It was difficult pulling together our comments on the Park Service’s Environmental Assessments (EA’s) for Security Improvements at the Lincoln and Jefferson Memorials during Thanksgiving, but we did it. On December 4th, the public comment deadline, we submitted extensive comments on both of these EA’s. They are now posted on our website — “What’s New“. Please take a few minutes to read them.
As the headline on our website states, the Coalition believes that the EA’s are grossly inadequate and need to be reworked and their conclusions substantially revised. As we state in our comments, these are the latest in what appears to be a pattern of EA’s prepared by the Park Service (including the Washington Monument EA and the World War II Memorial EA) which fail to take seriously the laws and regulations that apply: the National Environmental Policy Act of 1969 (NEPA) and, equally importantly, the National Park Service Director’s own Order #12, which is entitled “Conservation Planning, Environmental Impact Analysis, and Decision-making.”
Given the pattern of inadequate EA’s, we decided in our comments to include an extensive comparison/contrast of the some of EA elements and conclusions with the Director’s Order #12.
The purpose of the Park Service Director’s order, as stated in a NPS memo from January 8, 2001, was to lay the groundwork for “a necessary evolution in the way we [the Park Service] approach environmental analysis, public involvement, and making resource-based decisions.”
As the memo states, “Recent court challenges have stopped or redirected some of the Service’s actions and decisions…. The courts have cited a lack of, or failure to incorporate, critical information in decisions. In some cases, there has been a basic disregard of laws, regulations, and policies designed to foster resource preservation and conservation.” (NPS Memorandum, Jan. 8, 2001, p. 1)
Our conclusions are essentially that the current EA’s show the same inadequacies of the past. These points are detailed in our EA comments.
On Wednesday, December 4th, two of us — Don Hawkins of the Committee of 100 and your Chairman Judy Feldman — had a meeting with Terry Carlstrom, Director of the National Capital Region, National Park Service. Our purpose was to discuss with him the lack of progress in the Section 106 Public Consultation process for the Washington Monument security project. Mr. Carlstrom had in attendance, as well, the Park Service administrators in charge of the Washington Monument project — John Parsons, Sally Blumenthal, and Superintendent Arnold Goldstein. It was a useful meeting, if only to confirm that the NPS firmly believes that it has fully complied with rules and regulations.
Our comments on the EA’s for the Jefferson and Lincoln projects are an attempt to demonstrate that the facts appear to contradict that view.
Expert opinion and assistance from our friends is welcome.
Judy Scott Feldman