No Arch Support
The president’s desire for a 250-foot-tall monumental arch between the Lincoln Memorial and Arlington National Cemetery is being tested. The administration’s preferred location, Memorial Circle at the western end of Arlington Memorial Bridge, is of great significance. The bridge physically and symbolically links the north and south to heal the division of the Civil War. And this connection is reinforced via an unimpeded view from Arlington House, the onetime home of Confederate General Robert E. Lee, to the Lincoln Memorial. The arch would largely sever that important relationship. But there is one possible solution. The D.C. State Historic Preservation Office (DC SHPO) recently suggested siting the arch elsewhere.
This could, in theory, be a big win for the administration, but will it be enough? Will the administration, instead, insist on the Memorial Circle location?
The Triumphal Arch is not popular as measured by the thousands of letters in opposition received by the U.S. Commission of Fine Arts (CFA), which nevertheless gave the project final design approval without seeing final designs, and the tens of thousands of letters in opposition received by the National Capital Planning Commission (NCPC), which will review the project on Thursday, July 9. And then there are the 100,000 comments the National Park Service (NPS) received during a very abbreviated ten-day public comment period last month as part of a review under Section 106 of the National Historic Preservation Act.
As the DC SHPO made clear in a letter of June 15, “Since a memorial honoring our country’s 250th anniversary appears to have no relationship to Memorial Circle and would be inconsistent with Memorial Avenue’s symbolic view corridor, the arch could conceivably be constructed at other locations.” Unfortunately, the administration rushed the process by first seeking reviews and approvals from the CFA and NCPC before initiating a Section 106 review.
The principal goal of a Section 106 review is to identify if the proposed undertaking (in this case, a 250-foot-tall arch) would have an “adverse effect” on historically significant visual and spatial relationships (i.e., a negative impact) and how to “avoid, minimize or mitigate” those adverse effects. As part of that process alternative sites could have been considered to “avoid” the arch’s adverse effect. But that didn’t happen and now the administration is facing considerable public opposition along with a lawsuit filed by several military veterans and a prominent historian.
Moreover, the administration is trying to circumscribe and expedite the Section 106 process. NPS, which is administering the review (since the arch would be built on NPS property), has thus far chosen to not grant “consulting party” status to The Cultural Landscape Foundation (TCLF) and five other organizations. Consulting parties are subject area experts that provide important insights and advice in helping to address adverse effects. In the case of the arch, NPS has said the “Undertaking will be consistent with … the Secretary of the Interior’s … Guidelines for the Treatment of Cultural Landscapes.” Since TCLF’s Founding President & CEO, Charles A. Birnbaum, was the principal author of those guidelines during his tenure at NPS (1992-2007), he and TCLF would logically be “consulting parties” to this review. And the detailed, well-constructed comments submitted by other groups not granted consulting party status—including the National Trust for Historic Preservation, the Committee of 100 on the Federal City, and the D.C. Preservation League—further indicates the expertise missing from the “consulting party” meetings. NPS claims that “those who wish to participate have indeed been able to do so.” That is not only disingenuous, its simply not true because it deliberately ignores those who wish to participate as “consulting parties.” Moreover, TCLF and the other affected organizations have, over several decades, been participants and are participating as consulting parties in other reviews overseen by NPS, which raises questions about why in this specific instance NPS is not granting “consulting party” status.
For example, TCLF and others are currently “consulting parties” to the Section 106 review of the new White House Visitor Center, which is proposed for Sherman Park, just south of the Treasury Building. There were three meetings the spring and the result is a revised design that substantively and substantially addresses many of the adverse effects of the original proposal raised by consulting parties. It’s a textbook example of how the process can and should work.
Gaming the system is currently happening elsewhere in D.C. as demonstrated by TCLF’s recent lawsuit challenging the project work which is more than routine maintenance at the Reflecting Pool on the National Mall. The basin’s historic and character-defining color is a recognized key defining characteristic of this world-famous site, which is listed in the National Register of Historic Places. The project work should have undergone a full Section 106 review. Instead, the administration granted itself a “streamlined review” even though they admit the project was “ineligible.” And they also admit the “streamlined review” was granted because of pressure from “White House leadership” (it also should been reviewed by the CFA, as it has in previous decades, and NCPC).
Which brings us back to the arch.
In a letter of June 26, the DC SHPO stated: “the proposed triumphal arch would be isolated and constrained on a high-volume traffic circle … which is entirely parkland removed from the urban fabric of Washington. The location does not suggest a likelihood of success for a celebratory monument.” The letter continues: “Given the substantial adverse effects at the Memorial Circle location, we recommended that the National Park Service consider an alternate location for the arch, specifically at the newly created oval marking the arrival of South Capitol Street at the Anacostia River and its shift in direction to cross the new Frederick Douglass Bridge. This location offers multiple advantages. It is on direct axis with the Capitol and would mark the entrance to the original city on one of the four cardinal axes emanating from the Capitol dome. The 166-foot height of its main block would be more in scale with the 288-foot height of the Capitol dome. It would establish a direct visual interrelationship with the Capitol dome in the same manner as the other reciprocal vistas that characterize the L’Enfant city. … And importantly, it would enhance the historic L’Enfant Plan and the city’s monumental landscape rather than detracting from it. “
The Virginia Department of Historic Resources (which is home to the VA SHPO), wrote a compelling, detailed, and articulate critique of the Arch Section 106 process that not only questions the some of the assumptions that are foundational to NPS' assessments, it states: "These adverse effects are intentional and inherent in the design of the arch; it is intended to dominate the surrounding landscape." It continues by noting the location, size, and design "are all intended to be visually overpowering, dwarfing surrounding monuments and visible from points across Virginia and the District."
Opposition to a centrally located monument between the Lincoln Memorial and Arlington House is not new. As TCLF previously wrote, in a letter on April 4,1916, Frederick Law Olmsted, Jr., commented on a bridge proposal by Edward Pearce Casey (above) that included “central ornamental towers, which would conflict with the proposed Lincoln Memorial.” Olmsted said the towers should be removed, otherwise they would be “a slap in the face to the Lincoln memorial.”
The current administration has an opportunity to site the arch elsewhere and claim success; will they take it?
