challenges. Certain adverse effects of this proposal became inevitable upon its selection: the demolition and reconstruction of the Rainbow Pool, the dedicated use of existing open space in the premier historic landscapes, and permanent alteration of significant vistas and views of the McMillan Plane in particular the axial vista from the Washington Monument to the Lincoln Memorial. Nonetheless, the Council, from its first involvement, has accepted that it is possible to design a World War II Memorial on this site that would harmonize with its historic surroundings, thereby substantially mitigating these adverse effects.

We recognize that the design team has taken this challenge seriously and we commend them for their efforts. However, the Council believes that the current design of the proposed Memorial does not achieve this necessarily strict standard of compatibility with its historic setting. Several existing features, and other features yet to take form, are particularly problematic, First, the Memorial’s overall scale and complexity create a tension with the transcendent symbolic significance and fundamental simplicity of the National Mall. In particular, the visual screen of 56 ornamented pillars, while crossing the plaza violate the open feeling of the Mall and intrude upon the uncluttered historic vistas. Second, dusk and night views on the Mail would be altered by the current lighting plan which serves to further magnify as a newly introduced element on the Mall. And third, the sculptural element under consideration for the reconstructed Rainbow Pool has the potential to significantly alter the premier axial vista along the Mall.

In the Council’s view, it is of utmost importance that the National World War II Memorial complement and not compete with the Mall’s transcendent historic and cultural values and that the Mall remain genuinely the common ground that it has been historically. You have stated your intent to ensure that no unacceptable impacts to the historic properties occur as a result of this project. In that spirit, we urge reconsideration of the current Memorial design to preserve the distinctive character of this national treasure. In accordance with Section 106 of the National Historic Preservation Act, the Council is conveying these comments and recommendation to you for your consideration. We look forward to your response and stand ready to assist you in achieving our shared goal of creating a worthy legacy for future generations.

Cathryn B. Slater


The Commission of Fine Arts
National Building Museum
441 F Street N.W. – Suite 312
Washington, D.C. 20001-2728
202-504-2195 (fax)
J. Carter Brown, Chairman

The National Capital Planning Commission
801 Pennsylvania Avenue, N.W. – Suite 301
Washington, D.C. 20004-2682
202-482-7272 (fax)
Harvey B. Gantt, Chairman

Congresswoman Eleanor Holmes Norton
House of Representatives
1424 Longworth House Office Building
Washington, D.C. 20515-5101
202-225-3002 (fax)

The National Park Service
1100 Ohio Drive, S.W.
Washington, D.C. 20242
202-219-0910 (fax)
Robert B. Stanton, Director

The Department of the Interior
1849 C Street, N.W.
Washington, D.C. 20240
202-208-5048 (fax)
Bruce Babbitt, Secretary of the Interior

The American Battle Monuments Commission
Courthouse Plaza II – Suite 500
2300 Clarendon Boulevard
Arlington, Virginia 22201-3367
703-696-6666 (fax)
General Frederick F. Woerner, Jr., Chairman




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