Coalition comments on NPS Turf Plan

Scoping for the EA for the National Park Service Reconstruction of the Turf and Soil on the National Mall

  1. The need for a comprehensive National Mall master plan to guide resource planning

Improvement of the turf and trees, which are crucial design components of the Mall’s overall unity, should be part of a comprehensive physical master plan for the National Mall as a unified whole.  That master plan would be an updated modern artistic expression of the historic Mall plans updated to support the needs of all Mall constituencies.  The new NPS National Mall Plan, which focuses only on NPS-administered portions of the Mall and broad concepts, is not that plan.

Lacking any comprehensive Mall master plan, NPS must ensure that this planning effort and environmental document go beyond NPS maintenance needs to take into account and support the larger National Mall context and public interest.  During the public scoping meeting on March 9, 2010 it was evident that NPS has already given directions to its consultants HOK about NPS preferences for improving the turf and trees on the Mall areas between 3rd and 14th Street. The scoping process must now go further and make a full objective and scientific comparison and analysis of a full range of alternatives that might differ from typical NPS management practices and preferences.  The National Mall is a unique place, and we believe this turf and soil plan not only should represent the best modern and sustainable science but also serve as a model to the country of forward-looking urban park planning.

  1. Clarify the title and scope of the project

The title on the scoping announcement is “Reconstruction of the Turf and Soil on the National Mall.”  At the public scoping meeting on March 9, 2010, NPS and its consultants HOK and Louis Berger Group presented concepts not only for reconstructing the turf and soil but also for restoration of the trees and under-tree areas.  Serious questions and concerns were raised about the NPS approach to the elm trees that could destroy the unity of this critical landscape design element.  At the end of the session, NPS’s Steve Lorenzetti said, “essentially this is a repair of the grass.”  Is this study about turf and soil, as the title says and NPS stated during the meeting? Or does it include the elms?  The title should be accurate.

  1. Goals that support public use of under-tree areas

We are told that NPS Director Jon Jarvis assured Congress during a March 16th hearing of the House Interior Appropriations Subcommittee that NPS would continue to permit the Smithsonian Folklife Festival to use the under-tree areas of the Mall for public events.  We assume that the Memorandum of Understanding between NPS and the Smithsonian that was in effect for many years will be reactivated.  And we assume that the National Mall Plan proposal to ban under-tree events, and any directions given to NPS consultants based on that proposal, will be reviewed and adjusted to conform to this agreement.  Thus instead of preparing plans to protect these areas against public use, NPS must now find new and innovative and sustainable ways to facilitate use of these areas while also protecting the tree roots.

  1. Roads covered over in the 1970s to create gravel pathways should be removed as part of a long-range sustainability plan for the National Mall

These hard paved surfaces below the walkways prevent water to permeate more than a few inches below the Mall surface and are the cause of water retention and the failure of walkway surfaces above.

  1. Grass, soil, and tree upgrades must support non-NPS Mall organizations including the Smithsonian museums, National Gallery of Art, USDA, and a variety of public uses

In addition to changing the approach to use of the under-tree areas to conform to Director Jarvis’s statement to Congress, this planning effort must also recognize that the turf, soil, and trees also serve other institutions and constituencies that share stewardship of the Mall including the National Gallery of Art, Architect of the Capitol, and the general public. NPS maintenance needs, and NPS policies that give priority to preserving natural resources over public use, must be equally examined against substantive alternatives that recognize the broader public interest for using the turf and treed areas in the context of the National Mall’s unified composition of public buildings, monuments, museums, and public open space and the Mall’s role as an ever-evolving stage for American democracy.   Such uses should be supported by general policy and not require a separate Memorandum of Understanding.

  1. Properly identify the historic and cultural resources to recognize the legacy of the L’Enfant and McMillan plans

Properly identifying the historic resource, and its context with the larger National Mall and the historic plans, is critical to evaluate any potential adverse impacts of any proposed changes to this area.  It is not acceptable to treat the turf, soil, and trees in this portion of the “Mall” as a separate unit of parkland within the NPS administrative unit National Mall & Memorial Parks, which includes separate parks and parkland throughout all central Washington that are not related to the National Mall.  We have stated the same in our comments on the National Mall Plan, which treats NPS portions of the Mall as generic parkland instead of as integral components of the larger, unified National Mall.

The title of this study mentions the “National Mall” but the description of the project’s scope does not actually mention the “National Mall” or the L’Enfant and McMillan plans, which are the blueprints for the Mall.  Yet, in the Commemorative Works Act, Congress has defined the Mall as “the great cross axis,” which includes this area under study.  The purpose of the Act is “to preserve the integrity of the L’Enfant and McMillan plans for the Nation’s Capital.”  The turf, trees, and landscape design, integral parts of the Mall’s artistic concept from the McMillan Plan, need to be approached from this understanding.

This means that all changes and upgrades proposed should be in keeping with the character of the historic concepts.  But this approach was not in evidence during the March 19th meeting.  For example, at that meeting NPS proposed treating the 4th row of elms as “street trees” and putting them into protected boxes to encourage stronger growth.  However, these elms are part of the larger McMillan concept of the 4 rows of trees together as the “architectural” frame for the greensward and vista.  Additionally, NPS has proposed hard paving the walkways into sidewalks but the historic character, inspired by European parks such as Versailles, was of a naturalistic setting, not an urban street.  Apparently, NPS has given its consultants directions that do not include preserving the integrity of the historic concepts.  The EA must remedy that problem by seriously evaluating alternatives that preserve the historic concepts.

To ensure preservation of the historic concepts and character of the Mall, the Mall needs an updated, scientifically-based plan for its landscape elements which have not been evaluated and updated for many years.  This is a critical missing link.  This plan would include items such as:

  • A landscape restoration plan addressing reconstruction of the formal tree groves to attain their historic plan potential;
    • Current technology for prevention of soil compaction under trees to assure maximum human use and sustainability;
    • Scientific analysis of proposed tree root zone retrofitting methods to assess the sustainable traffic capacity;
    • Logical reconsideration and analysis of elm tree use as a sustainable species of tree for the Mall.

We realize that NPS does not recognize any design elements of the historic plans that were not actually built, stating that subsequent planning takes precedence over unbuilt historic concepts.  We believe this interpretation misunderstands Congress’s intent in the Commemorative Works Act.

  1. Planning must be in keeping with Executive Order 13514 for sustainable planning and cost-effective choices.

The NPS National Mall Plan does not include a sustainability plan or set of priorities and policies.  One must be developed to ensure that the EA and all decisions are based on serious science.  During the March 9th meeting, neither NPS nor its consultants made mention of the EO or explained how sustainable thinking has influenced proposed upgrades and improvements.

For example, serious consideration of a variety of permeable surfaces should be a priority.  Hard paving preferred by NPS for ease of maintenance is short-sighted and contrary to the Obama Administration’s mandate to look to long-term, sustainable solutions in planning and practice. Permeable surfaces should not be rejected, as NPS has done in the Mall Plan and in the Lincoln Reflecting Pool project, on the basis of failed examples such as the National Gallery of Art walkways.  NPS’s Steve Lorenzetti stated during the March meeting that NPS has not found any permeable surfaces that work for wheelchairs.  NPS has not looked hard enough.  Plentiful examples exist in parks across the United States of permeable surface walkways that are friendly to wheelchairs and strollers while also providing a softer surface more in keeping with a park environment.

In addition, we have heard from several turf and horticulture experts who have offered advice to NPS, that NPS and its consultants have rejected outright alternative approaches to soil and turf restoration and management, including recommendations being developed by the Sustainable Landscape Initiative sponsored by the ASLA and U.S. Botanic Garden, which represents some of the most up-to-date thinking.  The EA decision-making process must not be predetermined.  Other alternatives must be seriously studied and evaluated on the basis of scientific analysis.

  1. In developing Alternatives, NPS must look beyond NPS maintenance needs and work with other Mall stakeholders to identify and then equally evaluate proposals based in the historic plans for the Mall, the larger interests of other Mall institutions and the national public, and the Obama Administration’s sustainability goals

During the March 9th public scoping meeting, it became evident based on the presentation by NPS and its consultants that NPS had already narrowed the questions and considerations to be studied for this project.  This approach does not satisfy the need for serious, scientific evaluation of alternatives.

The EA must develop a full range of substantive alternatives that recognize the larger Mall context and then evaluate these alternatives against NPS preference in a serious, scientific manner.  If those other alternatives are properly conceived and then rejected, the EA must clearly explain why.  Examples of other alternatives that meet this broader need include:

  • NPS has proposed installing a new irrigation system for the turf. Working with the Smithsonian and other Mall constituencies, NPS could develop economical solutions for irrigation including gray water collected in cisterns or from rooftop collection basins to water the Mall’s grass and trees;
  • NPS is proposing hard paving for all the Mall walkways with gutters to collect run-off but has not demonstrated how this solution is preferable or that it will work and not result in pooling, clogging, and creating even worse conditions than now exist on the Mall.  Permeable paving comes in a wide variety of materials and applications, including open joint block paving, set on an appropriate base course.  The use of permeable paving materials for pedestrian and bicycle circulation is justifiable historically, visually, functionally, and economically, when properly and appropriately constructed.
  • NPS speaks of ease of maintenance as a goal for proposed hard paving and treating the undersized row of elms as “street trees.”  However, permeable paving and preservation of the 4 rows of elms as a unified design whole are critically important to preserving the character of this part of the Mall as conceived by the McMillan Commission.

We look forward to the next public consultation meeting and other opportunities to participate constructively in planning for the turf, soil, and trees that are essential design components of the National Mall and elements of great beauty that give the Mall its special character as a grand public open space and symbolic vista in the heart of the capital.

For the National Coalition to Save Our Mall,

Judy Scott Feldman, Ph.D.

W. Kent Cooper FAIA
Vice Chair


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