CONTENTS

PURPOSE OF AND NEED FOR THE PLAN — 1 Introduction ...... 3 Purpose of the Plan ...... 3 Need for a Plan ...... 4 Plan Objectives ...... 4 The Planning Process and Public Engagement ...... 8 The Next Steps ...... 8 Foundation for Planning and Management...... 9 The ...... 9 Purpose ...... 9 Significance...... 10 Fundamental Resources ...... 10 Fundamental Values...... 11 Primary Interpretive Themes...... 14 Other Important Resources ...... 14 Legal Considerations ...... 15 NPS Laws, Regulations, and Policies ...... 15 First Amendment Jurisprudence ...... 16 Regulating Public Use ...... 16 Memorials and the Reserve...... 18 Commercial Activities and Transportation...... 19 Scope of this Document...... 20 Opportunities, Problems, and Challenges ...... 20 National Mall Issues and Background...... 21 Specific Area Issues and Background ...... 27 Environmental Impact Topics...... 31 Impact Topics Analyzed in Detail ...... 31 Impact Topics Dismissed from Further Consideration ...... 32 Interrelationships with Other Plans and Projects ...... 42 Architect of the Capitol ...... 42 National Capital Planning Commission...... 42 District of Columbia ...... 44 ...... 44 NPS Planning Efforts...... 44 Visitor Transportation Study ...... 44 Mall Soil and Turf Study...... 47 The and President’s Park...... 47 Center for Urban Ecology ...... 47 Interagency Planning Efforts...... 48 CapitalSpace...... 48 Planning Together for Central Washington...... 48

i CONTENTS

PLAN MAPS

National Mall Plan Area...... 5 Monumental Core Framework Plan Opportunities ...... 43 Urban Design Framework...... 45

FIGURES

Figure 1: The National Mall ...... 12 Figure 2: Mall Tree Conditions...... 21 Figure 3: A National Demonstration at the U.S. Capitol and Union Square ...... 22 Figure 4: A Special Event on the Mall ...... 23 Figure 5: Recreation on the National Mall...... 25 Figure 6: Union Square ...... 27 Figure 7: The Smithsonian Metro Station ...... 28 Figure 8: Temporary Concession Facility ...... 28 Figure 9: Constitution Gardens Lake...... 29 Figure 10: Walkway...... 30 Figure 11: Riverfront...... 30 Figure 12: North Plaza of the Thomas ...... 31

TABLES

Table 1: Recent First Amendment Case Law Summary ...... 17 Table 2: Species of Greatest Conservation Need, Washington, D.C...... 38

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ACRONYMS AND ABBREVIATIONS

ACHP Advisory Council on Historic Preservation ADAAG Americans with Disabilities Act Accessibility Guidelines AIA American Institute of Architects AOC Architect of the Capitol ASLA American Society of Landscape Architects CEQ Council on Environmental Quality CFA U.S. Commission of Fine Arts CUE Center for Urban Ecology (NPS) CFR Code of Federal Regulations DBID Downtown Business Improvement District DDOT D.C. Department of Transportation FHWA Federal Highway Administration GAO Governmental Accounting Office GSA General Services Administration LCS List of Classified Structures LEED Leadership in Energy and Environmental Design MWCOG Metropolitan Washington Council of Governments NAMA National Mall and Memorial Parks NCPC National Capital Planning Commission NCR National Capital Region (NPS) NHPA National Historic Preservation Act NEPA National Environmental Policy Act NPCA National Parks Conservation Association NPS PMIS project management information system (NPS) SCS Soil Conservation Service USACE U.S. Army Corps of Engineers USC United States Code USDI U.S. Department of the Interior US EPA U.S. Environmental Protection Agency USFS U.S. Forest Service USFWS U.S. Fish and Wildlife Service USGS U.S. Geological Survey USPP United States Park Police WABA Washington Area Bicyclist Association WMATA Washington Metropolitan Area Transit Authority WMATC Washington Metropolitan Area Transit Commission

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This page has been left blank intentionally. PURPOSE OF AND NEED FOR THE PLAN

DRAFT NATIONAL MALL PLAN / ENVIRONMENTAL IMPACT STATEMENT THE NATIONAL MALL

WASHINGTON MONUMENT

INTRODUCTION 3 FOUNDATION FOR PLANNING AND MANAGEMENT 9 SCOPE OF THIS DOCUMENT 20 INTERRELATIONSHIPS WITH OTHER PLANS AND PROJECTS 42

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INTRODUCTION

The National Mall stretches west from the U.S. issued for commercial filming and recreation Capitol to the , and north from field use, as well as for other national park the Thomas Jefferson Memorial to Constitution system units in Washington, D.C. Avenue (see the National Mall Plan Area map). This highly recognizable space, perhaps the most The wear and tear of concentrated activity affects significant historic landscape in the United the landscape and visitor experiences. Facilities States, needs a comprehensive plan to address a can be overwhelmed with use, vegetation cannot number of issues. In 2003 Congress stated that easily recover, and turf may be worn to the the National Mall is a “substantially completed ground and soils heavily compacted, which in work of civic art” and that no new or unap- turn adversely affects the vigor of trees and other proved memorials or visitor centers could be vegetation. Walks are not wide enough for cur- added within the area labeled as the Reserve (40 rent levels of use, and adjacent areas may be dam- USC 8901 et seq.). Congress also directed the aged when use spills off walks or when people National Park Service (NPS), as the responsible choose a more direct route. The combined effects federal agency, to begin planning for the future generate heartfelt complaints by visitors about of the National Mall. The mandate of the Na- the deteriorated appearance of the National Mall. tional Park Service is to protect resources and Planning must take into consideration the provide for visitor enjoyment. unique urban planning environment of Wash- The National Mall is managed as a unit of the ington, D.C. Multiple agencies have jurisdiction national park system by the National Park Ser- over lands and roads within and adjacent to the vice through the National Mall and Memorial plan area. These agencies include the National Parks (NAMA); many park areas in central Park Service, the Architect of the Capitol, the Washington, D.C., are managed by the National , the Smithsonian Institu- Mall and Memorial Parks. The National Mall, tion, and the Department of Agriculture. Other which is about 684 acres, received more than 22 governmental entities with some level of re- million visits in 2008, more than twice the num- sponsibility within or near the National Mall ber of annual visits reported for Yellowstone, include the General Services Administration Yosemite, and Grand Canyon national parks (GSA), the District of Columbia, and the Wash- combined (10.9 million visits in 2008). Accom- ington Metropolitan Area Transit Authority modating this level of use and balancing all types (WMATA). In addition, governmental organiza- of activities within this limited area present tions such as the U.S. Commission of Fine Arts, enormous challenges. the National Capital Planning Commission (NCPC), and the D.C. Historic Preservation Of- The National Mall must function efficiently and fice have consultation, planning, review, and in flexibly at many levels — as the highly symbolic some cases approval authority for issues related visual setting for our government; as part of the to planning, historic preservation, commemora- city’s circulation and transportation network; as tive works, and design. the location of the nation’s primary memorials and museums; and as the stage for First Amend- Civic engagement with the public, a vital compo- ment demonstrations, national celebrations, and nent of the planning process, has been and will regional and local special events and activities. continue to be an open and inclusive process. The demands on the National Mall are constant and wide-ranging. Every year the National Park PURPOSE OF THE PLAN Service receives over 6,000 applications for per- mits, resulting in around 3,000 permitted activi- The purpose of this planning effort is to prepare ties. In 2008 and 2009 between 1,100 and 1,200 a long-term plan that will restore the National permits were issued for events on the National Mall so that it may continue to symbolize the Mall, including First Amendment gatherings and ideals and greatness envisioned for the United national celebrations. Additional permits were States of America. The approved plan will serve

3 PURPOSE OF AND NEED FOR THE PLAN as an overarching organizational document for landscapes can be preserved, (2) very high subsequent project implementation. Future levels of use can be sustained, and (3) the implementation plans will generally include needs of visitors can be met. The National standard procedures for site-specific design, Mall plan must address commission reviews, public engagement, and ◦ how to improve resource conditions; es- historic preservation consultation. As a result, tablish a standard of quality that invites this will be a multiyear and multidisciplinary respect and generates stewardship; and planning effort. Certain actions may require raise the standard of care and mainte- congressional authorization or revision of nance federal or park regulations. ◦ how to prepare for intensive levels of use Critical to this planning effort is the establish- for First Amendment demonstrations, ment of a common public understanding of the national celebrations, and special events extent and identity of the National Mall. The ◦ how to provide desired experiences, such National Park Service uses the term National as opportunities for education, contem- Mall to encompass three specific areas: plation, rest, relaxation, recreation, • the Mall, which extends from the grounds entertainment, and social experiences of the U.S. Capitol to the Washington ◦ how to address user capacity, which for Monument and includes Union Square this plan is defined as the type and level • the Washington Monument and its grounds of visitor use that can be accommodated while sustaining desired resource and • West Potomac Park, which is the setting for visitor experience conditions on the numerous memorials, including the Lincoln National Mall Memorial, the World War II Memorial, the ◦ how to provide for the physical needs, Vietnam Veterans Memorial, the Korean enjoyment, and convenience of visitors War Veterans Memorial, the Franklin and park users, including information, Delano Roosevelt Memorial, the Tidal restrooms, food, retail, drinking water, Basin, and the Thomas Jefferson Memorial and access Often the terms National Mall and the Mall are • There may be opportunities for partnership used interchangeably, and map labeling and groups to help fund construction, land- references to the National Mall have further scape renovation, and maintenance created public confusion. projects. The need for the plan is further discussed in “Op- NEED FOR A PLAN portunities, Problems, and Challenges” (begin- ning on page 20). Comprehensive planning is needed to define the future for the National Mall and to detail spe- cific desired conditions and actions. The ap- PLAN OBJECTIVES proved plan will be similar to a general man- agement plan, which the National Park Service Plan objectives identify what achievements would make the plan successful. The objectives take into requires for all parks, but it will not address all areas managed by the National Mall and Me- account the park purpose and significance, NPS morial Parks, so it is more focused than a general policies, planning principles developed in cooper- ation with other federal and city agencies with management plan. A comprehensive plan for the National Mall is needed for the following planning responsibilities within the District of Co- reasons: lumbia, public comments, and park goals and needs. • Congress has directed the National Park Service to plan for the National Mall within • Cultural Resource Protection the Reserve so as to preserve its character. Primary east-west vistas and several north- • The National Mall must be refurbished so south vistas on the National Mall are im- that (1) its treasured memorials and historic proved and perpetuated.

4 Introduction: Plan Objectives

National Mall Plan Area

5

PURPOSE OF AND NEED FOR THE PLAN

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6 Introduction: Plan Objectives

Cultural resources, including memorials ◦ feel welcome and their settings, are preserved and ◦ fully understand the importance of this protected. preeminent civic area for First Amend- Historic plans for the National Mall are ment rights respected. Resources are managed com- ◦ learn about our core values as a nation by patibly with the intent of historic plans. making an educational, emotional, inspirational, or patriotic connection to • Natural Resource Protection the memorials that commemorate our history and the physical design that re- Natural resources, such as water, turf, flects our democratic form of government trees/vegetation, and soils, are improved to ◦ be part of a sustainable urban ecosystem. appreciate the beauty of the National Mall during the day, at night, and year- round • Demonstrations and Special Events Lighting on the National Mall evokes emo- The National Mall remains a venue for First tion and provides enjoyment, while respect- Amendment demonstrations and national ing historic fixtures and existing lighting at celebrations. memorials. The Washington Monument, Special events are managed to sustain the , and Thomas Jefferson health of park resources, to balance the Memorial (as well as the U.S. Capitol and desires of all users, and to ensure a safe the White House) continue to be the most environment. No one’s enjoyment of the prominent nighttime features. National Mall is unacceptably compro- Visitor information is convenient, accurate, mised by others, now or in the future. easy to understand, and consistent through- Venues and facilities for demonstrations out the site. Information and programs are and special events are provided that are universally accessible and reach the widest compatible with the historic significance of audience possible. the National Mall, that enhance the experi- Visitors understand and appreciate the so- ences of users, and that accommodate oper- cial experiences they are likely to encounter ations efficiently and effectively with mini- — millions of people come here to cele- mal impacts on nationally significant brate, commemorate, demonstrate, or resources. recreate.

• Access and Circulation Learning opportunities are provided to en- gage all ages and abilities of an increasingly To fulfill its symbolic and civic importance, multicultural and technologically sophisti- the National Mall is a role model of inclu- cated society. Educational information in- siveness and universal design for all citi- spires all visitors, including populations zens. that have not typically visited national Public access and circulation are conven- parks. ient, and visitors are easily able to find their Recreational opportunities are balanced way to all sites on the National Mall. with other uses of the National Mall, and The National Mall is better integrated with both active and passive forms of recreation and connected to the urban fabric of meet the needs of visitors, residents, and Washington, D.C. workers. The National Mall continues to function as • Visitor Information, Education, and an important part of the D.C. park and Enjoyment open space network. The National Mall provides the quintes- sential American experience where visitors can

7 PURPOSE OF AND NEED FOR THE PLAN

• Visitor Amenities implementation plans will require ongoing consultation and coordination with other Facilities are of high quality and reflect a entities involved in planning and construction compatible and enduring character, thus efforts. creating a sense of place that reinforces the civic, historic, and symbolic role of the The planning process and public involvement National Mall to our nation. are described in detail in the “Consultation and Various visitor and commercial amenities Coordination” chapter, beginning on page 559. are provided that are conveniently located and that are sized and configured to flexibly THE NEXT STEPS meet visitor-use patterns during the peak season. The Draft National Mall Plan / Environmental Impact Statement was on public review from De- • Health, Public Safety, and Security cember 18, 2009, to March 18, 2010, after which the planning team evaluated comments from Safe, healthy, secure visits are provided, and other federal agencies, organizations, businesses, visitors have adequate notification of and individuals regarding the draft plan. Appro- emergency situations. priate changes have been incorporated into this The National Mall, including all walks and Final Environmental Impact Statement. Com- facilities, is a showcase for inclusiveness ments from cooperating agencies, consulting and universal design. parties, regional governments, organizations, and individuals are reprinted in volume 2, along • Park Operations with NPS responses to those comments. Follow- ing distribution of the final plan and a 30-day The National Mall is a role model in sus- no-action period, a record of decision approving tainable urban park development, resource a final plan will be signed by the NPS National protection, and management, focusing on Capital regional director. The record of decision six areas: requirements and policy, resource will document the NPS selection of an alterna- health, water use, circulation, facilities, and tive for implementation. Once it is signed, the park operations. plan can then be implemented.

Facilities are consistently maintained to the The approved National Mall plan will provide a desired standards of excellence. comprehensive vision and framework to protect All maintenance and park operations em- the historic character of the National Mall, to phasize efficient, effective, and sustainable restore its health and beauty, to help it function practices. better as America’s civic space, and to meet the needs of local, national, and international visi- Cooperating agencies coordinate planning, tors today and tomorrow for enjoyment, educa- information, services, facilities, and pro- tion, and recreation. However, completing the grams for visitors, residents, and the local plan does not ensure that all actions will take workforce. place or that funding will be forthcoming. As the plan is implemented, many of the proposed THE PLANNING PROCESS AND PUBLIC projects would provide additional opportunities ENGAGEMENT for public involvement. They would undergo re- views by and consultation with the U.S. Com- In recognition of the importance of the National mission of Fine Arts, the National Capital Plan- Mall to many Americans, this planning effort has ning Commission, the Advisory Council on and will continue to emphasize open and inclu- Historic Preservation, and the D.C. Historic sive communications to engage the public and to Preservation Office. Some projects might require understand their desires and concerns. Com- congressional action or changes in federal or pleting the National Mall plan and subsequent park regulations.

8

FOUNDATION FOR PLANNING AND MANAGEMENT

Park planning and management are based on the monument), an important element or rem- legal purposes of a park, its significance, its fun- nant of a historic plan (such as the L’Enfant damental resources and values, and its primary plan), or an element without which the park interpretive themes. These elements establish a would be greatly diminished. foundation for planning and management so that • Primary Interpretive Themes — These are everyone has a shared understanding of what is the major messages that visitors to a park most important about the park. It is also impor- should receive during their visit, and they tant to identify the constraints of special man- connect park resources to relevant ideas, dates on planning and management. The purpose meanings, concepts, contexts, beliefs, and of the foundation statement is to help ensure that values. They support the desired interpre- planning and management stay focused on what tive outcome of increasing visitor under- is most important. All alternatives must be consis- standing and appreciation of the signifi- tent with and contribute to fulfilling the park’s cance of the park’s resources. Primary purpose, significance, and mandates. interpretive themes are based on the park’s • Purpose — The park purpose is the specific purpose and significance. reason that a park was established by • Other Important Resources and Values — Congress or the president. Purpose state- Additional resources and values may have ments are grounded in a thorough analysis particular importance and warrant special of the park’s establishing legislation or consideration during general management executive order, as well as the legislative planning, even though they do not contri- history and studies prior to authorization. bute directly to the purpose and signifi- Purpose statements may go beyond a cance of the park. restatement of the law to document shared assumptions about what the law means in The five foundational elements for the National terms specific to the park. Mall plan are presented below. They were devel- oped as part of an NPS Foundation Workshop • Park Significance — Park significance for the larger National Mall and Memorial Parks statements express why the park’s re- held in July 2006. The following purpose and sources and values are important enough to significance statements specific to the National warrant national park designation. The Mall were derived from court decisions; con- statements capture the essence of the park’s gressional statements; the laws, regulations, and importance to our nation’s heritage and policies that guide the National Park Service; help ensure that managers make decisions and other laws and plans for Washington, D.C. that preserve the resources and values for (The foundation elements for the National Mall which the park was established or that are and Memorial Parks that relate to the National necessary to accomplish the park’s mission. Mall plan are included in appendix A.) • Fundamental Resources and Values — These are the most important ideas, tangi- THE NATIONAL MALL ble resources, or intangible values to be communicated to the public about a park Purpose and that warrant primary consideration during planning and management because The purposes of the National Mall are to they contribute to significance and are • Maintain the National Mall in the heart of critical to achieving the park’s purpose. A our nation’s capital as a stage for national fundamental resource and value is one that events and a preeminent national civic was specifically sanctioned by Congress in space for public gatherings because “it is legislation (such as for a memorial or here that the constitutional rights of speech

9 PURPOSE OF AND NEED FOR THE PLAN

and peaceful assembly find their fullest years ago. The form and character of our expression.” planned national capital still reflect the historic L’Enfant and McMillan plans. • Provide a monumental, dignified, and sym- bolic setting for the governmental struc- • The National Mall is an inclusive and open tures, museums, and national memorials as environment where we celebrate our na- first delineated by the L’Enfant plan and tional identity and important events. The further outlined in the McMillan plan, as National Mall, the nation’s foremost civic well as other significant plans. space, is the primary location for political demonstrations, First Amendment activi- • Maintain and provide for the use of the ties, rallies, parades, and numerous festi- National Mall with its public promenades vals. Visitors of every race, nationality, and as a completed work of civic art — a de- faith come to the National Mall to cele- signed historic landscape providing brate, commemorate, demonstrate, or extraordinary vistas to symbols of our recreate. nation. • The National Mall is a preeminent national • Maintain National Mall commemorative landscape, and its history and appearance works (memorials, monuments, statues, have been enriched by gifts to the United sites, and gardens) that honor presidential States from other countries. It is a combi- legacies, distinguished public figures, ideas, nation of formal designed areas, such as the events, and military and civilian sacrifices Mall and the grounds of the Washington and contributions. Monument, and naturalistic areas, such as • Forever retain the West Potomac Park sec- the Tidal Basin and West Potomac Park. tion of the National Mall as a public park Various trees and gardens symbolize cul- for recreation and enjoyment of the people. tural and diplomatic exchanges and gifts from other nations — such as the Japanese • Maintain the National Mall as an area free cherry trees, pagoda, and lantern, and the of commercial advertising while retaining German-American Friendship Garden, and the ability to recognize sponsors. Italy’s gift of the Arts of Peace. • The National Mall is the center of our na- Significance tion’s cultural heritage. The National Mall is The National Mall is significant for the following surrounded by many of the country’s most reasons: significant educational and cultural institu- tions, including the national museums of • The National Mall is the home to the endur- the Smithsonian Institution and the ing symbols of our country. It provides an National Gallery of Art, along with the inspiring setting for memorials, the back- nearby National Archives, the U.S. Bureau drop for the legislative and executive of Engraving and Printing, and the U.S. branches of our government, as well as a Holocaust Memorial Museum. visual connection between the branches of government, represented by the and the White House. The Fundamental Resources National Mall’s monuments, memorials, Memorials statues, and other commemorative works honor important personages, historical • Franklin Delano Roosevelt Memorial events, and the ideals of democracy. As a • Korean War Veterans Memorial result, it offers emotional and intellectual connections that affect our national • Lincoln Memorial and Reflecting Pool perceptions, consciousness, and identity. • Thomas Jefferson Memorial • The National Mall is the heart of our nation’s • Ulysses S. Grant Memorial capital and has endured since the city’s original design by Pierre L’Enfant over 200

10 Foundation for Planning and Management: The National Mall

• Vietnam Veterans Memorial, “In Memory” • The primary east-west cross axis between plaque, The Three Servicemen statue, the Capitol and the Potomac River and Vietnam Women’s Memorial, catalog listing beyond, planned by L’Enfant and symbol- of names on the wall, the flagpole izing potential westward expansion of the nation, and the north-south vista from the • Washington Monument White House to the Thomas Jefferson • World War II Memorial Memorial • 56 Signers of the Declaration of Inde- • The Washington Monument — a pivotal, pendence Memorial (Constitution Gardens central element of most views and vistas and Lake) • D.C. War Memorial Plans • First Air Mail Flight Marker • “L’Enfant Plan of the City of Washington” (1791) • • “Ellicott Plan for the City of Washington in • John Ericcson Memorial the Territory of Columbia” (1792) • • “Report of the Senate Committee on the • Martin Luther King, Jr. Commemorative District of Columbia on the Improvement Plaque — “I Have a Dream” Speech (steps of the Park System of the District of of the Lincoln Memorial) Columbia” (Senate Report No. 166, 57th Congress, 1st Session, 1902); hereafter referred to as the McMillan plan Park Areas • Constitution Gardens and Lake Fundamental Values • German-American Friendship Garden • A majestic landscape and a fitting setting for • Mall (1st Street to 14th Streets) the pomp and ceremony of state events, with the symbolism of strength, power, • Tidal Basin — first cherry tree planting, first protection, and safety. planting plaque, inlet bridge, Japanese lantern, Japanese pagoda, Kutz Bridge, • Free and open public access, both to the Outlet bridge, seawall, paddleboat kiosk physical space (which belongs to all citizens and is under the stewardship of the Na- Statues tional Park Service) and to the government. • Arts of Peace — Rock Creek and Potomac • The nation’s premier civic space — a venue Parkway entrance (the complementary for First Amendment demonstrations, na- sculptures, Arts of War, are under the tional celebrations, reflection and contem- jurisdiction of George Washington plation, recreation, and special events; a Memorial Parkway) place to explore values and ideas that reflect how Americans see themselves; an Views and Vistas area free of commercial advertising. • Hierarchy of internationally recognized • A visible connection between the legislative symbolic views and vistas based on the and executive branches of government. L’Enfant and McMillan plans • The portrayal of our nation’s history in the • Key vistas defined or framed by vegetation, monuments and memorials that bear testi- such as the formal rows of American elms mony to the vision of the founding fathers, on the Mall, European elms along the and the struggles and sacrifices of extra- Lincoln Reflecting Pool, and cherry trees ordinary leaders and ordinary citizens to around the Tidal Basin achieve that vision.

11

PURPOSE OF AND NEED FOR THE PLAN

FIGURE 1: THE NATIONAL MALL

The National Mall

• the home to the enduring symbols of our country

• the heart of our nation’s capital

• a preeminent national landscape

12 Foundation for Planning and Management: The National Mall

13 PURPOSE OF AND NEED FOR THE PLAN

• The ideas and values symbolized in com- - the Lincoln Memorial at the west end memorative works — freedom of speech, of the National Mall and the Grant national union, democracy, courage to fight Memorial at the east end, which physi- for ideals, citizenship, patriotism, leader- cally and symbolically represent the ship, invention / innovation, international re-unification of the nation at the end friendship, justice, unity leading to nation- of the Civil War hood, and the emotional connections that • Land reclamation by the U.S. Army Corps provide inspiration and healing. of Engineers and the creation of park lands • The physical and symbolic gateway of the for a range of recreational uses nation’s capital, which was oriented to the west, representing national expansion. Other Important Resources • Educational opportunities (museums, • Washington Monument flagpoles and U.S. cultural institutions, NPS interpretive flags, dedication flag, commemorative programs). stones, plaques, elevation obelisk, Monu- ment Lodge (tickets / bookstore), Survey • The visibility day and night of the National Lodge (ranger station and information), Mall’s architecture and designed land- marker, Sylvan Theater, scapes from the sky. Bullfinch gateposts • The contribution of the design and archi- • Museum collections and/or exhibits associ- tecture to the city’s character, and land- ated with the memorial sites — George marks that orient visitors to the city. Washington, Thomas Jefferson, Abraham • Association with the preeminent names in Lincoln, Franklin Delano Roosevelt, and late 19th and early 20th century landscape Vietnam Veterans architecture, including Frederick Law • Character-defining historic site furnishings Olmstead Jr. — historic seating (NPS standard Washing- • Healthy green infrastructure, ecosystems, ton benches) and lighting (Olmsted plan, and rivers; recognition that the National Washington globe, Twin Twenty and Mall is a significant component of the Saratoga lantern streetlights) Washington, D.C., park system. • Lockkeeper’s House for the Washington Canal Primary Interpretive Themes • Fountain renovated as a • The history of our capital and the story of central feature at the World War II our nation Memorial • The symbolic nature and unique purposes • West Potomac Park — Watergate steps, of civic space in the nation’s capital: belvedere, riverfront, ◦ First Amendment freedom of speech seawall, and the historic fountain at the ◦ celebration and patriotism George Mason Memorial ◦ The National Mall and Reserve as a • Trails and walks completed work of civic art • Active recreation space and athletic fields ◦ L’Enfant and McMillan plans for the local workforce, residents, and ◦ Themes directly related to commemora- visitors: tive works: ◦ ballfields at the Washington Monument - themes common to multiple memo- and the Franklin Delano Roosevelt rials (presidential legacies, sacrifice, Memorial liberty, equality, democracy, freedom, ◦ JFK hockey fields Civil War, etc.) ◦ Lincoln Memorial volleyball courts and ballfields

14 Foundation for Planning and Management: Legal Considerations

◦ activities such as bicycling, kite flying, Laws, regulations, and authorities that govern Frisbee, baseball, softball, kickball, the management of the National Mall include soccer, touch football those that are applicable to all national parks and ◦ Tidal Basin paddleboats to the National Park Service as a federal agency. As explained in the NPS Management Policies 2006, LEGAL CONSIDERATIONS The management of the national park system To aid in the discussion about the future of the and NPS programs is guided by the Constitu- National Mall, it is important to understand tion, public laws, treaties, proclamations, some of the key legal authorities that affect the executive orders, regulations, and directives management of these special areas and that will of the Secretary of the Interior and the Assis- tant Secretary for Fish and Wildlife and Water factor into the planning decisions for the (NPS Management Policies 2006, p. 2). National Mall plan. By no means does this discussion mention all of the authorities that The National Historic Preservation Act (NHPA), apply. For more information about laws and the National Environmental Policy Act (NEPA), regulations applying to the National Park the Clean Air Act, and the Clean Water Act are Service, see the NPS website at www.nps.gov/ among the laws applicable across the system. applications/npspolicy/index.cfm. Other laws apply to specific situations, such as those for making planning decisions affecting NPS Laws, Regulations, and parks in the greater Washington, D.C., area and that involve the National Capital Planning Com- Policies mission and the U.S. Commission of Fine Arts. The National Park System Still other laws and requirements apply to just the National Mall, such as those for individual As part of the national park system, the National memorials. Mall is administered by the National Park Service. NPS historians describe the National NPS Organic and General Authorities Mall as one of the oldest elements of today’s Acts national park system, dating from the creation of the District of Columbia in the 1790s. Knowing According to the NPS Management Policies 2006, why these legal considerations apply is essential the most important statutory directive for the to factoring them into planning decisions for the National Park Service is provided by interrelated National Mall plan. In this instance, many of provisions of the NPS Organic Act of 1916 and these laws and other requirements are applicable the NPS General Authorities Act of 1970, includ- because these areas are part of the national park ing amendments to the latter law in 1978. The system. As described by the NPS Management key management-related provision of the Policies 2006, Organic Act (16 USC 1) is as follows: The national park system was created to con- [The National Park Service] shall promote serve unimpaired many of the world’s most and regulate the use of the Federal areas magnificent landscapes, places that enshrine known as national parks, monuments, and our nation’s enduring principles, and places reservations hereinafter specified . . . by such that remind us of the tremendous sacrifices means and measures as conform to the fun- Americans have made on behalf of those damental purpose of the said parks, monu- principles. They are the most remarkable ments, and reservations, which purpose is to collection of places in America for recreation conserve the scenery and the natural and and learning. Visitors can immerse themselves historic objects and the wild life therein and in places where events actually happened and to provide for the enjoyment of the same in enjoy some of the most significant natural and such manner and by such means as will leave historic places in America. As required by the them unimpaired for the enjoyment of future 1916 Organic Act, these special places must be generations. managed in a special way — a way that allows them to be enjoyed not just by those who are Congress supplemented and clarified these here today, but also by generations that provisions through enactment of the General follow (NPS Management Policies 2006, p. iii). Authorities Act in 1970, and again through

15 PURPOSE OF AND NEED FOR THE PLAN enactment of a 1978 amendment to that act (16 Regulating Public Use USC la-1). These acts added Regulations in the Code of Federal Regulations [t]he authorization of activities shall be (CFR) apply to all federal agencies, and certain construed and the protection, management, regulations apply only to the administration of and administration of these areas shall be the national park system. The Code of Federal conducted in light of the high public value and integrity of the National Park System Regulations addresses public use limits, which and shall not be exercised in derogation of the superintendent may establish based on a the values and purposes for which these determination that limits are “necessary for the various areas have been established, except maintenance of public health and safety, pro- as may have been or shall be directly and tection of environmental and scenic values, specifically provided by Congress. protection of natural and cultural resources, . . . or implementation of management responsibili- First Amendment Jurisprudence ties, equitable allocation and use of facilities, or the avoidance of conflict among visitor use Any governmental regulation of demonstrations activities” (36 CFR 1.5). and related sales activities is subject to First Amendment jurisprudence. The National Park Permitted activities “shall be consistent with Service’s regulation of demonstrations and sales legislation, administrative policies and based activities on federal parkland has been the sub- upon a determination that public health and ject of extensive First Amendment litigation for safety, environmental or scenic values, natural or many years. cultural resources, scientific research, imple- mentation of management responsibilities, Recognizing the importance of the National proper allocation and use facilities, or the Mall and its nearby monuments and memorials, avoidance of conflict among visitor use activities the United States Court of Appeals for the will not be adversely affected” (36 CFR 1.6). A District of Columbia Circuit stated that “the permit may be denied if the capacity of the area Mall is more than home to these enduring or facility would be exceeded by one or more of symbols of our nationhood.” The court opinion the factors previously listed. continues, Its location in the heart of our nation’s capital Regulations at 36 CFR 7.96 contain provisions makes it a prime location for demonstrations. specific to the greater Washington, D.C., area. It is where Martin Luther King, Jr., delivered The following are provisions that center on his famous “I Have a Dream” speech, where public uses and figure prominently in the both sides of the abortion debate have staged administration of the National Mall. their demonstrations, and where on any given day one may witness people gathering to voice Demonstrations, Special Events, and their public concerns. As the court has stated National Celebrations before, “It is here that the constitutional rights of speech and peaceful assembly find their Demonstrations, special events, and national fullest expression” (Friends of Vietnam Memo- celebrations are defined as follows (36 CFR rial v. Kennedy, 116 F.3d 495, 496 (D.C. Cir. 7.96(g)(1)): 1997), quoting ISKCON of Potomac v. Kennedy, 61 F.3d 949, 952 (D.C. Cir. 1995)). • Demonstrations — The term includes demonstrations, picketing, speechmaking, In the context of such longstanding First marching, holding vigils or religious ser- Amendment jurisprudence, and consistent with vices, and all other like forms of conduct NPS regulations and policies that allow demon- that involve the communication or expres- strations and sales activities under certain condi- sion of views or grievances, engaged in by tions, as discussed below, demonstrations must one or more persons, the conduct of which be considered to be at least legally consistent has the effect, intent, or propensity to draw with the special nature and sanctity of the Na- a crowd or onlookers. This term does not tional Mall. Other cases involving First Amend- include casual park use by visitors or ment rights are listed in Table 1.

16 Foundation for Planning and Management: Legal Considerations

TABLE 1: RECENT FIRST AMENDMENT CASE LAW SUMMARY

Date Topic/Issue and Outcome 1972 If one group is allowed to use structures to communicate views, then others must be similarly allowed. Women Strike for Peace v. Morton, 472 F.2d 1273 (D.C. Cir. 1972). 1975 The National Park Service may regulate demonstrations, including permit denial (36 CFR 7.96 (g)) if "enforced uniformly and without discrimination." The National Park Service may not limit the duration of demonstra- tions in view of the availability of less restrictive methods. A Quaker Action Group v. Morton, 516 F.2d 717 (D.C. Cir. 1975). 1982 The application of NPS camping regulations on the National Mall and in Lafayette Park does not violate the First Amendment. The regulation meets the requirements for a reasonable time, place, or manner restriction of expression, whether oral, written, or symbolized by conduct. The regulation is neutral and narrowly focuses on the federal government’s substantial interest in maintaining the parks in the heart of the capital in an attractive and intact condition, readily available to the millions of people who wish to see and enjoy them. Clark v. Community for Creative Non-Violence, 468 U.S. 288 (1984). 1992 A prohibition against the free distribution of leaflets on certain sidewalks within the restricted zone of the Vietnam Veterans Memorial (36 CFR 7.96(j)(2)(vi)) was voided as not “narrowly tailored.” Henderson v. Lujan, 964 F.2d 1129 (D.C. Cir. 1992). 1992 A conviction (36 CFR 2.12(a)(1)(i)) for creating an audio disturbance was voided. While the court recognized that the government may justifiably impose sound volume restrictions, the regulation was not "narrowly tailored." United States v. Doe, 968 F.2d 86 (D.C. Cir. 1992). 1995 NPS sales regulations (36 CFR 7.96(k)) were upheld as consistent with the First Amendment. ISKCON of Potomac v. Kennedy, 61 F.3d 949 (D.C. Cir. 1995). 1997 NPS sales regulations were again upheld as consistent with the First Amendment. Friends of the Vietnam Veterans Memorial v. Kennedy, 116 F.3d 495 (D.C. Cir. 1997). 2001 NPS sales regulations were again upheld as consistent with the First Amendment, as well as consistent with Religious Freedom and Restoration Act and equal protections. Henderson v. Kennedy, 253 F.3d 12 (D.C. Cir. 2001).

tourists which does not have an intent or Festival, Columbus Day Commemorative propensity to attract a crowd or onlookers. Wreath-Laying, and Presidential Inaugural Ceremonies. • Special events — The term includes sports events, pageants, celebrations, historical Public gatherings or demonstrations involving reenactments, regattas, entertainments, more than 25 people within the National Mall exhibitions, parades, fairs, festivals, and and Memorial Parks generally require a permit similar events (including such events pre- issued by the National Park Service. To preserve sented by the National Park Service), which an atmosphere of calm, tranquility, and rever- are not demonstrations as previously ence, certain memorial areas exclude demon- defined, and which are engaged in by one strations or special events. These areas include or more persons, the conduct of which has specific portions of the Washington Monument, the effect, intent, or propensity to draw a the Lincoln Memorial, the Thomas Jefferson crowd or onlookers. This term also does Memorial, the Vietnam Veterans Memorial, and not include casual park use by visitors or the World War II Memorial (see 36 CFR tourists which does not have an intent or 7.96(g)(3)(ii) for specific exclusions). propensity to attract a crowd or onlookers. A permit may be denied if multiple uses cannot • National celebration events — The term be accommodated in the same area at the same means the annually recurring special events time; there is a clear and present danger to the regularly scheduled by the National Capital public safety, good order, or health; the pro- Region, including Lighting of the National posed demonstration or special event is of such Christmas Tree and Christmas Pathway of a nature or duration that it cannot reasonably be Peace, Cherry Blossom Festival, Fourth of accommodated in a certain area; or activities are July Celebration, Smithsonian Folklife

17 PURPOSE OF AND NEED FOR THE PLAN contrary to other applicable laws or regulations Memorials and the Reserve (36 CFR 7.96(g)(4)(iii)). Each memorial on the National Mall was placed Permit conditions for demonstrations and there pursuant to a specific law or laws enacted events include how long events may last; hours by Congress for that particular memorial. Since of operation to avoid unreasonable interference the mid-1980s the process through which a with rush-hour traffic; and allowance of memorial is authorized, funded, designed, and temporary structures erected for the purpose of sited has been governed by the Commemorative symbolizing a message or meeting logistical Works Act (40 USC 8901 et seq.). This law pro- needs (such structures may not unreasonably vides standards and requirements for the loca- harm park resources and shall be removed as tion, design, and construction of new memorials soon as practicable). Permits for special events on federal lands administered by the National are limited to four months. Permits for demon- Park Service and the General Services Adminis- strations may be extended if space is available tration in the District of Columbia and a portion (36 CFR 7.96(g)(5)). The regional director may of northern Virginia near the District. Provisions impose reasonable restrictions on the use of of the Commemorative Works Act include those temporary structures in the interest of protect- requiring consultation with the National Capital ing park areas, traffic, and public safety. Memorial Commission and for the review and approval of new memorials by the U.S. Commis- Sound amplification equipment is allowed in sion of Fine Arts and the National Capital Plan- connection with permitted demonstrations or ning Commission. Compliance with this law is special events as long as it does not unreasonably informed by memorial guidance plans that have disturb nonparticipating persons in, or in the been developed by these commissions and vicinity of, the area (36 CFR 7.96(g)(5)(xii)). others. Some of the 2003 amendments to this law stemmed from recommendations in these plans Recreational Activities that were also presented to Congress in hearings.

Regulations pertaining to recreational activities The purposes of the Commemorative Works Act require permits for organized games such as include preserving the integrity of the compre- baseball and football, and for model airplane hensive design of the L’Enfant and McMillan flying; prohibit athletics if the grounds are wet or plans for the nation’s capital; ensuring the otherwise unsuitable for play without damage to continued public use and enjoyment of open the turf; allow fishing in accordance with state space in the District of Columbia; preserving and law; allow ice skating only in designated areas; maintaining open space; and ensuring that these and prohibit swimming (36 CFR 7.96(b) through memorials are appropriately designed, con- (e)). structed, and located, and that they reflect a consensus of the lasting national significance of Soliciting their subjects. Soliciting is allowed if under a permit (ISKCON Congress, in the 2003 amendments to the Com- of Potomac v. Kennedy, 61 F.3d 949 (D.C. Cir. memorative Works Act, defined the Reserve as 1995)). “the great cross-axis of the Mall which . . . gener- ally extends from the United States Capitol to Sales the Lincoln Memorial, and from the White A permit is required for the sale or distribution House to the Jefferson Memorial” (sec. 202(a)). of books, newspapers, leaflets, pamphlets, The National Mall is located within the Reserve. buttons, and bumper stickers from a stand or Frequently, memorials have some visitor facili- structure during a special event (36 CFR ties such as restrooms, visitor contact stations, 7.96(k)). and bookstores, but they stop short of being visitor centers both in size and in range and types of facilities they contain. Further, Congress provided that following enactment of the 2003 amendments “no commemorative work or visitor center shall be located within the

18 Foundation for Planning and Management: Legal Considerations

Reserve” (sec. 202(b)). This did not include and the secretary that development of visitor those unbuilt memorials that had been previ- services in park areas must be limited to those as ously approved for sites on the National Mall, are necessary and appropriate for public use and such as the Martin Luther King, Jr. Memorial enjoyment of the park area in which they are and the Vietnam Veterans Memorial Center. located.

On December 16, 2003, Congress authorized the At present, the National Park Service has a con- establishment of the National Museum of cession contract with Guest Services, Inc., to African American History and Culture as part provide an array of services to visitors to the of the Smithsonian Institution and stated that it National Mall. Visitors to the National Mall may could be sited in some places on the National also obtain interpretive transportation services Mall. The site selected in January 2006 pursuant through the NPS concessioner known as to that law is on the Washington Monument Landmark Services Tourmobile Inc. grounds, between 14th and 15th Streets NW and Constitution Avenue and Madison Drive NW. The Department of the Interior and Related At present the site temporarily accommodates Agencies Appropriations Act of 2004 (PL 108- an NPS concession facility for refreshments and 108, Nov. 10, 2003) contains provisions to pro- sundries. The National Park Service will not be hibit the erection, placement, or use of struc- administering this museum or its grounds. tures and signs bearing commercial advertising at special events on the National Mall (sec. 145). The sponsors of special events may be recog- Commercial Activities and nized provided that the size and form of the Transportation recognition is consistent with the special nature The National Park Service Concessions Man- and sanctity of the National Mall. agement Improvement Act of 1998 directs that The following regulations restrict commercial “except as provided by this title or otherwise activities in all units of the national park system: authorized by law, the Secretary [of the Interior] shall utilize concessions contracts to authorize a • Advertisements — Commercial notices or person, corporation, or other entity to provide advertisements shall not be displayed, accommodations, facilities, and services to visi- posted, or distributed on federally owned tors of the National Park System” (Public Law or controlled lands within a park area [PL] l05-391, sec. 403, 112 Stat. 3504). The NPS unless prior written permission has been regulations concerning concessions are found at given by the superintendent. Permission 36 CFR Part 51. may be granted only if such notices and advertisements are found by the super- It is the policy of Congress and the Secretary of intendent to be desirable and necessary for the Interior that visitor services in park areas the convenience and guidance of the public may be provided only under carefully controlled (36 CFR 5.1). safeguards against unregulated and indiscrim- • Business operations — Engaging in or inate use so that commercial activities will not soliciting any business in park areas, except unduly impair park values and resources. in accordance with the provisions of a Development of visitor services is limited to permit, contract, or other written agree- locations that are consistent to the highest ment with the United States, except as such practicable degree with the preservation and may be specifically authorized under conservation of the resources and values of the special regulations applicable to a park area, park area. It is also the policy of the Congress is prohibited (36 CFR 5.3).

19

SCOPE OF THIS DOCUMENT

This chapter discusses opportunities, problems, New Destinations with the National Mall, a joint and challenges that the alternatives need to effort of the National Capital Planning Commis- address in order to fully meet the purpose of and sion (NCPC) and the U.S. Commission of Fine need for the plan. Following this discussion is a Arts (NCPC 2009). list of the environmental impact topics that have been analyzed in detail; these topics are based on OPPORTUNITIES, PROBLEMS, AND this discussion of opportunities, problems, and CHALLENGES challenges, as well as on federal laws, regula- tions, and policies, and also on public scoping A number of critical issues need to be addressed comments. This chapter concludes with a list of through comprehensive planning. Areas of pub- the topics that were dismissed from further lic interest and concern include preservation of consideration because there would be no im- resources and the historic character, the health pacts or because the impacts would be negligible and appearance of the National Mall, appro- or minor. priate uses and levels of use, the impacts of per- mitted events and security on public and recrea- Both the National Mall and Pennsylvania Ave- tional uses, and the challenges of maintaining nue were addressed during the early stages of the National Mall to high standards of this planning effort. Because the issues facing excellence. these areas are somewhat different, a separate environmental document will be prepared for The most important goal for planning is to . This is consistent with the define a clear and common vision for balancing Monumental Core Framework Plan: Connecting use of the National Mall, and achieving desired

Ongoing Projects on the National Mall Several ongoing projects are related to this plan but are beyond its scope because they would be undertaken by other entities or because they have been previously approved and funded and implementation is underway. When Congress amended the Commemorative Works Act in 2003, it stated that the National Mall is a “com- pleted work of civic art,” and it established the Reserve area to protect it (see page 263). The Reserve is to remain free of additional memorials and visitor centers except for the following, which Congress had already approved: • Vietnam Veterans Memorial Center — An underground facility will include restrooms, information, exhibits, administrative space, and a bookstore. • National Museum of African American History and Culture — Land has been transferred to the Smithsonian Institution. The food service and retail functions at the Washington Monument will be relocated. • Martin Luther King, Jr. Memorial — The new memorial will include restrooms, a visitor contact station, and a bookstore. Memorials are now being considered for sites outside the Reserve. These sites have been indentified in the 2001 Memorials and Museums Master Plan, which was produced by the National Capital Planning Commission working with the U.S. Commission of Fine Arts and the National Capital Memorial Commission (which includes the National Park Service) as the Joint Task Force on Memorials. Existing memorials on the National Mall will be maintained and protected under applicable law, regulations, and policy. Five deferred maintenance projects affecting the National Mall have been funded through the American Recovery and Reinvestment Act of 2009. They include the Lincoln Memorial Reflecting Pool area (lower approachway, pool, and related landscape, plus the north and south elm walks), the D.C. War Memorial, the Thomas Jefferson Me- morial plaza seawall, Madison Drive, and Ohio Drive. Also the preferred alternative in the NPS 2006 Visitor Trans- portation Study, which addresses strategies to reduce and manage transportation demand within the area, as well as a visitor transportation service around the National Mall, is being implemented. Other projects include a co- ordinated National Mall sign system, which has been approved, and the Potomac Park levee project, which will address flood protection for downtown D.C. These projects are considered as present and reasonably foreseeable projects in the cumulative impact analyses in “Environmental Consequences.”

20 Scope of this Document: Opportunities, Problems, and Challenges natural and cultural resource conditions. The FIGURE 2: MALL TREE CONDITIONS NPS presence is not readily apparent on the National Mall, and the agency’s stewardship mission and regulations may not be understood.

National Mall Issues and

Background

Cultural Resources

The National Mall’s Evolving History

Issue — To what extent can the evolving history of the National Mall be balanced with the con- servation of the historic landscape character, It takes many years for replacement trees to reach the height and what desired cultural resource management of established trees. The bare spots are the result of temporary standards should be achieved? event facilities.

Background — The National Mall concept Mall and over 2,100 Japanese cherry trees encir- dates from the 1791 L’Enfant plan and took its cle the Tidal Basin. Flower beds are botanical present form as a result of the 1901 McMillan showplaces for thousands of tulips, pansies, and plan and other historically significant plans. annuals. The impressive mingling of natural and Within the National Mall separate park areas cultural resources has made Washington, D.C., have evolved as memorials and have been built one of the most heavily visited and photo- to honor famous Americans or to commemorate graphed cities in the world. However, the important events. Planning over the last quarter National Park Service has repeatedly heard from of the 20th century focused on specific projects, the general public that landscape conditions and such as memorials. The result has been a frag- maintenance need to be improved. mented approach that affects our country’s Turf and trees are generally perceived as renew- premier national historic landscape with its great able resources, but it takes generations to grow American symbols of democracy. the Mall’s magnificent shade and ornamental Primary vistas that were defined in historic land- trees, which are important contributing features mark plans, along with large areas of unpro- of the historic landscape. Over the last two grammed open space that emphasize historic decades there has been a substantial loss of tree landscape features, may be obscured. For cover within the District of Columbia, affecting example, the view from the White House to the not only air quality and temperature, but also the Thomas Jefferson Memorial is somewhat quality of life. Soil compaction affects the health obscured by trees on the northeast side of the of trees, as well as the urban ecosystem, and ur- Tidal Basin, and temporary facilities for events ban flooding. on the Mall can sometimes obstruct the view between the U.S. Capitol and the Washington Natural Resources Monument. Issue — What is the most appropriate way to deal with water quality issues of natural and The Historic Landscape’s Health man-made features, soil and vegetative condi- and Appearance tions, flood control, and urban wildlife? Issue — To what extent can the highest stan- Background — Water quality issues affect most dards for various landscapes be achieved and water features, such as pools and ponds, and sustained while accommodating frequent changes in water chemistry have resulted in intensive public use? algae growth. Some pools and ornamental Background — The National Mall is a symbol of fountains lack proper circulation systems, and our nation and is expected to exemplify superior the Tidal Basin does not flush as intended. Three standards. Nearly 600 American elms line the major water features (the Lincoln Reflecting

21 PURPOSE OF AND NEED FOR THE PLAN

Pool, Constitution Gardens Lake, and the result of putting Tiber Creek underground to at Union Square) use create Constitution Avenue. millions of gallons of potable water each year. Demonstrations, Special Events, and About half of the National Mall has been con- National Celebrations structed from tidal flats, and much of the west- ern portion of the National Mall lies within the Issues — Different regulations apply to demon- 100- and 500-year floodplains. Imported soils strations and special events, so the issues are have often been of poor quality. Additionally, slightly different. soil compaction and hardened turf areas from • Within the confines of policy and regula- high levels of use affect tree root systems, partic- tion, to what extent can the ability to ac- ularly the cherry trees near the Tidal Basin and commodate First Amendment demonstra- the American elms on the Mall. Social trails tions be improved on the National Mall? (user-created trails off paved paths) adjacent to formal trails or water edges destroy turf and • Within the confines of policy and regula- further compact soils. In 1992 the director of the tion, to what extent can events be sustain- National Capital Region wrote to the director of ably and efficiently staged on the National the National Park Service about the impact of Mall while simultaneously achieving activities on turfgrass on the Mall: desired resource conditions? The only way maintenance efforts can be • What is the role and physical expression of realized is to restrict the recurrent scheduled the civic stage in the 21st century? activities and heavy visitor use patterns that negate every effort the National Park Service Background — The National Mall has been re- expends to manage the site. ferred to as the nation’s front yard, the space where national pageantry, celebrations, cultural Various urban wildlife species are present, along events, and demonstrations occur. This highly with less frequently seen fox and deer. Visitors visible space in the heart of our nation’s capital have complained about droppings from resident has evolved into the national forum — the place ducks and Canada geese. where large and small demonstrations and rallies take place, and where people can petition their Urban air quality is impacted by vehicular ex- government, present and debate differing haust. Urban sounds, such as traffic and airplane positions, advocate for action, or express pride noise, are audible throughout park areas. Water in their identity, organizations, or causes. features may mask noise to some degree. Over 3,000 permitted demonstrations, national Park managers can do little to prevent global celebrations, and other events (including per- climate change; however, they can take some steps mitted sporting events) take place annually on to mitigate its impact. A 3-foot rise in sea levels the National Mall, including would affect areas and infrastructure throughout Washington, D.C., including the National Mall.

Increased storm severity could result in tidal FIGURE 3: A NATIONAL DEMONSTRATION AT THE U.S. surges that inundate more park areas. CAPITOL AND UNION SQUARE A U.S. Army Corps of Engineers flood control levee runs north of the Lincoln Reflecting Pool to the Washington Monument grounds. Stan- dards for flood control were modified after Hur- ricane Katrina, and the levee will need to meet higher standards. As a result, new improvements for the levee are being developed.

Large rainstorms may temporarily exceed the capacity of the stormwater drainage system and result in flooding. There is a high water table as a Demonstration organizers frequently choose the National Mall because of its high visibility and recognizable national symbols.

22 Scope of this Document: Opportunities, Problems, and Challenges

• public demonstrations in connection with FIGURE 4: A SPECIAL EVENT ON THE MALL First Amendment rights

• annual celebrations, such as the National Cherry Blossom Festival, Memorial Day, the Smithsonian Folklife Festival, and the

Fourth of July

• regularly scheduled concerts and cultural programs

• hundreds of events such as solar technol- ogy displays, book fairs, public employee

recognition events, the laying of commem- orative wreaths, re-enlistment ceremonies, Tents and other structures are used during permitted events. or school group musical performances, as well as one-time events, such as a state funeral or home building for Hurricane Katrina victims

• annual marathons, triathlons, and foot

races benefiting various causes, and hun- dreds of recreational league team sports

Additionally around 900 commercial filming permits are issued every year.

The sheer number of special events with atten- dant deliveries and logistics, setup and take- down, and temporary facilities affects landscape Food tents set up in the elm tree panels on the Mall for a health and the ability of NPS staff to maintain permitted event. park natural resources such as turf and trees. Significant character-defining elements and irrigation system, rendering the system largely historic planned vistas are also affected. Tempo- dysfunctional. rary facilities, which include stages, signs, tents, bleachers, portable restrooms, and food service, A number of highly visible venues are attractive are frequently located on turf or under tree for First Amendment demonstrations because canopies. Turf may be demolished and its health their backdrops contain symbols of our nation. impacted by compaction that affects water Improvements to access, paving, facilities, and infiltration. Compaction near the roots of trees utilities could facilitate demonstrations. is detrimental to tree health. The Code of Federal Regulations limits permitted A late 1980s practice of installing 6 inches of special events (not demonstrations) on the mulch under trees was abandoned because of National Mall to four months, including setup the cost burden of clean up. Instead, mats or and takedown time. This event time limit has not temporary surfaces are used in some areas. been enforced uniformly. The reservation Temporary walks, which spread weight to system for events does not take advantage of reduce soil compaction, at the same time deprive current technology. the turf of air and moisture, and in hot weather result in burning of the turf. In 1989 construc- Access and Circulation tion trenching of more than 4,400 linear feet Issue — To what extent can public access be severed tree roots on the Mall. improved?

Utility infrastructure is lacking, and tent stakes Background — The urban streets near the used during events have penetrated into the National Mall accommodate around 400,000 commuters every weekday. The road system

23 PURPOSE OF AND NEED FOR THE PLAN may be difficult to navigate for infrequent service to destinations, improved connections to visitors. Crosswalks have limited pedestrian public transit, and links to public transportation. crossing times. There is a large regional bicycle The preferred alternative in the study would be riding population that commutes and engages in common to all alternatives and has been de- recreational riding. Up to 25% of visitors may scribed under cumulative impacts in the “Envi- not be able to walk long distances or may be- ronmental Consequences” portion of this come exhausted from walking between memo- document. rials. There are few amenities for pedestrians walking to the National Mall. Visitor Education, Interpretation, and Enjoyment The addition of public transit, including the Metro stop in front of the Smithsonian Castle, The National Mall within a Complex Urban and increased nighttime visitation are important Framework changes that were not anticipated by the original Issue — To what extent can this national sym- planners. Once visitors are on the National Mall, bolic landscape function efficiently and be com- public transit access is limited. Tourmobile patible with desired experiences of national and provides hop-on/-off service to attractions on international visitors while meeting the needs of the National Mall for $27 per day. The Smith- federal and city governmental agencies, local sonian–National Gallery of Art Circulator residents, and the local workforce? provides seasonal service on Independence and Constitution avenues west to 17th Street. Background — The National Mall is a pilgrim- age site for many people, precisely because it is Parking is at a premium within and near the located at the core of our national capital. It National Mall, with many more vehicles than symbolizes the openness and diversity of a parking spaces. The National Park Service democratic society, and its design captures the provides approximately 1,000 free on-street country’s core values and ideals. When it was public parking spaces in and around the Mall. planned, the National Mall was at the edge of About 550 public parking spaces under the the downtown area, now it is the heart of the city Smithsonian Institution museums were closed and its role in the city has evolved. The concen- between 1983 and 1985 for security reasons. The tration of visitor destinations within the core District of Columbia has 200 parking meters on area and ongoing numerous large-scale gather- north-south cross streets (3rd, 4th and 7th ings bring vitality to the urban environment, but streets NW/SW). There are 3,750 on-street also complicate maintenance tasks. Landscape metered parking spaces with 0.5 mile north and conditions are not maintained to the highest south of the National Mall. Drop-off locations standards. Streets accommodate heavy com- for visitors with disabilities are not always con- muter traffic, and a large number of bicyclists venient. use the same walkways as slower pedestrians. To orient people to the city, the Smithsonian Insti- Public scoping comments have suggested that tution makes Tourmobile brochures available at underground parking should be provided on the the Smithsonian Castle visitor center, and the National Mall. Approved plans by the National NPS Mall kiosk by the Metro entrance is sup- Capital Planning Commission and the D.C. plied with a Smithsonian-designed Mall map on government envision a transit-oriented future tear-off pads. for central Washington to address congestion and insufficient parking. Up to a third of visitors to the National Mall may arrive by tour bus. Interpretation / Education Issue — What kinds of opportunities or im- The National Park Service has prepared an Envi- provements in interpretation and education ronmental Assessment and Visitor Transportation should be made so that park visitors and all Study (NPS 2006c) to continue providing inter- Americans can be inspired by the National Mall, pretive visitor transportation service for access as well as understand and enjoy it, and develop a to museums and other visitor destinations on or personal stewardship ethic toward supporting near the National Mall and Pennsylvania its preservation? Avenue. The system would offer more frequent

24 Scope of this Document: Opportunities, Problems, and Challenges

FIGURE 5: RECREATION ON THE NATIONAL MALL programs, performances, demonstrations, sightseeing, and taking pleasure in eating, recreation, or other activities within the context of a nationally symbolic landscape.

Recreational Use

Issue — To what extent can recreational uses of the National Mall be achieved in combination

with public gatherings and visitation to monu- ments, memorials, and museums?

Background — The National Mall has histor-

ically been the location for numerous local rec- reational activities. Passive recreation, such as Portions of the National Mall are regularly used by local picnicking, strolling, or sunbathing, occurs si- residents for informal recreation. multaneously with informal or organized activi- ties, such as pickup games and league sports Background — Visitors come to the National (softball, baseball, football, and soccer). The Mall to experience and learn more about our majority of active recreation occurs on open turf national capital and the wealth of educational, areas, with groups supplying their own equip- cultural, civic, and recreational opportunities ment, such as goals and bases. The only recrea- that it offers, from the many monuments and tional facilities provided are the paddleboats on memorials, to the museums of the National the Tidal Basin, seasonal ice skating facilities, Gallery of Art and the Smithsonian Institution, and a few locations with backstops or goal posts. along with the National Archives, the U.S. Capi- Skateboarding is prohibited since it damages tol, the , the U.S. Botanic memorials, curbing, steps, and walls. Swimming Garden, the Supreme Court, the Bureau of and wading in memorial fountains are also Engraving and Printing, and the U.S. Holocaust prohibited. Memorial Museum. Differing goals may result in safety concerns for Memorials and park areas provide numerous various types of users. Out-of-town visitors typi- opportunities to learn about commemorative cally want opportunities for passive recreation sites, unique features, activities or uses such as and sightseeing, along with access to monu- demonstrations, and site history. With many ments, memorials, and cultural destinations. international tourists, special efforts are made to Local residents, however, may desire consistent communicate with non-English speaking visi- access to public open space that is suitable for tors. Educational and interpretive opportunities active recreation. Large-scale events in particu- are affected by the numerous activities that oc- lar may interfere with either or both of these cur within the boundaries of the National Mall, uses. from First Amendment demonstrations to large- scale annual celebrations. Space and time con- Visitor Amenities straints also limit interpretive contacts. Issue — What visitor amenities and services are Enjoyment appropriate? How should the architectural character be unified? Issue — To what extent can additional oppor- tunities be offered for visitors to enjoy them- Background — The National Park Service pro- selves on the National Mall, while respecting the vides visitor amenities such as restrooms, book- historic design and significance of the area? stores, and concession and food service facili- ties. Past planning proposed a wider variety of Background — Inspiration, welcome, and restaurants and food service. patriotism are components of an enjoyable visit to the National Mall. Visits may also include

25 PURPOSE OF AND NEED FOR THE PLAN

The variety of architectural styles in visitor facili- Health, Public Safety, and Security ties within the National Mall does not contri- Issue — What health and safety improvements bute to a unified identity to make them, as well are needed? How do safe, secure visits correlate as the NPS presence, readily apparent. Some with the openness that is characteristic of a facilities are outdated and difficult to maintain. democracy? Restrooms are insufficient for demand and are not located near food service outlets. Park furni- Background — The National Mall attracts im- ture is not coordinated, and seating is insuffi- mense numbers of visitors who need and expect cient at some times and is not focused on views. adequate safety, public notification, protection Shaded seating is highly desirable in the summer from crime, and the ability to get help if they as is group seating. Shelter is desirable in case of have health emergencies. inclement or hot weather. The National Capital Planning Commission and The use of multiple types of paving throughout consultants have been involved for many years in the National Mall does not contribute to a sense reviewing the planning, design, and implementa- of place or unified character. Loose paving tion of security measures throughout the District, material, such as gravel, migrates onto paved even before the events of September 11, 2001. walks and into grass. Gravel is also slippery to Constructed and proposed interim and perma- walk on, dust has resulted in complaints, and it nent measures to protect important national makes access difficult for people with disabili- symbols have been criticized for altering the ties. Existing paving materials may not meet the character, openness, and democratic symbolism needs of joggers and bicyclists. of the National Mall, and also for not addressing the area comprehensively. The night sky in Washington, D.C., is dominated by five symbolic icons that focus how people see NPS perimeter security projects have been com- the city — the U.S. Capitol, the White House, the pleted or are underway for the Washington Washington Monument, the Lincoln Memorial, Monument, the Lincoln Memorial, and the and the Thomas Jefferson Memorial. Other pub- Thomas Jefferson Memorial. Museums lining lic and private buildings, memorials or public the Mall also have perimeter security projects art, streets and walks, and park areas are lit to underway or completed. varying degrees, with the potential for conflict. There is no written and approved lighting plan Highly used areas with many different activities to protect the city’s nighttime character and can result in safety concerns or use conflicts. provide guidance. Examples are bicycle use on sidewalks and softball games near areas where people are Food service is offered at refreshment stands picnicking or walking. Paving materials make and mobile carts, and retail items are available at some areas difficult to access for visitors with some locations. Public comments indicate that disabilities, and some furniture does not meet additional commercial visitor services are de- accessibility guidelines for disabled individuals. sired, including recreational opportunities, such as kayaks, rowboats, model boats, and lawn Pedestrian waiting areas at some intersections chairs. The alternatives indicate general loca- are too small. Street crossing times may be too tions for these types of opportunities. Park staff short for many visitors, and jaywalking is must assess the economic feasibility, necessity, common in some areas. Some pedestrian walks and appropriateness of any service changes. are not lit at night. No lighting and low lighting can contribute to occurrences of criminal Park staff must also assess the economic feasi- activity. bility, necessity, and appropriateness of addi- tional commercial services, plus determine the Hot, humid weather and air pollution contribute service types and levels that would be offered. to visitor discomfort and health issues for the Commercial service would be offered using public as well as staff. Weather-related warnings available authorities. Currently authorized are issued as needed both for the public and visitor services would be continued. staff. Drinking fountains need frequent repairs, and surfaces and basins may not be sanitary.

26 Scope of this Document: Opportunities, Problems, and Challenges

Plastic water bottles generate a large amount of gum removal may require special maintenance trash, and recycling is not universal. techniques.

The General Services Administration operates Site furnishings such as signs, bicycle racks, or an aging steam tunnel / vent system that runs seating at specific memorials have been custom under the National Mall. The system needs designed, or they may be contributing elements extensive repairs; some repairs have been re- of historic landscapes and listed on the National cently completed. It contributes to excess mois- Register of Historic Places. Various non-stan- ture inside the Washington Monument and can dardized furnishings (such as irrigation systems, adversely affects nearby trees and vegetation. mechanical systems for water features, and light The vents attract use by homeless people during fixtures and bulbs) contribute to maintenance cold weather. Steam leaks may result in burns. challenges because of the need to stock an assortment of replacement parts and for staff to Shrub beds and other densely planted areas are be familiar with multiple maintenance practices. used for storage and sleeping by the city’s home- less population. Federal regulations prohibit Communication capabilities for park operations, camping on the National Mall. Restrooms and events, public information/education, emergen- fountains may be misused for personal hygiene. cies, or media use are inefficient or lacking.

Nighttime visitation has become more common. Specific Area Issues and Public comments have indicated the need for better lighting in some areas. Background The Mall Park Operations • Union Square (1st to 3rd Streets) — The Maintenance and Operational Challenges Ulysses S. Grant Memorial needs to be Issue — What types of facilities, furnishings, or repaired and restored, and the Capitol organizational practices would make park Reflecting Pool needs to be rehabilitated. maintenance operations more efficient? The Capitol backdrop makes this a popular venue for demonstrations and events, but Background — There is a substantial amount of there are no amenities or utilities to meet deferred maintenance on the National Mall, the needs of visitors or demonstrations and totaling approximately $508 million. Park staff permitted events. The large pool is an ob- may not be able to keep up with planned and stacle to convenient pedestrian circulation scheduled maintenance due to multiple, often between the Capitol and the National Mall. conflicting and immediate demands. There are Multiple levels or grade changes inhibit over 20,000 light fixtures and various site fur- universal access and include narrow walks nishings, such as bollards, post-and-chain that limit pedestrian circulation and park fences, and signs. Park standards are outdated and limited to grounds maintenance; conse- FIGURE 6: UNION SQUARE quently, service improvement opportunities are neglected.

Adequate access for vehicles was never de- signed, affecting deliveries, trash removal, and grounds maintenance. As a result, vehicles drive over curbs and damage resources, as well as make operations less efficient. Some operations, such as trash removal, can be mechanized to improve efficiencies. There are nearly 900 trash containers, and 3–4 tons of trash are removed daily and up to 32 tons during events, such as the Fourth of July. Even though eating and drinking Grade level changes at Union Square and deteriorated paving are prohibited at memorials, spills, stains, and make access difficult for visitors in wheelchairs.

27 PURPOSE OF AND NEED FOR THE PLAN

operations. The reflecting pool contains 2.5 FIGURE 7: THE SMITHSONIAN METRO STATION million gallons of potable water, but no cir- culation system, so the water becomes stag- nant every summer. The pool is drained

and cleaned twice a year. The Architect of the Capitol is responsible for roads sur- rounding Union Square, including permit

parking.

• The Mall (3rd to 14th Streets) — The Mall is the designed historic landscape that articu- lates the vision of the McMillan plan in

1901–02 and renowned landscape architect Frederick Law Olmsted Jr. in the 1930s. The rows of American elm trees define the The Smithsonian Metro stop has minimal facilities for visitors.

view between the Capitol and the Washing- ton Monument and are internationally rec- ognized. The shade provided by the mature elms is much appreciated by visitors during the hot, humid summer. Access to the Mall

for million of visitors is by way of the Smithsonian Metro station, the only one within the National Mall. In addition to

hosting millions of sightseers, the Mall is heavily used for demonstrations and per- mitted events. Resulting soil compaction affects the designed historic landscape and

the health of trees and turf, as well as the urban ecosystem. Poor water infiltration may contribute to urban flooding. The Mall There is an opportunity to improve information for visitors lacks restrooms (see appendix D); while getting off the Metro at the Smithsonian station. restrooms are available in adjacent museum buildings, these buildings have prescribed through a security check to use them. hours of operation, and visitors need to go Gravel-paved walkways make access diffi- cult for some visitors, and gravel migrates onto lawns. The former Adams and Wash- FIGURE 8: WASHINGTON MONUMENT TEMPORARY ington drives, which ran parallel to Jeffer- CONCESSION FACILITY son and Madison drives, were closed to traffic in 1975 and replaced with wide

graveled walkways over asphalt that run along the inner edges of the rows of Amer- ican elms.

The Washington Monument and Grounds

• Celebrations, demonstrations, special events, and recreational activities take place

on the monument’s grounds. The tempo- rary food and retail facility must be relo- cated to allow for construction of the Na- tional Museum of African American His- The temporary refreshment and retail facility for the Washing- tory and Culture on the northeast corner of ton Monument is at the future site of the National Museum of African American History and Culture. The tent cover was the grounds. Survey Lodge, the main visitor removed in 2010, while the underlying structure remains. contact station, is off the main circulation

28 Scope of this Document: Opportunities, Problems, and Challenges

routes and not easy to identify. Circular FIGURE 9: CONSTITUTION GARDENS LAKE restrooms near a tour bus drop off are out- dated and inadequate for demand. The north grounds are highly used for demon-

strations, permitted events, celebrations, civic activities, and recreation, but no infra- structure is provided. The south grounds

(south of Independence Avenue), which are cut off by park drives and roadways from both the monument and the Tidal Basin,

provide recreation fields.

• In 2003 a landscape plan was approved for the grounds of the Washington Monument. Constitution Gardens Lake has water quality problems from a This plan, developed by the Olin Partner- lack of adequate water recirculation. The original 1970s plan ship for the National Park Service, called included a restaurant at the east end of the lake. for planting hundreds of additional trees to improve the appearance and health of the • Vietnam Veterans Memorial — No oppor- grounds, as well as to provide shade, to tunities for contemplation are provided complement the revised circulation pattern, near the memorial. and to frame the grounds and reinforce viewsheds. The construction of the Na- • Lincoln Memorial and Grounds — Multiple tional Museum for African American His- tour bus arrivals cause peak-season crowd- tory and Culture and other ongoing or pro- ing, and restrooms are inadequate and fre- posed projects provide opportunities to quently overwhelmed by demand. Recently update this plan. opened north and south concession / re- freshment stands provide visitor services West Potomac Park (North of but no restrooms. Concentric rows of elm Independence Avenue) trees affect where facilities can be placed. The exhibit area and bookstore are • World War II Memorial — No large-scale outdated. changes are recommended other than increased education at the World War II Events on the lower approachway require Memorial. organizers to install temporary utilities and equipment. Issues related to the reflecting • Constitution Gardens — The gardens were pool, approachway, and elm walkways are designed as a resting area for people visiting being addressed under the American Re- the memorials. Poor quality soils have covery and Reinvestment Act of 2009. stunted tree growth, and the 7-acre con- crete-lined shallow lake contains 5.5 million The Watergate area is on the northwest gallons of potable water but no circulation edge of the National Mall, and it has been system, resulting in water quality problems. identified by the National Capital Planning Asphalt walks embedded with small stones Commission as a location for future na- are deteriorating and are difficult to tional memorials. This area is discussed in maintain. the Monumental Core Framework Plan: Connecting New Destinations with the Na- The historic Lockkeeper’s House, previ- tional Mall (NCPC 2009). This primary ve- ously moved to the corner of 17th Street hicular entrance to the city contains his- and Constitution Avenue NW, is not being toric features, volleyball courts, and ball- used and requires some preservation. Its fields. There are proposals by other agen- location near the intersection affects pedes- cies to rebuild and simplify the road system trian visibility and represents a possible and celebrate the Constitution Avenue threat to its preservation. belvedere.

29 PURPOSE OF AND NEED FOR THE PLAN

FIGURE 10: TIDAL BASIN WALKWAY function to the basin, but additional studies and improvements are needed.

The deteriorating Tidal Basin walls are overtopped in some areas by high tides, spilling onto walkways and resulting in

social trails as visitors try to avoid the water.

Walkways are too narrow for current levels of use, so the adjacent cherry tree root sys- tems are trampled by visitors. Paddleboats

are the only boating choice for recreation, seasonal refreshment and recreation equip- ment rental facilities are outdated, and no The walkway around the Tidal Basin is frequently flooded by restrooms are available with the exception high water. of those located at the Thomas Jefferson Memorial and the Franklin Delano Roose- • Korean War Veterans Memorial — Narrow velt Memorial. entry walks are frequently congested. Visi- • Franklin Delano Roosevelt Memorial — Visi- tor walking patterns have changed, and tors trample some planting areas to take there is no access from the east. photos or shortcuts. • D.C. War Memorial — This small events • West Potomac Park Riverfront — Dry-laid venue requires major preservation work, stone river walls are deteriorating and are which has been funded by the American overtopped by tidewater and debris. The Recovery and Reinvestment Act of 2009. National Capital Planning Commission’s Use of the area as a performance venue Extending the Legacy plan (1997) and the could be enhanced. Monumental Core Framework Plan (2009) • Ash Woods — Utilitarian wood fencing, both call for water taxis along the river. truck and horse trailer parking, and the of- • Thomas Jefferson Memorial — The plaza fice trailer at the U.S. Park Police mounted edge is uneven due to the shifting of the patrol facilities are not in keeping with the Tidal Basin seawalls in front of the memo- historic character of the National Mall. The rial, which is being addressed through the access road has become a popular pedes- American Recovery and Reinvestment Act trian route. The circular restrooms on Ash of 2009. Pedestrian access near the tour bus Road are outdated and hard to maintain; drop-off area has been controlled to pre- this facility is near the newer restrooms at the World War II Memorial. FIGURE 11: WEST POTOMAC PARK RIVERFRONT West Potomac Park (South of Independence Avenue)

• Tidal Basin Area — Local streets and park- ing bisect recreation areas. Commuter and recreational bicyclists share narrow side-

walks with much slower pedestrians.

The Tidal Basin was designed to help flush the Washington Channel to support naviga- tion. Over the last 100 years the flushing

capability has been reduced and the basin has silted in. The Tidal Basin gates were re- placed in 2007 to help restore the flushing Dry-laid stone riverwalls have deteriorated, and riprap is used is some areas to control erosion.

30 Scope of this Document: Environmental Impact Topics

FIGURE 12: NORTH PLAZA OF THE THOMAS JEFFERSON and they are the focus of the discussion of MEMORIAL cultural resource impacts.

• Historic properties consist of several types — memorials, buildings, sites, structures, objects (such as statues), and districts.

• Cultural landscapes are defined areas asso-

ciated with significant events, persons, design styles, or ways of life (such as a park or an estate).

Only properties listed on, or eligible for listing on, the National Register of Historic Places are

considered cultural resources for the purposes of this plan. Temporary paving repairs have been made on the north plaza to correct problems caused by the settling seawalls. Permanent repairs have been funded through the American Recovery and It was determined that archeological resources, Reinvestment Act of 2009 and are now underway. ethnographic resources, Indian Trust resources, and museum collections were dismissed from vent unwanted visitor paths to the Tidal further analysis, as explained below. Basin and the memorial. Walks near the Tidal Basin have been relocated so that they Natural Resources are not inundated daily by tides. Impacts on soils, water resources (including water quality and quantity, floodplains and ENVIRONMENTAL IMPACT TOPICS stormwater, and use of potable water), vegeta- tion, and fish and wildlife are analyzed in detail. This management plan develops a vision, or a Impacts on geology, paleontology, topography, shared understanding between NPS managers air quality, wetlands, special status species, and the public, about the kinds of resource soundscape, lightscape, climate change, agri- conditions, visitor experiences, and facilities that cultural lands / farmlands, and energy require- would best fulfill the purposes of the National ments were dismissed from further analysis, as Mall. Part of this process is the analysis of envi- explained beginning on page 34. ronmental impacts. This document identifies the types of impacts that would occur and where. Demonstrations, Special Events, and National Celebrations Impact topics were identified on the basis of federal laws, regulations, and executive orders; Impacts on First Amendment demonstrations, NPS Management Policies 2006; and NPS knowl- celebrations, and special events are analyzed. edge of limited or easily affected resources, as The analysis also considers opportunities to well as public input. A brief rationale for the participate in demonstrations and events, in- selection of each impact topic is given below. cluding knowledge about what is happening, where, and how to participate. The capacities of Impact Topics Analyzed in Detail various venues under each alternative are presented. Cultural Resources Impact topics were evaluated for archeological Access and Circulation resources, historic properties, cultural land- The analysis looks at (1) visitor access and circu- scapes, ethnographic resources, Indian Trust lation, including vehicle access, parking, and resources, and museum collections. It was deter- transit access (Metro system as well as taxis); (2) mined that historic properties (buildings, sites, the pedestrian environment , including pedes- structures, objects, districts) and cultural land- trian experiences on the National Mall and con- scapes could be affected by the implementation of the alternatives considered in this document,

31 PURPOSE OF AND NEED FOR THE PLAN nections to adjacent areas; (3) bicycle use; and no impacts or that the impacts would be negli- (4) motorized uses and the road system. gible to minor.

Visitor Use and Experience Cultural Resources Impacts are analyzed on a quality visitor experi- Archeological Resources ence, which is defined as one that would allow Archeological resources — the physical evidence visitors (1) to understand and be able to contem- of past human activity — can represent both pre- plate core American values, government, and historic and historic occupations. There is little democracy as symbolized by the National Mall’s potential for prehistoric sites to occur history and memorials, as well as the adjacent throughout most of the National Mall due to the cultural institutions; (2) to enjoy a welcoming fact that much of the area was created by the experience and the beauty of the National Mall, filling of Potomac River wetlands. In other areas both during the day and at night; and (3) to make any prehistoric resources would be so deeply emotional or intellectual connections to the buried as to be effectively inaccessible. There National Mall and what it represents. The im- may, however, be areas where prehistoric arch- pacts of opportunities for information and edu- eological sites remain intact, although minimal cation; for enjoyment, entertainment, and infor- archeological investigations have been mal recreation; and for active recreation are undertaken. evaluated. The impacts of visitor facilities and amenities on the visitor experience are also ana- The infill that created much of the National Mall lyzed. Finally impacts on public health and safe- may contain historic debris of archeological ty, plus user carrying capacities, are analyzed. interest. Historic archeological features likely remain at each of the monument and memorial Socioeconomic Environment sites. Examples might be the foundations of buildings that once existed on the Mall, road The analysis considers the impacts of increased traces, the remains of railroad structures and visitation; impacts on commercial business tracks, remnants of old landscape features, and opportunities, including commercial facilities canal structures. for recreation and food service, and the type and dispersal of facilities; the impacts of construc- While no complete survey or inventory of arch- tion opportunities on the local and regional eological resources on the National Mall has economy, and visitor costs if free parking is been attempted in accordance with section 110 converted to paid parking. of the National Historic Preservation Act of 1966, as amended, NPS policies and procedures Park Operations require a professional archeologist to evaluate Impacts on park conditions are evaluated in the possibility of such resources occurring be- terms of deferred maintenance projects, infra- fore any ground disturbance. Based on previous structure, permitted activities, and staffing. The archeological work, further testing or excavation aspect of efficient and safe operations looks at may or may not be necessary before ground permit processes for special events, the main- disturbance. As an additional precaution to tainability of mechanical systems, and best prac- avoid inadvertent destruction of archeological tices for operations that are used for maintaining resources and to expedite project planning, the high-use urban parks. Sustainability is consid- National Park Service will coordinate with the ered in terms of facility design, recycling, water D.C. Historic Preservation Office to more thor- use, renewable energy, and circulation (vehicle oughly identify areas where archeological moni- trips and congestion). toring and testing may be appropriate. Should unexpected archeological resources be discov- ered during the course of proposed work, NPS Impact Topics Dismissed from policy requires that all work be halted until a Further Consideration professional archeological evaluation of the find The following impact topics were considered, can be made, along with a determination of its but further analysis showed that there would be significance.

32 Scope of this Document: Environmental Impact Topics

The NPS regional archeologist of the National tural practices or beliefs of a living community Capital Region will determine the efficacy of a that are (1) rooted in that community’s history, complete archeological resource survey of the and (2) important in maintaining the continuing National Mall in accordance with the National cultural identity of the community (NPS 2006e). Historic Preservation Act and NPS policy. Until then, or in the absence of a complete archeolog- No ethnographic overview and assessment study ical inventory, these procedures should provide has been done for the National Mall to identify a level of protection for any archeological traditionally associated peoples; however, many resources that remain. park resources have significance to local Wash- ingtonians, veterans, and individuals or groups Because the National Park Service is required by who associate with the themes of the national law and policy to archeologically evaluate any memorials. An ethnographic overview and as- site proposed for development, and because this sessment could lead to a review of existing nom- plan does not entail actions that would affect inations to the National Register of Historic specific known archeological resources, this Places to determine if ethnographic data for topic has been dismissed from further traditional cultural property status should be consideration. included. Some resources have special associa- tions for specific groups of people. Veterans of Ethnographic Resources conflicts may associate with the World War II Memorial, Korean War Veterans Memorial, The NPS Management Policies 2006 define park Vietnam Veterans Memorial, or D.C. War ethnographic resources as “the cultural and Memorial. Asians may associate with the flower- natural features of a park that are of traditional ing cherry trees along the Tidal Basin, the significance to traditionally associated peoples” Japanese lantern, and the pagoda. The Lincoln (NPS 2006e). Traditionally associated peoples Memorial has associations for African Amer- may include contemporary park neighbors as icans owing to President Abraham Lincoln’s well as ethnic or occupational communities that emancipation of slaves, and events that have have been associated with what is now a park for occurred on its steps, such as Marian Anderson’s two or more generations (40 years), whose inter- 1939 concert and Martin Luther King Jr.’s 1963 ests in the park’s resources began before the “I Have a Dream” speech. No American Indian park’s establishment and whose cultural heritage tribes or sacred sites associated with the Na- and traditional way of life are involved. tional Mall have been identified. Traditionally associated peoples generally differ Even though an ethnographic overview and as a group from other park visitors in that they assessment have not been completed, prelimi- typically assign significance to ethnographic nary analysis indicates that this plan will not resources — places closely linked with their own affect those features that have the potential to be sense of purpose, existence as a community, and determined ethnographic resources. This plan development as ethnically distinctive peoples. does not propose any actions that would limit These places may be in urban or rural parks and access to any of the monuments, memorials, or support ceremonial activities or represent birth- other features, nor change their cultural mean- places of significant individuals, group origin ing to any group. All visitors will continue to sites, migration routes, or harvesting or collect- have access to and use of the monuments and ing places. Although these places have historic memorials as they do now. Permits for events or attributes that are of great importance to the ceremonies will continue to be issued or denied group, they may not necessarily have a direct under current rules and regulations. As a result, association with the reason the park was estab- this topic has been dismissed from further lished or be appropriate as a topic of general discussion. public interest. Some ethnographic resources might also be traditional cultural properties. A NPS Museum Collections traditional cultural property is one that is eligible for inclusion on the National Register of His- The museum collections of the National Mall toric Places because of its association with cul- and Memorial Parks contain both natural and

33 PURPOSE OF AND NEED FOR THE PLAN cultural objects. Collections of museum items Lin’s involvement in the design and construction are preserved either onsite or at the National of the monument, along with objects related to Capital Region Museum Resource Center. the Joel Meisner Foundry’s involvement in the design, construction, and installation of the The Lincoln Memorial collection is made up of Three Servicemen statue. The proposed new approximately 60 objects, only a few of which Vietnam Veterans Memorial Center will exhibit are actually on exhibit in the museum area, with many of the items in the collection, but the the rest at the Museum Resource Center. The majority will remain at the Museum Resource majority of these objects are related to the Center. construction of the memorial; the installation of the Daniel Chester French statue of Abraham Under all alternatives nearly all NPS museum Lincoln or the murals painted by Jules Guerin; objects will continue to be stored offsite at the objects related to individuals who participated in Museum Resource Center. A small number of the construction of the memorial, statue, or selected museum objects will be exhibited in murals (ca. 1911–22); and objects related to buildings outside the floodplain. In addition, architect Henry Bacon’s involvement in the museum objects will continue to be acquired, design and execution of the memorial. accessioned and cataloged, preserved, pro- tected, and made available for access and use The collection associated with the Washington according to NPS standards and guidelines (NPS Monument is made up of objects related to (1) 2000b). Therefore, museum objects would not the planning, design, and construction of the be affected under any alternative, and this topic monument, including involvement by the Wash- has been dismissed from further consideration. ington Monument Society, the Army Corps of Engineers, and architect Robert Mills, (2) indi- Indian Trust Resources viduals who participated in the construction, and (3) the design, production, and installation The Department of the Interior is responsible of the 191 memorial stones that are set in the for protecting Indian trust resources, including interior walls of the monument. All of these tribal lands, assets, resources, and treaty rights, objects are housed at the Museum Resource that are held in trust by the Secretary of the Center. Interior for the benefit of American Indians due solely to their status as American Indians. There One object from the small Thomas Jefferson are no Indian trust resources on the National Memorial collection is on display at the memo- Mall. Therefore, this topic was dismissed from rial; the rest of this collection is housed at the further impact analysis. Museum Resource Center. Natural Resources The Vietnam Veterans Memorial collection is international in scope and is comprised of more Geology, Paleontology, and Topography than 100,000 objects that have been left at the The District of Columbia lies on the line be- memorial wall. The collection includes objects tween the Atlantic Coastal Plain physiographic directly related to (1) military activities (dog tags, province on the southeast and the Piedmont patches, uniforms and military clothing, combat province on the northwest. This line roughly boots, C rations, discharge papers, photographs, follows . The National Mall lies and medals); (2) framed and unframed materials in the Atlantic Coastal Plain. (letters, poems, birth announcements, birthday cards, personal dedications, newspaper obitu- The Atlantic Coastal Plain province borders the aries, books, Bibles, family photographs, and Atlantic Ocean and consists of gravel, sand, silt, Vietnam snapshots); and (3) patriotic-to-protest clay, and marl. Deposition of these sediments objects (artificial flowers and wreaths, flags, began 100 million years ago and continues to the missing-in-action and prisoner-of-war bracelets, present time. The oldest rocks in the Coastal clothing, canes, high school diplomas, records Plain are poorly consolidated (i.e., easily and tapes, teddy bears, liquor bottles, beer cans, crumbled) gravel, sand, silt, and clay derived and cigarette lighters). The collection also in- from the weathering of rocks to the north and cludes objects related to designer Maya Ying

34 Scope of this Document: Environmental Impact Topics west that were carried to the Coastal Plain by While the action alternatives include construc- south-flowing rivers. Younger rocks consist of tion and landscape management actions, they sands and clays containing the minerals glauco- would occur in previously disturbed areas. nite and mica, which were deposited in estuaries Because no alternatives presented in this docu- and on the Continental Shelf at a time when ment include any actions of the scale or type that water covered the present Coastal Plain to would affect geologic formation, paleontology, depths of as much as 200 feet (USGS 1999). or general topography of the area, these topics were dismissed from further analysis. The Piedmont Plateau province lies west of the Coastal Plain. Piedmont rocks in and near Air Quality Washington, D.C., are crystalline metamorphic rocks that are quite hard and resist weathering; The planning area is within the National Capital they contain veins of quartz and pegmatite, and Interstate Air Quality Control Region. While the in many places have been intruded by igneous District of Columbia region has been designated rock. These crystalline rocks can be seen most by the Environmental Protect Agency as a “seri- easily in valleys where the soil cover has been ous non-attainment area” for fine particulate stripped away by erosion. Most of the crystalline matter, it meets the national ambient air quality rocks on the uplands were deposited about 550– standards for other air pollutants. 600 million years ago. Over the ages, they have weathered to saprolite, a porous, spongy, red- The General Conformity Rule of the Clean Air brown clay-rich material, as much as 200 feet Act Amendment of 1990 requires any federal thick (USGS 1999). agency responsible for an action in a non- attainment area to determine that the action is From a surface geology standpoint, most of the either exempt from the conformity rule re- study area is identified as disturbed ground and quirements or that the action conforms to the artificial fill. The southern part of the National applicable state implementation plan. The Mall is low level Pleistocene-era fluvial and es- conformity assessment process is intended to tuarine deposits and was originally swampland. ensure that federal agency actions (1) will not It was reclaimed in the late 1800s by fill with cause or contribute to new violations of the material dredged from farther down the river. national ambient air quality standards; (2) will not increase the frequency or severity of any The National Mall includes numerous structures existing violations of national ambient air quality built from fossil-bearing rock, such as sand- standards; and (3) will not delay the timely stone, limestone, and marble (metamorphosed attainment of ambient air quality standards. An limestone) from quarries throughout the coun- agency may establish that the projected emission try. For example, Indiana limestone (Mississip- rates would be less than specified emission rate pian-age Salem limestone quarried near Bed- thresholds, known as de minimis thresholds. If ford, Indiana) is highly fossiliferous. Marine these conditions are met, conformity of a project invertebrate fossils are readily visible in the is presumed. Indiana limestone used in many structures, such as the Capitol Reflecting Pool. The Lincoln Me- The problem of urban pollution and acid precip- morial and other NPS-managed structures also itation (often called acid rain) is of increasing contain fossils in their building stone (NPS concern in the Washington metropolitan area. 2004c). Pure, distilled water has a neutral pH of 7. Nor- mal, unpolluted rain is slightly acid, with a pH of Central Washington and the National Mall and 5.6, because the carbon dioxide in air combines Memorial Parks are on a series of terraces that with water to form small amounts of a weak acid increase in elevation from the Potomac River. called carbonic acid. Rainfall in the Washington The majority of this area reflects the pressures of area has an average pH of 4.2 to 4.4, more than urban density and growth. The original land- 10 times as acidic as unpolluted rain (USGS form has been highly manipulated to create 2007). The main source of pollution in the great- appropriate settings for government buildings er Washington region is exhaust from automo- and memorials. biles, trucks, and other forms of transportation.

35 PURPOSE OF AND NEED FOR THE PLAN

Vehicle exhaust contains nitrogen oxides and One of the goals of the preferred alternative and sulfur dioxide, which combine with water to alternative C is to reduce the park’s current out- form strong acids. put of greenhouse gases by 18% by 2012, which would be a long-term beneficial effect. The stones that form many of the buildings and monuments in Washington are limestone and These actions would result in short- and long- marble, which are vulnerable to acid precipita- term, negligible, adverse impacts on local air tion because they are predominantly made of the quality. Because no moderate or major impacts mineral calcite (calcium carbonate), which dis- are anticipated from any of the potential actions solves easily in acid. in this plan, the topic of air quality has been dismissed from further analysis. Should any of the action alternatives be selected, local air quality may be temporarily affected by Wetlands construction-related activities. The operation of construction equipment would result in in- Most of the southern and western portions of creased vehicle emissions in a localized area. the National Mall were low-lying swampy Volatile organic compounds, nitrogen com- wetlands in the late 1800s. The swamp was later pounds, carbon monoxide, and sulfur dioxide drained and/or filled in to create the landscape emissions would be generated but would dis- seen today. Photographs and maps from the perse fairly quickly from the construction area. 1870s through the early 1900s show the small This degradation would last only as long as con- Babcock Lake near the original Tiber Creek, and struction activities occurred and would most a carp pond near the Washington Monument likely have a negligible effect on regional pollu- (Milner Associates 2003). These were filled in by tant levels. Fugitive dust from construction 1923. could intermittently increase airborne particu- late concentrations in the area near the project Currently, wetlands are present in or along the site, but standard mitigating measures, such as Tidal Basin, the Washington Channel, and wetting the disturbed soil, would be used to Potomac River. The National Wetlands reduce potential adverse effects to a negligible Inventory categorizes the Tidal Basin as a level. One or more of the alternatives could lacustrine unvegetated wetland and the result in a slight increase in visitation, with a Constitution Gardens Lake as a freshwater corresponding increase in vehicle emissions. pond/palustrine wetland (USFWS 1998). The adverse impacts of this would be reduced as Wetland habitat supports terrestrial and aquatic national vehicle emission and fuel-economy invertebrates, fish, waterfowl, reptiles, and standards are revised. amphibians. Uncontrolled growth of blue-green As mentioned above, the single main source of algae and some filamentous algae can reduce the pollution in the greater District of Columbia ability of water to support fish. metropolitan area is vehicle exhaust. The Federal and state partners of the Chesapeake percentage of total vehicles in the metropolitan Bay Program have adopted an interim goal of no area that are directly related to visiting the overall net loss of the drainage basin’s remaining National Mall is quite small during most of the wetlands and a long-term goal of increasing the year (non-summer months). quality and quantity of the basin’s wetlands Alternative B proposes adding underground resource base. Under the preferred alternative vehicle parking garages. An increase in vehicles and alternative C, naturalized riverbanks would and their emissions in the core of the planning be established in some areas along the Potomac area would have adverse impacts on air quality. River frontage where existing river walls have However, even if 1,000 parking spaces were deteriorated. These could become small wetland added, this would be less than a 1% increase in strips along the river. Constitution Gardens total spaces in the vicinity of the Mall (currently Lake would be maintained as a sustainable water around 400,000). With mitigating factors such as body capable of supporting fish. These actions more efficient vehicle standards, this impact is would result in long-term, minor, beneficial expected to be minor. impacts to wetlands.

36 Scope of this Document: Environmental Impact Topics

Under alternative B Constitution Gardens Lake Potomac River but, as a result of the Atlantic would be reconstructed so that it could be Sturgeon Reward Program established in 1996 drained for use during public events. This would by the U.S. Fish and Wildlife Service, the first result in the loss of an artificial wetland habitat, a shortnose sturgeon since 1899 was found in the long-term, negligible, adverse impact. Also river. To date, 10 shortnose sturgeons have been under alternative B the Capitol Reflecting Pool documented from the Potomac (Minkkinen, would be removed, but this feature provides pers. comm. 2007). Two females were telemetry- only a very small habitat need for some water- tagged, one in 2005 and another in 2006, in an fowl, so the loss would be negligible. There effort to study their movements. Study results would be no other impacts to wetlands. were included in an annual report dated March 21, 2007. Because there would be no moderate or greater impacts, this topic has been dismissed from It is unlikely that shortnose sturgeon would be further analysis. present in the Tidal Basin because of warm water temperatures and their preference for Special Status Species using deep channels and a variety of mixed or hard (non-mud) foraging substrates. However, Except for occasional transient individuals, no there is always the possibility that an individual proposed or federally listed endangered or could wander into the basin. Therefore, any threatened species are known to exist within the planned modifications to the substrate in the planning area (USFWS letter, Sept. 18, 2007). basin should follow NEPA compliance pro- A federally endangered species, the shortnose cedures and address the possibility of an adverse sturgeon (Acipenser brevirostrum), has recently impact on this endangered species. While Wash- been found in the Potomac River as far north as ington, D.C., maintains water control into the Little Falls (USFWS 2009). This large (up to 3 basin, the National Park Service should exercise feet) native fish occurs mainly in rivers along the vigilance for any actions that could degrade Atlantic coastline from southeastern Canada to water quality. Florida but may venture into saltwater. Short- Under the action alternatives the subsiding Tidal nose sturgeons reportedly prefer deep pools Basin seawalls would be rebuilt, and under the with mixed or hard substrates and vegetated preferred alternative and alternatives B and C bottoms, but individuals may vary in preference the walkways atop the walls would be widened. for various water depths and substrate types. Widening the walkways could require moving They eat mollusks, crustaceans, worms, and the basin walls into the basin, resulting in the aquatic insects. loss of about 5 acres of warm, shallow water The current potential for the sturgeon to spawn habitat. However, since the Tidal Basin is arti- within this area is of major interest because of ficial, the long-term impacts of this would be the federally endangered status of the species adverse but negligible. Construction would and the federally mandated responsibility of the result in short-term, negligible, adverse impacts National Park Service to protect and enhance because of habitat disturbance and sedimenta- endangered species. Principal responsibility for tion. Since it is unlikely that the shortnose the sturgeon rests with the National Oceanic and sturgeon inhabits the basin, construction-related Atmospheric Administration’s Fisheries Service. impacts would be unlikely to adversely affect The National Park Service is responsible for this species. Other actions would have no effect managing the bed of the Potomac River within on listed species or their habitat because they are the District of Columbia where the shortnose not known to inhabit the planning area. sturgeon could potentially spawn. Species identified by the D.C. Department of the The shortnose sturgeon was placed on the Environment as those in greatest need of conser- original endangered species list on March 11, vation are listed in Table 2. 1967 (32 FR 4001) due to the damming of rivers Bald eagles have been observed using the project and over-harvesting throughout its range. The area. Many black-crowned night herons are seen fish was considered extirpated from the in the park, including Constitution Gardens

37 PURPOSE OF AND NEED FOR THE PLAN

TABLE 2: SPECIES OF GREATEST CONSERVATION NEED, human-caused sound considered acceptable WASHINGTON, D.C. vary among national park system units, as well as Common Name Scientific Name potentially throughout each park unit, being Bald eagle Haliaeetus leucocephalus generally greater in developed areas and less in Black-crowned night heron Nictocorax nictocorax undeveloped areas. Scarlet tanager Prianga olivacea Wood thrush Hylocichla mustelina The National Mall is in a highly urbanized area, SOURCE: D.C. Department of the Environment, electronic letter, August 27, 2007. where the protection of a natural ambient soundscape and/or opportunities for visitors to Lake. Scarlet tanagers and wood thrushes have experience natural sound environments is not an been seen in the vicinity of the National Mall. objective of the park. Visitors would not come to Both birds are migratory and have been re- the park to seek the quiet, intermittent sounds of corded as breeding in the area (DC 2007). No nature. nesting sites for either species are known within Any construction associated with the implemen- the study area. tation of the selected alternative, e.g., the hauling Under the preferred alternative and alternative of material or the operation of construction C portions of the wall along the Potomac River equipment, could result in dissonant sounds, but would be removed and replaced with native such sounds would be temporary and not out- materials to create more natural riparian areas. of-place in an urban setting. Because protection This would result in a long-term, negligible, of a natural ambient soundscape and/or oppor- beneficial impact for special status species with tunities for visitors to experience natural sound riparian habitat needs, such as the D.C. listed environments is not an objective of the park, black-crowned night heron. soundscape management was dismissed as an impact topic. Implementing the no-action alternative would have no effect on special status species. The Lightscape Management action alternatives could affect, but would be In accordance with NPS Management Policies unlikely to adversely affect, the federally listed 2006, the National Park Service strives to pre- shortnose sturgeon. They would result in serve natural ambient landscapes, which are negligible beneficial impacts to the D.C. listed natural resources and values that exist in the black-crowned night heron. Because there absence of human-caused light. would be no moderate or greater impacts and no adverse effects to special status species, this Due to its highly urbanized setting, the preser- topic has been dismissed from further analysis. vation of natural ambient landscapes is not an objective at the National Mall. The night sky in Soundscape Management Washington, D.C., is dominated by lighting of In accordance with NPS Management Policies five symbolic icons — the U.S. Capitol, the 2006 and Director’s Order #47, Sound Preserva- White House, the Washington Monument, the tion and Noise Management, an important part of Lincoln Memorial, and the Thomas Jefferson the National Park Service mission is the preser- Memorial. Other public and private buildings, vation of natural soundscapes associated with memorials, public art, streets and walks, and national park system units. Natural soundscapes park areas are lit to varying degrees. exist in the absence of human-caused sound. Under the action alternatives the National Park The natural ambient soundscape is the aggregate Service would work closely with the Commis- of all the natural sounds that occur in park units, sion of Fine Arts, the National Capital Planning together with the physical capacity for trans- Commission, the Architect of the Capitol, the mitting natural sounds. Natural sounds occur Smithsonian Institution, and D.C. city agencies within and beyond the range of sounds that to reestablish the lighting task force to develop humans can perceive and can be transmitted an approved, written comprehensive lighting through air, water, or solid materials. The guideline for the monumental core that would frequencies, magnitudes, and durations of address protection to maintain dominant light-

38 Scope of this Document: Environmental Impact Topics ing of the five symbolic icons, desired lighting national park system has ever faced (NPCA character for urban and park areas, appropriate 2007). Climate change in this context refers to a light levels and color for different areas, and suite of changes occurring in Earth’s atmos- light pollution / protection of night sky from pheric, hydrologic, and oceanic systems. These excessive, horizontal light pollution. Any im- changes, including increased global air and pacts of a lighting guideline would be beneficial, ocean temperatures, widespread melting of and lightscape management was dismissed as an snow and ice, and rising average sea level, impact topic. provide unequivocal evidence that the climate system is warming. While the warming trend, Agricultural Lands, Prime and Unique commonly referred to as global warming, is Farmlands discernible over the entire past century and a half, recent decades have exhibited an accel- No soils known in the planning area are regu- erated warming rate, with 11 of the last 12 years lated under the Federal Farmland Protection ranking among the 12 warmest years on record. Policy Act. Additionally, no soils are identified as prime farmland, unique farmland, farmland of While climate change is a global phenomenon, it statewide importance, or hydric soils by the manifests itself differently in different places. Natural Resources Conservation Service. None One of the most dramatic effects is the impact of the alternatives would affect agricultural lands on sea level. A rise in sea level could affect na- or prime and unique farmlands as defined by the tural and cultural resources, and it would likely Natural Resource Conservation Service, so these interfere with public use and enjoyment of parks resources have been dismissed from analysis. in low-lying coastal areas. Although many places in the world have already observed and re- Energy Requirements and Conservation corded changes that can be attributed to climate Potential change, the impacts on the National Mall have not been specifically determined. Climate Implementing any of the action alternatives change is a long-term phenomenon, and the would result in new facilities requiring energy likelihood that significant effects will be seen use. The National Park Service has adopted the during the life of this plan (50 years) is fairly concept of sustainable design as a guiding princi- certain. Some models predict a sea level rise of ple of facility planning and development (NPS 15 to 37 inches in the Chesapeake Bay region. Management Policies 2006, sec. 9.1.1.6). The ob- jectives of sustainability are to design facilities to Climate change and the response of govern- minimize adverse effects on natural and cultural mental agencies are guided by the following values, to reflect their environmental setting, and regulations and policies: to require the least amount of nonrenewable fuels or energy. All NPS facility development • Executive Order 13423, “Strengthening must include improvements in energy efficiency Federal Environmental, Energy, and Trans- and reduction in greenhouse gas emissions. In all portation Management” (issued January 24, the action alternatives new and reused facilities 2007), requires federal agencies to “conduct would be designed with long-term sustainability their environmental, transportation, and in mind. energy-related activities under the law in support of their respective missions in an Action alternatives could result in changed ener- environmentally, economically, and fiscally gy needs, but this change is expected to be negli- sound, integrated, continuously improving, gible when seen in a regional context. Thus, this efficient, and sustainable manner.” It in- topic has been dismissed from further analysis. cludes requirements for the reduction of greenhouse gases and implementation of Climate Change other energy and water conservation mea- sures. The order requires agencies to re- Related to the energy use discussion is climate duce greenhouse gas emissions by 3% change, the human-caused change to global annually through the end of fiscal year climate patterns. Climate change is perhaps the 2015, or 30% by the end of fiscal year 2015, most far-reaching and irreversible threat the

39 PURPOSE OF AND NEED FOR THE PLAN

relative to the baseline of the agency’s public would receive educational messages energy use in fiscal year 2003. about reducing our impact on the climate. These • DOI Secretarial Order 3226 (issued January programs and others would be implemented 19, 2001) ensures that climate change im- under all alternatives and would contribute to pacts are taken into account in connection national and international efforts to decrease the with departmental planning and decision effects of human-caused climate change. making. Over the life of this plan, it is anticipated that • NPS Management Policies 2006 state that national emission-reduction efforts and new “the Service will use all available authorities technologies will become available that would to protect park resources and values from decrease the overall output of greenhouse gases potentially harmful activities. . . . NPS and other pollutants from motor vehicles. managers must always seek ways to avoid, or minimize to the greatest degree possible, Implementation of the preferred alternative adverse impacts on park resources and could slightly increase total visitation to the values” (NPS 2006e, sec. 4.7.2). park. If all of these visitors arrived by private vehicle, this would result in a corresponding The policies also discuss sustainable energy increase in vehicle emissions. Therefore, the design, requiring any facility development consequences of implementing this plan would to include improvements in energy effici- be long-term, negligible, and adverse to climate ency and reduction in greenhouse gas change. Because there would be no impacts that emissions for both the building envelope would be moderate or higher in intensity, this and the mechanical systems that support topic was dismissed from further analysis. the facility (NPS 2006e, sec. 9.1.1.6). Addi- tionally, projects that include major visitor Natural or Depletable Resource Require- services facilities must incorporate Leader- ments and Conservation Potential ship in Energy and Environmental Design (LEED) standards to achieve a silver rating. Consideration of these topics is required by the Council on Environmental Quality’s NEPA The National Park Service will interpret for regulations (40 CFR 1502.16). The National Park the public the overall resource protection Service has adopted the concept of sustainable benefits from the efficient use of energy, design as a guiding principle of facility planning and will actively educate and motivate park and development (NPS 2006e, sec. 9.1.1.6). The personnel and visitors to use sustainable objectives of sustainability are to design facilities practices in conserving energy (NPS 2006e, to minimize adverse effects on natural and cul- sec. 9.1.7). tural values; to reflect their environmental Implementing any of the alternatives described setting and to maintain and encourage biodi- in this plan would have very little effect on the versity; to operate and maintain facilities to cumulative level of greenhouse gas emissions or promote their sustainability; and to illustrate and other climate change factors (e.g., the carbon promote conservation principles and practices footprint) in the District of Columbia. However, through sustainable design and ecologically the National Park Service is considering several sensitive use. Essentially, sustainability is the management directions to reduce the park’s concept of living within the environment with contribution to climate change factors. Exam- the least impact on the environment. ples include replacing the current fleet of vehi- cles and motorized equipment with more fuel- The planning area is an urban setting. Through efficient or alternate fuel models, adding insula- sustainable design concepts and other resource tion and weather-proofing to existing buildings, management principles, no alternative analyzed and using solar panels to generate electricity. in this document would result in an appreciable New construction, such as restrooms and food loss of natural or depletable resources. Thus, service buildings under the preferred alternative, this topic was dismissed from further analysis. would be constructed to be energy efficient and sustainable. As part of an NPS initiative, the

40 Scope of this Document: Environmental Impact Topics

Visitor Experience: Commercially Washington Monument temporary security Provided Opportunities screening will be removed and replaced by an approved replacement screening approach. A No alternative would affect commercial pro- goal of all security is to minimize the visual im- viders, sightseeing buses, or commercial guides pact of security elements so they do not detract that offer tours or guided walks on the National from the open character that defines the desired Mall. Financial transactions would continue to experience. There would be no change as a be made off park land. Therefore, this topic was result of the plan; therefore, this topic was dismissed from further analysis. dismissed from further analysis. Park Operations Environmental Justice Operational Partnerships Executive Order 12898 requires all federal agen- The National Park Service has several opera- cies to incorporate environmental justice into tional partnerships for bookstores, programs, their missions by identifying and addressing specific memorials, fundraising, law enforce- disproportionately high and adverse human ment, recreation, and national celebrations or health or environmental effects of their pro- televised concerts. The Park Service maintains grams and policies on minorities and low-in- recreation fields that are permitted through the come populations and communities. D.C. Department of Parks and Recreation. Under every alternative partnerships would The Washington, D.C., metropolitan area con- continue and would not change as a result of a tains both minority and low-income populations; National Mall management plan. Agreements however, environmental justice is dismissed as an would be updated as needed. Therefore, this impact topic for the following reasons: topic was dismissed from further analysis. • The park staff and planning team actively solicited public participation as part of the Shared Infrastructure and Jurisdiction planning process and gave equal consid- eration to all input from persons regardless There are areas of shared infrastructure such as of age, race, income status, or other city-provided utilities (power, water, sewer) and socioeconomic or demographic factors. GSA steamlines. Issues related to overlapping jurisdiction include roads, signs, and traffic • Implementation of any alternative would signals. Any future actions by others would not result in any identifiable adverse human undergo collaborative planning, reviews, and health effects. Therefore, there would be no approvals to ensure that the actions were bene- direct or indirect adverse effects on any ficial to all parties. Sustainability and efficient minority or low-income population. park operations would be included in the collab- • The impacts associated with implementa- orative process. As a result, any infrastructure tion of any of the alternatives would not upgrades or jurisdictional revisions would not disproportionately affect any minority or change as a result of the plan. Therefore, no low-income population or community. further analysis was conducted. • Implementation of any of the alternatives would not result in any identified effects Perimeter Security that would be specific to any minority or Common to every alternative would be the in- low-income community. stallation of authorized and funded perimeter • The impacts to the socioeconomic environ- security for the Thomas Jefferson Memorial and ment resulting from implementation of any the Martin Luther King, Jr. Memorial, as well as of the action alternatives would be predom- the adjacent Smithsonian Institution museums, inantly beneficial. In addition, the park staff the National Gallery of Art, and federal build- and planning team do not anticipate the ings such as the Department of Agriculture. Any impacts on the socioeconomic environment perimeter security improvements would under- to appreciably alter the physical and social go review by the National Capital Planning structure of nearby communities. Commission and Commission of Fine Arts. The

41

INTERRELATIONSHIPS WITH OTHER PLANS AND PROJECTS

Planning by the National Park Service for the context, and workplace and visitor needs and National Mall takes place within an urban issues. framework of roads, buildings, and open space (see Urban Design Framework map). Washing- Planning for the design of Union Square would ton, D.C., is an outgrowth of the L’Enfant and be coordinated with the Architect of the Capitol McMillan plans, and early in the 20th century and could also consider design implications re- Congress created the United States Commission lated to the U.S. Senate Youth Park and U.S. of Fine Arts and the National Capital Planning Botanic Garden Education and Outreach Center Commission to protect the visions of these to the north, as well as the parking function with- visionary plans. Since 1933 the National Park in the rights-of-way of Maryland and Pennsyl- Service has been responsible for managing vania avenues between 1st and 3rd streets. federal park lands in Washington, D.C. NATIONAL CAPITAL PLANNING Planning for the National Mall is integrally tied to other comprehensive or cooperative planning COMMISSION efforts in the District of Columbia. These inter- In the 1920s the National Capital Park and Plan- related efforts are summarized below, and ning Commission (renamed the National Capital specific plans and projects are also considered in Planning Commission in 1952) hired Frederick the cumulative impacts analysis in the “Envi- Law Olmsted Jr., an original member of the Mc- ronmental Consequences” portion of this docu- Millan Commission, to prepare plans to imple- ment. ment the McMillan plan. Some of his resulting Planning and compliance for the Vietnam plans addressed the entire area, such as an illus- Veterans Memorial Center, the Dr. Martin trative master plan from 1939 that delineated a Luther King, Jr. Memorial, and the National somewhat simplified vision of the McMillan plan. Museum of African American History and The Olmsted Jr. plans were implemented in Culture is ongoing by each sponsor. The Na- Union Square and the Mall. His work at Union tional Park Service is assisting in the planning Square was changed in the 1970s by the “Wash- and compliance efforts for each of these projects, ington Mall Plan” (Skidmore, Owings and Merrill and opportunities for public involvement are 1973), but his design on the Mall retains great being provided through the NEPA and NHPA integrity. compliance processes. In 1997 the National Capital Planning Commis- sion prepared Extending the Legacy, which laid ARCHITECT OF THE CAPITOL the groundwork for Congress to amend the Commemorative Works Act in 2003 to strength- The Architect of the Capitol’s Capitol Complex en and clarify the act’s purpose and to designate Master Plan is an update of the 1981 U.S. Capitol the Reserve area. The Legacy plan provides an Master Plan, which aligned with the 1970s NPS overarching vision for the nation’s capital that plans for the Mall. The revised plan addresses builds on the principles of the L’Enfant and areas east of the National Mall, including the McMillan plans and is their successor. It calls for Capitol, the U.S. Supreme Court, the U.S. Bo- re-centering the city on the U.S. Capitol by tanic Garden, and the Library of Congress. The mixing public and private uses and extending plan is a long-range vision, master plan, and new public buildings, memorials, and museums implementation strategy for the maintenance, into all quadrants of the city. renovation, and improvement of the Capitol complex over the next 20 years. The planning The 2001 Memorials and Museums Master Plan principles address stewardship, urban form and identifies more than 100 sites in Washington, D.C., for future commemorative works and cul-

42 Interrelationships with Other Plans and Projects: National Capital Planning Commission tural attractions, recognizing that the Reserve missing. It also includes additional topics not does not contain sufficient space to keep pace covered in a master plan as defined by the with our nation’s evolving history and the need National Capital Planning Commission. to commemorate its culture, heroes, and history in the future. Five of these sites have been se- The Monumental Core Framework Plan: Con- lected for new memorials, including the U.S. Air necting New Destinations with the National Mall is Force Memorial and the Dwight D. Eisenhower a joint effort of the National Capital Planning Memorial. Commission and the U.S. Commission of Fine Arts (NCPC 2009). It advances the vision articu- The Comprehensive Plan for the National Capital: lated in the Legacy plan by focusing on the areas Federal Elements creates a planning framework immediately adjacent to the National Mall. connected by the following guiding principles: Through more detailed planning, it identifies (1) accommodate federal and national activities, opportunities to transform the architectural (2) reinforce smart growth and sustainable de- monumentality of the core to more contextual velopment and planning principles, and (3) sup- place-making. The Framework Plan lays out a port local and regional planning and develop- series of proposals to integrate the civic qualities ment objectives (NCPC 2004a). Visitor elements, of the National Mall with the vitality of the city transportation, and open space goals are com- to create new destinations that will be prestigious patible with the National Mall plan. locations for future cultural attractions, distin- guished settings for government offices, and The Comprehensive Plan also called for an up- inviting places to enrich the experience of people dated master plan for the National Mall. This who live, work, or visit here. Water taxi service Final Plan / Environmental Impact Statement with transfers to other transit modes is included, presents the National Park Service’s vision for as it was in the 1997 Legacy plan. the National Mall, something that has been

Monumental Core Framework Plan Opportunities

43 PURPOSE OF AND NEED FOR THE PLAN

Related to access and circulation, a long-term SMITHSONIAN INSTITUTION vision in the Framework Plan is to (1) relocate and consolidate the I-395/14th Street bridges The Smithsonian Institution’s Arts and Indus- (the George Mason, Rochambeau, Arland D. tries Building, which is just south of the Mall, has Williams Jr., Metro, and railroad bridges) to the been suggested as a visitor or welcome center for south to create additional gathering space the National Mall. The building is outside the southeast of the Thomas Jefferson Memorial, (2) Reserve, where visitor centers are prohibited. develop a new Metro station near the Thomas The Smithsonian Institution has stated that they Jefferson Memorial, (3) provide new Metro believe visitors could be well served by coordi- station entries at 7th Street and Constitution nated and combined information. The building Avenue NW, (4) add midblock crossings on has large open exhibit halls, natural daylight, and Constitution Avenue, and (5) redesign roads is close to two subway stops. The Smithsonian north of Constitution Avenue and west of 23rd Institution has begun repair and preservation Street NW to improve pedestrian access and work at the Arts and Industries Building, which connections to neighborhoods and the Kennedy has been funded by the American Recovery and Center. The Framework Plan focuses on this area Reinvestment Act of 2009. The ultimate use and and recommends minimizing above-grade treatment of the building is yet to be determined. infrastructure and establishing: (1) a symbolic, visual, and physical connection between the On May 8, 2008, the National Museum of Amer- Kennedy Center and the Lincoln Memorial; (2) ican Latino Community Commission Act was commemorative and recreation space and signed into law (PL 110-229). The Hispanic improved pedestrian and bicyclist paths along caucus has asked that no permanent decision on the waterfront; and (3) an extension of Consti- the Arts and Industries Building be made until tution Avenue to the historic belvedere. The the commission has assessed it as a possible National Park Service supports this vision. location for a new National Museum of the On April 2, 2009, the Framework Plan was American Latino. approved (NCPC 2009). The National Mall Under all alternatives the National Park Service planning effort has been coordinated with the will track progress on the future of this historic development of the Framework Plan. building and provide comment as needed. Any proposals affecting the National Park Service will DISTRICT OF COLUMBIA be fully analyzed to determine their value, finan- cial implications, and operational impacts. The District of Columbia’s City Center Action Agenda 2008 identifies challenges and actions needed to ensure the vitality and vibrancy of NPS PLANNING EFFORTS central Washington. It recognizes the great op- portunity to develop well-connected and distinct Visitor Transportation Study areas in a rapidly expanding downtown area that The National Park Service prepared an Environ- now has the National Mall as its centerpiece. The mental Assessment for a Visitor Transportation plan advances Washington’s identity as a water- Study for the National Mall and Surrounding Park front city, and it recommends investment in key Areas in 2006. A “Finding of No Significant Im- places, corridors, and transit to ensure economic pact” for the Visitor Transportation Study was vitality, sustainability, and cultural diversity signed February 5, 2010, completing the planning (District of Columbia 2008). The plan identified effort. Park staff have begun discussions with the 4th, 7th, and 14th streets as priority corridors for city and public transportation providers about crossing the Mall; 10th Street would be restored potential partnerships. The study recommends a north of the National History Museum. Addi- convenient visitor transportation service that will tionally, the NCPC Framework Plan proposes help protect park resources and ensure high- pedestrian improvements along 12th, 14th, 15th, quality visitor experiences by offering a and 17th streets, as well as west of 17th Street. sustainable, educational, integrated, and afford- able transportation network for park visitors (NPS 2006c). The service will replace the existing

44 Interrelationships with Other Plans and Projects: NPS Planning Efforts

Urban Design Framework

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PURPOSE OF AND NEED FOR THE PLAN

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46 Interrelationships with Other Plans and Projects: NPS Planning Efforts educational hop-on / -off service known as The White House and President’s Tourmobile. The plan proposes an integrated, Park easy-to-use system with basic orientation and a choice of additional educational / interpretive The goal of the Comprehensive Design Plan for services. the White House and President’s Park (NPS 2000a) is to improve the efficient functioning of The proposed service includes: the Office of the President, to preserve and en- • a two-way National Mall route and an addi- hance the symbolic and historic character of the tional one-way loop linking the memorial site, and to improve the experience of the Amer- core area to downtown ican public and all visitors who come to the house, the grounds, and the surrounding Presi- • a one-way loop serving Arlington Cemetery, dent’s Park. The plan emphasizes a pedestrian- with extensions to the U.S. Marine Corps oriented experience within President’s Park, and (Iwo Jima) Memorial; future extensions are the White House Visitor Center in the Com- also proposed to the U.S. Air Force Memo- merce Building would be expanded. Any actions rial and the U.S. Department of Defense taken under a National Mall plan would comple- September 11th Memorial ment the Comprehensive Design Plan for the These proposals could be compatible with exist- White House and President’s Park. ing transit, such as the Metrobus Circulator. The Design Guidelines for the White House and Free parking provided by the National Park President’s Park (NPS 1997) provide a frame- Service in the vicinity of the National Mall would work of mutually agreed upon tenets that guide, be changed to metered parking, and routes but do not dictate, future designs. The White would be designated for the recreational use of House and President’s Park will continue to Segway® HTs and electric scooters. exhibit a sense of unity and to be an integral element of the urban fabric, with a direct con- All visitor transportation service should be more nection to the District of Columbia, the monu- frequent and at a lower cost. Additional con- mental core, and the National Mall. venient stops will be provided at Metro stations. All alternatives in this document are consistent Center for Urban Ecology with the proposed transportation service. The National Park Service’s Center for Urban Mall Soil and Turf Study Ecology provides scientific guidance, technical assistance, and education for the preservation, In 2010 at the request of Secretary of the Interior conservation, and enhancement of park resources Ken Salazar, a consultant design team with ex- within urban landscapes. The center is committed pertise in sports field development is developing to improving and conserving the quality of a plan to restore the central Mall turf panels. The natural resources throughout the National Capi- approach is to remove soil to a depth of about 2 tal Region of the National Park Service. Working feet and replace it with a compaction-resistant with resource managers, researchers, and the but drainable soil system. Turf panels would be public, the center strives to discover and incor- crowned for good drainage, as they were de- porate new ways to understand, preserve, and signed in the 1930s by Frederick Law Olmsted Jr. enhance natural communities within and around The project includes the development of a dur- the national parks in the Washington, D.C., area. able irrigation system that would have the ca- The center’s research and initiatives continue to pacity to capture and reuse water from sur- provide planning guidance on issues affecting the rounding sources, such as groundwater currently National Mall plan. being removed from tunnels under the National Mall. This sustainable approach would help meet The center can undertake inventories, conduct the requirements of Executive Order 13514 monitoring, and prepare reports related to air and (“Federal Leadership in Environmental, Energy, climate, geology and soils, water resources, bio- and Economic Performance”) to reduce the use logical integrity, and landscape dynamics. In the of potable water by 26% by 2020. past they were involved in several studies of soils

47 PURPOSE OF AND NEED FOR THE PLAN that addressed compaction. The booklet Values Planning Together for Central and Challenges in Urban Ecology (NPS 2008f) Washington identifies several challenges in urban park areas, including impervious surfaces and trees. Planning Together for Central Washington is a collaborative effort of the Architect of the Capi- tol, the Commission of Fine Arts, the District of NTERAGENCY LANNING FFORTS I P E Columbia, the National Capital Planning Com- CapitalSpace mission, and the National Park Service. Each of these agencies is undertaking major planning Washington, D.C., has more than 7,650 acres of initiatives for central Washington, which to- public parks, ranging from Rock Creek Park to gether provide a framework to coordinate plan- small neighborhood parks, playgrounds and ning and investment to ensure that central ballfields. The National Capital Planning Com- Washington continues to serve as a model for the mission, the National Park Service, and the nation and the world through its cultural venues, District of Columbia have formed CapitalSpace its architecture and open spaces, its vibrant walk- to enhance existing plans for D.C. parks by pro- able neighborhoods and public transit, and its viding closer coordination of separate initiatives national and international presence. While each (NCPC et al. 2008). The goal is to develop a initiative reflects the mission and goals of its citywide framework to achieve the full potential sponsoring agency, the plans share core objec- of a beautiful, high-quality, and unified park tives and implementation priorities. system for the nation’s capital. As such, the Na- tional Mall and all of the areas managed by the Common objectives that the agencies have National Mall and Memorial Parks play an im- adopted include the following: portant role in providing for active and passive • Welcoming Atmosphere — Create an atmos- recreation. The CapitalSpace initiative includes phere that embraces local citizens and visi- maps that provide a comprehensive analysis of tors, statesmen, foreign dignitaries, and the access to various existing park resources, includ- global media. Celebrate the warmth of a ing active recreation fields, natural resources, friendly town, the dignity of a seat of gov- and passive recreation amenities. ernment, and the vibrancy of a progressive CapitalSpace envisions a beautiful, high-quality, international city. Provide opportunities for unified park system for the nation’s capital that the exchange of ideas, citizen action, enjoy- ment, and meaningful encounters and • is safe and accessible to everyone who events. Create public spaces that are attrac- lives in, works in, or visits the city tive year-round as well as programs and services that are accessible and easy to use. • includes a variety of parks and open spaces that connect communities • Well-Connected Public Space — Create a distinguished and accessible public realm of • incorporates stewardship and celebration enduring quality shaped by beautiful civic or natural, cultural, commemorative and infrastructure, architecture, streets, parks, historic spaces and waterfronts. Connect destinations and • provides a diversity of active and passive overcome existing physical barriers with recreation walkable landscaped corridors, interpretive and wayfinding systems, and engaging • contributes to a healthy, sustainable, and views. Meet the highest standards for de- livable city sign, construction, and maintenance. • serves as a national and international • Distinctive Places — Create or renew neigh- model of citizen engagement and borhoods and public places throughout collaboration central Washington to provide a mix of uses and experiences that are authentic, diverse, and reflect the city’s history and culture. Devote attention and infrastructure rein- vestment to ensure that the National Mall

48 Interrelationships with Other Plans and Projects: Interagency Planning Efforts

remains a destination worthy of its civic, conserve energy, and reuse and recycle historic, and symbolic role in serving the water and materials. city and the nation. Refurbish historic gov- • 21st Century Transportation — Establish a ernment facilities and sites that serve the comprehensive, flexible, convenient, and American people and house the three coordinated network of public and visitor branches of government. transit options — subway, light rail, street- • Green and Sustainable — Achieve a livable, car, bus, water taxi — linking central Wash- healthy, and sustainable environment with ington destinations to support economic clean air, water, and soil by using model investment and environmental health. Up- development and maintenance practices. grade public infrastructure to encourage Apply an integrated ecological approach to walking and bicycling, and develop compre- implement programs for controlling emis- hensive travel demand management pro- sions, plant trees, preserve and connect grams to reduce congestion, improve air open spaces, encourage green and sustain- quality, and address parking and tour bus able building practices, reduce pollutants, issues.

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