Coalition Comments on Proposed Rehabilitation of Constitution Gardens

Read our two-part comments during the roll-out of the Section 106 process in 2014.

May 22, 2014

  • The “Public Scoping Notice” treats the preparation of the next EA for Constitution Gardens on the National Mall, a National Register Concurrence Determination in 2008, as a rehabilitation projecteffort described in the 2010 general management and visioning National Mall Plan. In addition a design team has already been selected via a national design competition in 2012 providing design concepts. The “SCOPING” needs to include alternative landscaped design concepts, for this part of the National Mall, based on the original historic 1901 McMillan Plan and/or any subsequent official modifications, in addition to the usual no action alternative.
  • The EA needs to describe directly how each of the alternatives will “improve the ecology”. • Project boundaries need to be delineated. The notice states “This 52 acre park was officially dedicated in 1976” designed as a pastoral landscape. The NPS 2008 “Cultural Landscape Inventory” for Constitution Gardens, page 2, describes the gardens as “The 43.1-acre parkoccupies a prominent position in West Potomac Park, northeast of the Lincoln Memorial Grounds”. (Emphasis added)Is it part of US Reservation 332 or smaller?
  • All alternatives must be examined in relation to the rest of West Potomac Park and the portion of the Park and Lake known as “The Signers of the Declaration of Independence” Memorial. • The history of the site needs to go back before the 1966 SOM Plan and should be reflected in the alternatives studied. McMillan Plan concepts (established a design framework for the area and deserve to be considered and included).
  • All previous 1974 EA recommendations should be considered and evaluated. “ • Any alternative studied needs to assess existing and long range flood issues. The lake should be part of the comprehensive flood program in the works by Federal and District Agencies. Only restoring the lake is too limited. What is its potential in holding flood waters that inundate this low part of the National Capital?
  • How does the lake relate to other flood measures such as the 17th Street levee and the Potomac River flooding?
  • Public Scoping Notice mentions “Poor soil conditions have kept some of the trees from reaching full maturity to this day”. The EA needs to examine and study this situation and recommend solutions. (We understand that there was never enough money in the 1970’s to adequately remove all polluted soil and /or foundations with good soil). Will this “Rehabilitation” effort include adequate funds for this basic park setting need?
  • The Public Notice also mentions “many of the walkways have deteriorated and the visitor services facility once imagined…was never realized”. The EA needs to assess changed conditions to avoid this happening again, in all equally treated, alternatives.

Submitted by George H. F. Oberlander, AICP, on behalf of National Coalition to Save Our Mall (301-816-1153)

• • •

June 2, 2014

The following are additional comments from the National Coalition To Save Our Mall (NCSOM) supplementing our May 22, 2014 statement presented at the Scoping meeting for the Constitution Gardens Rehabilitation Environmental Assessment and Section 106 process:

  • The two suggested alternatives to be assessed for environmental and historic impacts, in addition to the “no change alternative” are only “slightly different remediation options” not actual alternative plans. Assessing these minor differences options gives the impression that the Trust’s competition single winning design is the preferred or desired alternative. There need to be several different feasible alternative plans recognizing this very historic area not just remediation proposals. Each plan is required to be equally assessed. The “Sustainable Alternative” and the “Social Alternative” are too close to adequately assess the different environmental historic impacts of the proposed man made environment and garden rehabilitation.
  • Moving the Lockkeeper’s House a few feet west and/or assessing the two levels proposed Pavilion in the same location close to the WW II Memorial, is inadequate.
  • Comments were made that the “ultimate solution will probably be a hybrid of the two plans”. This again indicates pre judgment in favor of the design selected. • The Scoping presentation did not indicate who will prepare the EA? Since the Trust has already identified the competition winning design, we suggest the EA be prepared for the NPS by an independent contractor. Consideration should be given to up-date and/or revise the 1974 EA.Examine why certain recommendations in that document did not get implemented?
  • The winning design concept characterizes Constitution Gardens as a “Destination”. We consider the “destination” to be the entire extent of the National Mall. Constitution Gardens should be evaluated as an integral part of the historic 1901 McMillan (Park) Plan. Designating the Gardens as a direct destination would imply and require more automobile and bus parking needs than can be accommodated on Constitution Avenue.
  • The real alternatives should include a number of the wining design’s rehabilitation ideas, such as the land berms and lake rehabilitation concepts, soil improvements, tree intensification and seating areas. Any two level pavilion structure(s), larger than a Kiosk, needs to be buried and /or incorporated into the landscape and greened to the maximum. Keep it lowkey as proposed by the original SOM approved design.
  • Solutions to the “poor soil” conditions should be given greater consideration and funding priority with tree planting to the maximum.
  • Examine feasibility of an open sky refreshment facility, as a “garden design solution” with limited enclosed service and toilet space. Designing the park to be a “MultiPurpose Facility” needs to be limited to actual determined people needs in a “pastoral landscape”. Is there a real need for an additional ice skating rink and its support?
  • Include a design study of the historic “cross axial” alternative proposed earlier in relation to the existing Reflecting Pool. Should the lake be reduced in size with possible cross walk pedestrian circulation improvements?
  • A night lighting assessment should be included to relate possible lighting impacts of proposed structure(s) to viewing distractions on each adjacentMemorial, including viewing the Washington Monument from Constitution Avenue. • NCSOM requests consulting party status for the Section 106 process.



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