Coalition comments on NPS “temporary” building in East Potomac Park

Superintendent John Piltzecker
National Mall & Memorial Parks
900 Ohio Drive, S.W.
Washington, DC 20024 Via Email: [email protected]

Dear Superintendent Piltzecker,

Attached to this letter are detailed written remarks and suggestions by the National Coalition to Save Our Mall responding to the NPS call for public comment on the proposed temporary office facility in East Potomac Park. We request a written response to these substantive comments in advance of the scheduled September 2nd meeting of the National Capital Planning Commission.

Let’s be clear, this administrative annex once constructed next to the existing “temporary” Headquarters Building will be here a long, long time. The NPS record over the past 50 years is plain: temporary buildings become permanent. Neither the review agencies nor Congress see fit to stop this destructive pattern or require NPS to create a coherent, updated master plan for its administrative needs. This project does not conform to the NPS 1982 Development Concept Plan for East Potomac Park. The newly completed National Mall Plan inexplicably fails to identify or provide any guidelines for office space needs. If this project is built as planned, the loss will be to the District of Columbia, where plans for the Southwest Waterfront redevelopment are moving quickly forward, and to federal interests as well. The National Capital Framework Plan recently completed by the NCPC and Commission of Fine Arts anticipates in this area not more NPS administrative offices but instead welcoming new public amenities and attractions.

NPS wants to cut out the public by classifying the undertaking as a “Categorical Exclusion” from environmental review; posting project documents on an agency website instead of holding public meetings; and restricting the comment period to August when District residents and civic organizations are out of town. NPS must have known about the need for office space for many months. So why was this project kept a secret from the public and from those organizations and individuals who have been actively participating in recent NPS planning efforts only to be rammed through the review process at the last-minute during the height of summer vacation? What serious alternatives were studied?

We strongly urge NPS not to seek a Categorical Exclusion and instead begin the necessary public consultation. We are asking NCPC also to reject an exclusion and, if this project remains on the NCPC September 2nd draft agenda, to change it from a “Delegated Item,” which means there would be no public presentation and no public comment, to an “Action Item.”

The Coalition feels that this project, perhaps even more than other controversial projects we have commented on during the past 10 years of our existence, could set a destructive standard that seriously undermines the integrity and future of the National Mall, other federal long-range planning efforts for East Potomac Park and the Mall, as well as the planning interests of the District of Columbia for this waterfront area of the City. The NPS should reconsider its approach and the federal and DC review agencies should step up to address the serious issues raised by this proposal.

For the National Coalition to Save Our Mall,
Judy Scott Feldman, PhD
W. Kent Cooper, FAIA

cc: Peter May, Marcel Acosta (NCPC), Thomas Luebke (Commission of Fine Arts), David Maloney (DC Historic Preservation Office), Louise Brodnitz (Advisory Council), Edward Boling (CEQ)


Enclosure

Comments submitted by the National Coalition to Save Our Mall to the National Park Service on the Proposed New Temporary Modular Office Unit in East Potomac Park
August 16, 2010

The National Coalition to Save Our Mall, a citizens’ nonprofit organization seeking a comprehensive, forward-looking vision for the National Mall in its 3rd century, welcomes the opportunity to respond to the National Park Service call for public comment for the proposed new temporary modular office unit.

The NPS states, in its 30-days notice for this project, that this proposed structure responds to the need for additional office space, meeting rooms, and associated support facilities. It will supplement the existing temporary Superintendent’s Headquarters Building for the National Mall & Memorial Parks unit of the National Park Service on Ohio Drive in East Potomac Park. NPS says that the agency will satisfy the requirements of NEPA and Section 106 through use of its PEPC website, and further says the project could qualify for a Categorical Exclusion for NEPA under NPS Director’s Orders 12, Section 3-4, Part C.18. NPS has asked National Capital Planning Commission to approve the project at its September 2, 2010 public meeting.

The Coalition recognizes NPS’s need for additional administrative office space, which we surmise is related to a number of new Mall-related reconstruction projects including Tidal Basin seawall repair, turf grass improvements, and restoration of the Lincoln Memorial Reflecting Pool. We have no problem with NPS meeting short-term construction needs with a small trailer. However, the proposed structure is not a construction trailer but a substantial, 4,096-square-foot administrative annex to the existing “temporary” Superintendent’s Headquarters Building. We should be clear: given the history of NPS temporary structures, this NPS administration building will be here a long, long time.

We strongly disagree with the NPS decision to cut out the public and the proper environmental review by seeking a Categorical Exclusion and restricting the comment period to August when District residents and civic organizations are on vacation. As stated in our cover letter to Superintendent Piltzecker, the Coalition urges NPS not to seek a Categorical Exclusion for NEPA environmental studies for this project and instead begin the public consultation process for the NEPA and National Historic Preservation Act Section 106 review.This review should include consideration of serious alternatives and can be the first step of a much-needed larger master planning effort for NPS administrative needs. In addition, we have asked NCPC to change this project from a “Delegated Item,” which means there would be no public presentation and no public testimony at the September 2nd meeting, to an “Action Item” so that District residents and the general public can see what is being proposed and comment before any final approval is given.

We have six main concerns and questions:

  1. The public must not be shut out of the consultation process. NPS appears to be trying to circumvent the required public consultation process by characterizing the structure “temporary” and a “trailer.” If this were a typical construction trailer to be used for short-term projects, we do not believe it would require federal review agency review, which this project obviously does. This proposed building will have major impacts on residents of the District of Columbia and the general public. Its location, size, and unattractive design will be a blight on this sensitive and highly visible area and the National Mall, our national icons, and the District’s Southwest Waterfront neighborhood. It could cripple for decades federal and District long-range plans to transform this waterfront area into a welcoming public space with new public amenities and attractions. A full NEPA and Section 106 public process should be begun immediately that includes strong public involvement.
  2. The proposed office structure should be treated as a permanent structure.Also, since the existing “temporary” Headquarters building was never subject to NEPA review in the past, that structure also should be included as part of the NEPA and Section 106 public consultation process.

The history of temporary structures becoming permanent is clear (requiring Presidential orders to remove them). Beginning in the 1960s, and especially in the 1970s in anticipation of the bicentennial, the National Park Service constructed a number of temporary structures on the Mall and in Potomac Park that have become permanent. These include Park Police stables, Tourmobile headquarters, NPS maintenance yard, bathhouse, tennis bubble, and the NPS Superintendent Headquarters Building. As the National Register states, “these buildings [were] meant to be temporary in nature” but “they are still used for their original purpose.” (National Register Nomination for East and West Potomac Parks, Section 8, Page 86). Now NPS proposes adding a substantial new temporary structure on the same parcel as the existing “temporary” Headquarters Building. Our fear is that both structures, as well as their associated parking lots, will follow the pattern and slip into permanence. Recent history supports our fear. For example, earlier this year NPS decided to construct a water pumping station at the stables south of the Lincoln Reflecting Pool, thus ensuring that the jumble of aging “temporary” stable buildings there will now be permanent features of the National Mall landscape.

  1. What other serious alternatives were equally studied?The proposed 128 x 32-foot annex will have major impacts both short term and long term on this sensitive and highly visible portion of East Potomac Park and surrounding areas of the National Mall. For example, the large size and unattractive, shed-like architectural profile detracts from and encroaches on the historic character of the nearby U.S. Engineers’ storehouse and views toward and from Ohio Drive. Views to and from the Southwest Waterfront neighborhood, which is in the midst of major urban revitalization planning, will be adversely impacted in more dramatic ways than are shown in the NPS illustrations, especially in winter when the trees will not camouflage this site. East Potomac Park is landfill in the floodplain and prone to frequent, serious flooding. How did NPS evaluate the effects of locating this structure in the floodplain? And what about parking? The new office and meeting space will require many new parking spaces but the plan does not show where on this constricted space additional parking will be located. What else is missing from the NPS plans and views that potentially will add to and further intensify adverse impacts?

If NPS has emergency short-term needs for construction purposes, NPS should consider the alternative of locating a small construction trailer in a less conspicuous location to be removed within a couple of years. If NPS needs more than a construction trailer, there are several convenient federal buildings with available space. Using existing federal office space is not only the economical and sustainable alternative. It eliminates the problem of adding another eyesore on this sensitive and highly visible area of East Potomac Park so near to the National Mall and our nation’s iconic buildings and monuments.

A much-needed, updated Development Plan for National Mall & Memorial Parks Headquarters administrative needs could consider a number of alternatives, including not only other locations and designs for the proposed annex, and also explore relocating the existing Headquarters structure, perhaps by consolidating administrative offices in a permanent location elsewhere. Since this park unit includes federal parkland throughout central Washington as far north as Dupont and Logan Circle, one option would be to relocate NAMA offices to a more central location in an existing federal building.

  1. How does NPS justify building additional intrusions near the historic Army Corps of Engineers Building, which is a contributing feature of the National Register character of East Potomac Park?The proposed office structure not only will create new adverse impacts on the Building but will aggravate existing adverse impacts. As noted above, the existing Headquarters Building and parking lot at this location have become permanent features that intrude on the historic character of the Engineers Building and its park setting. The proposed new structure, plus any additional new parking, will compound these adverse impacts by further blocking off the structure from the surrounding parkland and Ohio Drive. The NPS illustrations fail to show existing shabby conditions at this location even before this new structure is added. Views should include the existing modular “temporary” Headquarters Buildings and parking lot, and illustrate the effect of adding yet another, different type of modular building so that potential effects can be accurately evaluated. This is another reason to research alternative locations.
  2. How does NPS justify this project that not only ignores NPS’s own 1982 Development Plan for East Potomac Park and is not supported with any updated master plan, but will cripple federal and District long-range goals for East Potomac Park and the waterfront?The NPS East Potomac Park 1982 Development Concept Plan (posted on the NPS PEPC website) did not anticipate any changes or additions to Park Headquarters, which at that time were housed in the historic Engineer’s Building on the same parcel. Both the proposed new structure as well as the existing temporary Headquarters Building go against that plan. There is no updated Development Plan, and inexplicably the recently completed National Mall Plan for National Mall & Memorial Parks lands fails to address NPS administrative needs.

In addition, the NCPC and District government have developed long-range plans to enhance the Southwest Waterfront and Washington Channel area with public open spaces and amenities. Further, in recent years the public as well as planners have warmed to the idea of expanding the Mall to East Potomac Park. This possibility is anticipated in the Monumental Core Framework Plan prepared by the NCPC and Commission of Fine Arts. However, the proposed office structure would reinforce NPS use of this area for administrative purposes, which is not anticipated in the Framework Plan, and undermine the other federal and DC plans. These other plans need to be given serious and equal weight in the NEPA and Section 106 process.

  1. The most destructive consequence of ad hoc development such as the proposed facility is the long- term adverse cumulative effects of piecemeal development on the character of East Potomac Park, the environs of the Jefferson Memorial, the Tidal Basin and other parts of the National Mall, and the Southwest Waterfront neighborhood.The public, media, and review agencies regularly criticize and lament the chaotic, run-down condition of the Mall and its decrepit “temporary” facilities. It is no secret that the cumulative impact of this chaotic, piecemeal development over the past five decades has been to seriously degrade the park quality of this public land. The last thing we should be doing now, at a time Congress is funding NPS Mall initiatives and the public has shown new interest in future planning for the Mall, is to allow this lamentable and irresponsible pattern to continue.

The elephant in the room is the astonishing and deplorable lack of any updated, coherent, long-range master plan to guide NPS decision-making for office space and other administrative needs. This is despite the 50-year history of ad hoc, piecemeal additions of temporary structures, and the recently completed four-year planning effort for the National Mall Plan that inexplicably fails to identify NPS office space needs, (even on a temporary basis). Why did the National Mall & Memorial Parks office leave out one of its most urgent responsibilities? What else is missing from the Mall Plan? What will be the next emergency development to be shoehorned onto this nationally significant public parkland without any guiding master plan? Instead of acknowledging and resolving the problems, NPS appears to want to avoid them altogether by calling the proposed new structure “temporary” without defining what temporary means and what assurance there is it will be removed anytime soon, and seeking a Categorical Exclusion from the public consultation and environmental review processes. This is unacceptable.

Further, the Coalition has legitimate fears, based on long experience with controversial NPS-sponsored projects, that the NCPC, District Historic Preservation Office, Commission of Fine Arts, and other review agencies will work with NPS to resolve these substantive questions behind closed doors.The typical practice is to “mitigate” adverse effects of a NPS project by signing an inter-agency Programmatic Agreement in which promises are made that NPS will undertake a future planning effort. This practice of going along to get along undermines the legitimacy of the NEPA and Section 106 public consultation process and represents, in the Coalition’s view, an unacceptable shirking of responsibility by the Park Service and federal and District review agencies to the affected lands, District residents, and the American public. (We are commenting elsewhere on the draft PA for the National Mall Plan, which codifies a behind-closed-doors  agreement among federal and District agencies to ignore acknowledged problems with that Plan so long as NPS promises to do better next time.)

The Coalition feels strongly that this project, perhaps even more than other controversial projects we have commented on during the past 10 years of our existence, could set a destructive standard that seriously undermines the integrity and future of the National Mall, other federal long-range planning efforts for East Potomac Park and the Mall, as well as the planning interests of the District of Columbia for this waterfront area of the City. The NPS should reconsider its approach and the federal and DC review agencies should step up to address the serious issues raised by this proposal.

We request a written response from NPS to these substantive comments in advance of the scheduled September 2nd meeting of the NCPC.

For the National Coalition to Save Our Mall,

Judy Scott Feldman, PhD
Chair and President [email protected]

  1. Kent Cooper, FAIA
    Vice Chair [email protected]

c/o National Coalition to Save Our Mall PO Box 4709
Rockville, MD 20849
301-340-3938

 

 

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