TABLE 1: SUMMARY OF ALTERNATIVES AND IMPACTS

ALTERNATIVE A: No ACTION ALTERNATIVE B: PROPOSED ACTION

CONCEPT
Maintain the existing concrete barriers along H Street bordering the north side of Lafayette Park; retain existing conditions within the park. Install permanent security bollards along the north side of the park between townhouses on Jackson and Madison Places; removing lodge structure at the north edge of the park; and make minor road alterations to Jackson and Madison Places.

· Description of Action
Replace individual barriers when damaged or deteriorated and paint as needed to cover graffiti or vandalism, but do not change their location. Install bollards and capstone line behind the curbstone along the northside of Lafayette Park. Use curb terminus pieces to transition to pedestrian circulation areas. Use the same design, shape, and color for bollards as those along E Street south of the White House. Undertake minor road work on Jackson and Madison Places: provide narrower vehicular entries off H Street to Jackson and Madison Places by using curbs, gutters, and paving materials; maintain pedestrian crosswalks at the north ends of Madison and Jackson Places level with the adjacent sidewalks (vehicles drive over the level crosswalk); at each gatehouse and vehicle barrier south of H Street narrow the roadway to the width of a single vehicle by using curbs, gutters, and paving; place line of bollards north of each gatehouse and pick up again on the other side of the vehicle barrier. Except at entry ways and around the gatehouses, the bollards would have a chain between them. Provide storm sewer drop inlets.

IMPACTS
Adverse effects on the visual environment, visitor use, pedestrian circulation, and the historic landscape created by the installation of the temporary concrete barriers in May 1995 would continue. Security needs would not be met. The proposed action would remove the adverse effects created by the installation of temporary concrete bollards as a security measure in May 1995. By using materials already on the site and repairing lost or damaged features with new quality materials and features, this action would also help restore a more formal appearance to the north side of Lafayette Park.

·Cultural Resources
The continued presence of the concrete barriers would be an intrusion on the character and overall design of Lafayette Square National Historic Landmark District. While the bollards would not introduce any new materials, colors, or textures to the park, they would be a new element in the historic landscape and would be an adverse effect under federal historic preservation regulations (36 CFR 800). Removing the lodge would help emphasize the formal design of the landscape

·Visual Resources
A Over the years piecemeal repair and replacement of elements in Lafayette Park and the installation of concrete barriers have given the area the appearance of being unfinished. Retaining the lodge structure would continue to detract from the park and its surroundings. Replacing the concrete barriers with bollards would enhance the appearance of the north side of the park. Visitors would be able to see through the bollards into the park, and painting the bollards black would reduce their visibility. Recessing the bollard line at pedestrian entries would be more visually welcoming and would keep the historic park statues as dominant elements. Using an existing bollard design would help establish a uniform design and sense of continuity throughout President's Park. Removing the deteriorated lodge would improve visual access through the park as well as toward the White House and adjacent historic structures.

· Visitor Use
The appearance of the park may make some people feel unwelcome or may have caused them to avoid using it. The lodge blocks sightlines for visitors viewing the White House and walking through the park. The bollards would present a more welcoming impression for the public and possibly encourage them to spend more time in the park and its immediate environs. Demolishing the lodge would remove a public use facility already closed for health reasons.

·Circulation
The concrete barriers would continue impede pedestrian access to Lafayette Park. to Pedestrian movements would be easier all along the north side of the park. Recessed pedestrian entries clearly identify circulation patterns. Setting the bollards on Madison and Jackson Places back from H Street would provide space for vehicles waiting to be cleared and improve traffic flow on H Street.

· Security
The barriers do not meet security requirements. Bollards would provide the necessary security for this area. The bollard line would connect with interim gatehouses and vehicle barriers to create a continuous northside secure line. Narrower and redefined entries, level crosswalks and paving materials, along with curb / gutter lines at the entrances to Jackson and Madison Places would discourage accidental entries by unauthorized vehicles.

· Natural Resources

No effect.

No effect.

· Park Operations
Bringing the closed restrooms up to code and Uniform Federal Accessibility Standards would require extensive renovations and financial investment. The concrete barriers would continue to make snow removal, sweeping, and other maintenance operations more difficult.  Removing the concrete barriers would simplify maintenance operations. Following removal of the lodge, maintenance equipment now stored in the lodge area would need to be stored offsite and brought in as needed.  


AFFECTED ENVIRONMENT

SIGNIFICANT PLANS FOR LAFAYETTE PARK

Pierre Charles L'Enfant, 1791. L'Enfant's 1791 plan for the federal city, which was revised by Andrew Ellicott in 1792 and others, provides the design for Washington, D.C., today. The city was planned to rest on a series of riverine terraces and to be oriented toward the Potomac River. Most important to L'Enfant's vision were broad urban and ceremonial vistas and grand avenues connecting the executive, legislative, and judicial branches of government.

In the L'Enfant plan the streets followed a grid system overlaid with a series of radial configurations centered on proposed open spaces. The National Mall and President's Park combined to form an L-shaped open space, the axis of which terminated at the juncture of the Potomac River and Tiber Creek. L'Enfant envisioned a great house and offices for the president facing the river, framed by substantial grounds and connected to the Capitol by a broad ceremonial avenue later known as Pennsylvania Avenue. President's Park and its uninterrupted south vista constitutes one of the major elements of L'Enfant's plan.

Thomas Jefferson, cat 1804. Thomas Jefferson's specific plans for the White House property remain unknown. However, it is clear that he felt L'Enfant's park to be too extensive for the executive mansion. He attempted to reduce the substantial acreage of the house site in various ways. He envisioned the future Lafayette Park (then known as the President's Square) as a public commons, and he had a curved stone wall built around the immediate house grounds in an attempt to scale the property to the house and to separate this area from the executive office buildings on the east and west. There are no records showing how much of Jefferson's landscape plans were implemented; however, some schematics and paintings of the wall have survived. The north approach to the White House, for instance, was more formal: walkways lined with trees repeated the radial lines of the streets on the north lawn with a central north-south drive approaching the north entrance. Southeast of the White House, a classical Roman triumphal arch designed by Benjamin Henry Latrobe (ca. 1806) marked Pennsylvania Avenue. Jefferson envisioned street plantings of Lombardy poplars on Pennsylvania Avenue that would visually link the Capitol and the White House. Jefferson's vision for the property dominated its development until the mid- l9th century.

Andrew Jackson Downing, 1851. Downing's 1851 plan for President's Park represents the first detailed plan for development. Downing's plan respected L'Enfant's initial concepts but also reflected a mid- 1800s aesthetic in the layout of plantings and walkways. Under Downing's plan, Lafayette Park (which had been renamed Lafayette Square in 1824--25) was designed to be a separate world, with walks somewhat resembling those of today. A pedestal was installed as a base for an equestrian statue of Andrew Jackson in 1853. The park was taken over by the Union Army during the Civil War and had to be rebuilt about 1871-72, using the Downing plans.

McMillan Plan (Senate Park Plan), 1901. The 1901 plan by the Senate Park Commission used L'Enfant's original designs as a base and refined some concepts concerning the National Mall and President's Park. The commission, consisting of Daniel H. Burnham, Frederick Law Olmsted, Jr., Charles F. McKim, and Augustus Saint-Gaudens, was formed to guide urban planning for the District of Columbia, taking its lead from the City Beautiful ideal first expressed at the World's Columbian Exposition of 1893. Although the McMillan plan's influence on the National Mall and other areas of the city was great, its effect on President's Park was limited. The Treasury Building, the Executive Office Building, and the general plan for Lafayette Park were left intact. The plan proposed large federal buildings surrounding Lafayette Park.

National Park Service, cat 1935. Lafayette Park (renamed from Lafayette Square in 1933) was substantially reworked by the National Park Service during the 1930s. In 1933 the Park Service had assumed administration of President's Park from the Corps of Engineers, and it contracted with Olmsted to evaluate the landscape and make recommendations. Many of the Downing-inspired secondary walkways were removed, and a new simplified walk design was installed. Plantings were changed to open the vista to the north. The two bronze urns placed in the park in 1872 were relocated to the eastern and western edges of the park. Discussions regarding the removal of the Jackson statue, however, were tabled.

John Carl Warnecke Associates, 1962 69. From 1962 to 1969, John Carl Warnecke Associates, in conjunction with Mrs. Paul Mellon and the National Park Service, redesigned Lafayette Park. Warnecke retained the basic 1930s walk design, using brick pavers set on sand. Two large oval fountains were built to the east and west of the Jackson statue in the general areas where the bronze urns had been placed in the 1930s, and the urns were moved to their present positions at the south central entrance to the park. The design also called for saving the historic townhouses along Jackson and Madison Places, infilling with structures of a similar scale and new construction behind.

CULTURAL RESOURCES

The area of potential effect covered by this Environmental Assessment extends generally from 15th Street on the east to 17th Street on the west and from Lafayette Park northward on 16th Street and Vermont and Connecticut Avenues to I Street. Pennsylvania Avenue serves as the south edge of the area of potential effect. The farther removed one is from Lafayette Park, the less visible actions in the park become. Views rapidly diminish or are obscured by modern construction outside the immediate area; consequently, the effect on cultural resources of implementing any alternative would be negligible beyond these streets.

Only Lafayette Park and the area extending from the townhouses on Jackson and Madison Places to H Street would be directly affected by bollard placement and lodge removal. Hence, the study area for the purpose of analyzing the effects of bollard placement and removal of the lodge structure on properties listed on, or determined eligible for listing on, the National Register of Historic Places consists of Lafayette Park and its immediate environs (from H Street to Pennsylvania Avenue, and from Jackson Place to Madison Place).

Archeological and historic resources within the study area have been evaluated by the National Park Service and are described in the following documents for the White House and President's Park: "Archeological Evaluation Report" (NPS, Pousson and Hoepfner 1995), "President's Park Cultural Landscape Report" (EDAW, Inc., et al., 1995), and "Draft Administrative History" (NPS, O'Brien 1996a). The following description of archeological and historic resources is derived from these reports.

Archeological Resources

Prehistoric archeological resources dating from the Paleo-Indian period (9,500-8,000 B.C.) through contact with European colonists have been discovered in the District of Columbia. However, the earliest prehistoric artifacts found in President's Park date to the Late Archaic period (3,000 1,000 B.C.) and were uncovered in 1975 during excavation south of the West Wing of the White House. While it could not be determined whether these artifacts were undisturbed or had been brought in with fill dirt during the past 200 years, the location of the White House on high ground makes it possible that these artifacts had been undisturbed onsite.

Late Archaic artifacts have also been uncovered during nonarcheological excavations on the Ellipse by NPS staff but are believed to have been in fill material brought in during the raising of the ground level. No other prehistoric artifacts have been uncovered in President's Park, although it is possible that such resources are buried deeper under the fill.

Within Lafayette Park the likelihood of either prehistoric or historic archeological resources of significance is low. Such resources would have been severely compromised by leveling and filling operations that occurred until the 1850s and by tree planting and utility installation that have occurred since. Any remaining archeological features would likely be associated with various episodes of park development. Although valuable from the standpoint of verifying the historical record, the likelihood of such resources being determined eligible for listing on the National Register of Historic Places in their own right would be small.

Historic Resources

The two parcels of land that later became President's Park, prior to their purchase by the federal government in 1791, were owned by Edward Peerce and David Bumes. The Peerce property, which had been in that family since 1685, occupied the northern portion of the site, including lands that would later become Lafayette Park. There may have been a farmhouse, outbuildings, and a cemetery on the site, but sources are unclear as to their exact location. The Bumes farmstead was west of 17th Street, and no farm structures appear to have been constructed within the area now known as President's Park.

After purchase by the federal government, the land became part of Federal Reservation 1, which encompassed all of the White House and President's Park. The area that was later to become Lafayette Park, Pennsylvania Avenue, and the north lawn of the White House were used for construction activities and materials storage during White House construction. A workshop was constructed at the approximate location of the Jackson statue in Lafayette Park, along with temporary housing for workers, two brick kilns, a brickmaking lime house, tempering pits for mixing clay, and carpentry and stone shops. As many as 22 structures, several of which were brick, have been identified in this area through cartographic interpretation.

During the 1790s, when the majority of the federal capital population lived in nearby Georgetown, a road that would become known as Pennsylvania Avenue was probably the most used route to the construction sites of the White House and the Capitol. One source, however, noted that a ferry road from Georgetown followed the route of present-day H Street at the north edge of what is now Lafayette Park. Some sort of right-of-way had to provide access to workmen's cottages in what was to become Lafayette Park, and the north drive of the White House had to empty into some sort of roadway.

Lafayette Park may have been separated from the White House grounds as early as 1797, but tradition has it that President Jefferson separated what was then known as President's Square from the White House grounds in order to create a public commons. During the War of 1812, the square served as an encampment for soldiers protecting the White House. After the war, it again served as the construction staging area for rebuilding the burned out White House. By 1820, a plan that had been designed by Charles Bulfinch, the architect of the Capitol, was being implemented for President's Square.

Streets in the President's Square area were graded and formalized around 1818, and the construction of houses around and near the square began (the Tayloe-Cameron house in 1818, the Decatur house in 1819, the Cutts-Madison house in 1820, the Blair house in 1824-27, the Ashburton house in 1836, and the Lee house cat 1852).

During the presidency of James Monroe (ca. 1824), Jefferson's curved wall around the White House grounds was partially dismantled and replaced by a low, straight wall with a central inset portion and iron railing on a stone base. Although the south facade of the White House originally served as the front, over the years the north side of the structure, which is oriented more to the city of Washington, became known as the front. A road paralleling the new fence (Pennsylvania Avenue) became established by 1824, providing access to the White House and marking the south boundary of President's Square. About this time, President's Square was named Lafayette Square by either Monroe or John Quincy Adams in honor of a visit by the Marquis de Lafayette in 1824-25.

By 1852, Lafayette Square had been relandscaped extensively according to the plans developed by Andrew Jackson Downing. In 1853, the statue of Andrew Jackson, the oldest equestrian statue in the United States (cast by sculptor Clarke Mills from Spanish cannon taken at Jacksonville), was installed in the center of the square, and the square was fenced. Beginning in 1857, underground drainage systems and gas pipelines for gas lamps were installed.

During the Civil War, Lafayette Square was damaged extensively by troop encampments and was restored in 1866 by the Corps of Engineers in accordance with the Downing plan. Later, a new drainage system, additional gas lamps, a watchman's lodge, and water fountains were added. During the period from 1889 to 1911, four monumental American Revolutionary statues commemorating military figures who aided the young republic in its fight for independence were added to the corners of the square—Lafayette in 1889, Rochambeau in 1902, Kosciuszko in 1910, and von Steuben in 1911.

In 1894, Lafayette Square was officially separated from Federal Reservation 1 and renumbered Reservation 10. The watchman's lodge on the north edge of the square was replaced in 1913-14, and utility conduits were installed between 1905 and 1910.

After 1900, larger buildings began to dominate the edge of Lafayette Square, replacing the more residential scale structures that had surrounded it for a century. This was in response to the McMillan plan of 1901, which envisioned this area as containing monumental government and associated buildings, a concept similar to the present-day Federal Triangle. The scale and monumentality of the Veterans Administration (1918), Treasury Annex (1919), U.S. Chamber of Commerce (1925), Hay-Adams Hotel, Riggs National Bank (1899-1902), and American Security and Trust Company (1904-05) all express the McMillan plan vision.

After the National Park Service took over administration of Lafayette Park in 1933, the Works Progress Administration, under the direction of the Park Service, redeveloped the park along recommendations from Olmsted, essentially creating its present-day appearance. During the 1960s and 1970s a concerted effort was undertaken to preserve the historic houses along Jackson and Madison Places, as well as the Renwick Gallery and the Old Executive Office Building on Pennsylvania Avenue, and to rehabilitate Lafayette Park, which had become a focal point for demonstrations. A plan developed by John Carl Warnecke during the Kennedy administration upgraded the park with "minimal changes," brick paving, and new fountains, while creating much needed office space, resulting in the present appearance of the park and its immediate surrounding area.

Significant Historic Structures and Districts in or near Lafayette Park

In accordance with the National Historic Preservation Act of 1966, as amended, all properties listed on, or determined eligible for listing on, the National Register of Historic Places are described in terms of what makes them significant. The original nomination forms for resources in the Lafayette Park area that are listed on the register do not provide adequate information about the significance of resources, so subsequent research was undertaken through the aforementioned studies. The 1995 "Cultural Landscape Report" recommends that the period of significance for Lafayette Park end with the last major rehabilitation in 1970. The effects considered in the "Environmental Consequences" section of this Environmental Assessment are based on this date.

This area of Washington has continually changed despite the fact that resources along Pennsylvania Avenue, Jackson and Madison Places, and within Lafayette Park are part of a national historic landmark district. For example, the Old Executive Office Building has been restored to its appearance at the time of its construction (1871-88), but the surrounding landscape does not represent that period; rather, it is aesthetically compatible with the structure itself and does not detract from its significance. Most of the historic structures within the design precinct are significant for their architecture and history but do not retain their immediate historic environs.

Lafayette Park has also evolved, but the basic conceptual landscape designs of Andrew Jackson Downing (1851) and the National Park Service (1930s) have endured. Therefore, although changes considered in the proposed action could alter features of the environment for historic structures, individual changes associated with this project when taken in context may not affect the criteria that originally qualified a structure for inclusion on the national register.

Historic structures and districts in or near Lafayette Park and its immediate environs include (1) American Peace Society National Historic Landmark; (2) American Revolution statuary; (3) Ashburton House (St. John's Church Parish House) National Historic Landmark; (4) Blair House National Historic Landmark; (5) Carnegie Endowment for International Peace National Historic Landmark; (6) Decatur House National Historic Landmark; (7) Lafayette Square National Historic Landmark; (8) L'Enfant Plan of the City of Washington, District of Columbia, National Historic Landmark; (9) St. John's Church National Historic Landmark; and (10) U.S. Chamber of Commerce. (These properties are further described in appendix A.)

A watchman's lodge was built on the north side of the park in 1871 and was replaced in 1913-14. Although it is the last remaining such structure in a District of Columbia park area, the building has been altered considerably since it was constructed. According to a 1974 finding by the Joint Committee on Landmarks of the National Capital, the state historic preservation officer of the District of Columbia, and the Advisory Council on Historic Preservation, removing the lodge building would not constitute an adverse effect on the Lafayette Square National Historic Landmark District. A subsequent NPS determination of eligibility for the structure has found that it does not meet any criteria for listing on the National Register of Historic Places (see appendix D). The lodge structure had not been previously removed because the Park Service had determined that proposed designs for a new restroom building were not acceptable. The Park Service closed the restroom facility in October 1997 in response to a U.S. Public Health inspection; it is likely that for the structure to be reopened for use as public restrooms, the building and its water- and sewerlines would have to be dismantled and reconstructed.

NATURAL RESOURCES

The President's House was sited to take advantage of local geographical and hydrological patterns. It is situated on the Talbot terrace, a point of higher elevation that is unaffected by flooding on the Potomac River.

Geology and Topography

President's Park, including Lafayette Park, is underlain by river terrace deposits generally composed of gravel, sand, and loam. In scattered areas the formation contains layers of finegrained deposits of clay, silt and peat, and plant fossils. The river terrace formation is as much as 30" thick. Artificial fill occurs throughout the park and consists of unconsolidated material from nearby river dredgings and excavations. Areas of artificial fill are located in cut or disturbed ground, reclaimed areas, and sanitary landfills.

Soils

The Soil Conservation Service has identified the soils of President's Park as Beltsville-Urban land complex, with 0% to 8% slopes. These soils formed in the parent material of a silty mantle probably deposited by the wind. They are moderately well-drained, nearly level to gently sloping on higher elevations of the Coastal Plain. The Soil Conservation Service has collected and analyzed data from soil borings in the Beltsville-Urban land complex to determine soil characteristics and behavior of soil for potential development uses:

Physical and Chemical Properties

Soil drainage: slow
Permeability: slow
Runoff: medium to rapid
Erosion hazard: moderate to severe
Available water capacity: moderate in relatively undisturbed areas; low to very low in highly urbanized areas
pH: most unlimed areas very strongly acidic
Flood frequency: none
Shrink/swell potential: low

Site Development Limitations

Shallow excavations: severe due to moisture, cemented pan
Roads and streets: severe due to frost action
Recreational uses: fair to poor potential due to moisture
Landscape vegetation: fair potential

While some areas of the park are relatively undisturbed, disturbed areas have had as much as two-thirds of the original profile removed by grading and cutting.

Water

Historically, the Potomac River extended as far as the southwest corner of President's Park. Tiber Creek, a perennial stream flowing southwest through the present downtown Washington area, emptied into the Potomac at this point. With the growth of the city, portions of the river and adjacent river flats were filled to create the Ellipse and the National Mall. Tiber Creek still flows beneath Constitution Avenue, but it has been incorporated into the city's stormwater sewer system.

No known wetlands exist within President's Park, although historically the southern section of the Ellipse was creek bottoms and wetlands.

Vegetation

Vegetation and landforms in this area have been heavily manipulated. Plantings have been selected for aesthetics, and landforms have been altered to create building sites, street alignments, and parklike settings. The lawns, plantings, large canopied trees, and curvilinear walks are a marked contrast to the adjacent paved streets, sidewalks, and clustered buildings.

Despite the urban stresses of pollution, soil compaction, litter, damage, and vandalism, vegetation in Lafayette Park is carefully maintained and healthy. The park contains 212 trees, representing 38 native and exotic species (see appendix B for a list of the trees). Four tree species comprise more than 60% of the trees in the park: native willow oaks and American elms and exotic ginkgoes (all tall spreading trees) are planted in tree wells in the sidewalks surrounding the park, while nonnative saucer magnolias (a bush-like tree) are found throughout the interior of the park. Most tree species, however, are represented by just a few specimens.\

Wildlife

Species that typically occupy urban areas, including squirrels, pigeons, gulls, sparrows, starlings, and Norway rats, are found in Lafayette Park. Other species occasionally observed are peregrine falcons and migratory birds.

Landscape maintenance activities include the management of Norway rats in Lafayette Park. Since rat infestations are high at adjacent properties, control methods mitigate, but cannot eradicate, existing populations. The management program includes monitoring, baiting burrows, and removing overgrown vegetation.

Populations of other species are dense enough to present difficulties. Pigeons and gulls in the park crowd walkways and deposit droppings on benches, statuary, walkways, and plant materials. No management programs are currently in place for these bird species, although the feeding of birds is discouraged because squirrels and rats forage on this food source.

Lafayette Park reportedly once had the highest density per acre for squirrels in the world. In the past gray squirrels have damaged a significant number of the park's trees and flowering plants. The park supported as many as 150 to 200 squirrels per acre prior to a relocation program in 1985, while habitat modification decreased the number of available den sites. Past management activities also included monitoring the size and condition of the squirrel population and educating the public on the deleterious effects of feeding them. The squirrel population has stabilized at 35 to 40 animals per acre.

Threatened or Endangered Species

The Endangered Species Act of 1973, as amended, requires all federal agencies to consult with the U.S. Fish and Wildlife Service to ensure that any action authorized, funded, or carried out by an agency does not jeopardize the continued existence of listed species or critical habitat. There are no known federally listed threatened or endangered species in the area.

Air Quality

Within President's Park, ambient concentrations of carbon monoxide and ozone result primarily from motor vehicle use; emissions of nitrogen oxides and particulate matter result from vehicles and stationary sources; and emissions of sulfur oxides and lead are associated mainly with stationary sources of emissions. Even though there are no air quality monitoring stations within or adjacent to the study area (the closest monitoring station is at 21st and L Streets, northwest of Lafayette Park), pollutants most likely to be of concern near President's Park are those associated with motorized vehicles.

The Washington, D.C./Maryland/Virginia Metropolitan Statistical Area was classified as a serious nonattainment area for ozone from 1973 to 1990 and as a moderate nonattainment area from 1990 to 1996. In 1996 the metropolitan Washington region was redesignated as an attainment area for carbon monoxide.

The Metropolitan Washington Air Quality Council has prepared plans calling for a 15% reduction in volatile organic compound emissions. The plans identify control measures for reducing volatile organic compounds and nitrogen oxides to comply with the national ambient air quality standards by 1999.

ENVIRONMENTAL CONSEQUENCES

ALTERNATIVE A—NO ACTION

Cultural Resource Impacts

Lafayette Park and its immediate surroundings are part of Lafayette Square National Historic Landmark District, lying essentially at the nation's "front door." The portable concrete barriers were never intended to be a permanent fixture, and their appearance is out of character with the overall design of the national historic landmark district. The barriers intrude on the historic landscape rather than subtly blending into it; the scale and intrusion of the barriers result in visual impacts that overpower the subtle historic details of the district. If the barriers remained indefinitely, their effect on the cultural resources of the site would continue to be adverse.

Visual Resource Impacts

Over the years, piecemeal repair and replacement of landscape features in Lafayette Park has resulted in the loss of a finished look for this area. The concrete barriers give Lafayette Park and its neighborhood the appearance of a construction area. President's Park and surrounding structures have been designed to be stately and have a sense of timelessness, and the use of the barriers is incongruent with the overall significance of the site. Moreover, the barriers have sheltered rats and have become a collection site for wind-blown debris. Periodic painting would be needed to hide scars and graffiti.

The lodge structure and the concrete barriers block visibility across Lafayette Park. Retaining this deteriorated building, which now only serves a maintenance function, would continue to detract from the character of Lafayette Park and its surroundings. Upgrading the appearance of the structure would require high maintenance expenditures, which would be unlikely to be funded in light of current budget restrictions.

Visitor Use Impacts

Concrete barriers and security vehicles are frequently associated in the public's mind with temporary construction. Consequently, some people may feel unwelcome in Lafayette Park and may have avoided using it, thinking construction is underway or about to occur and that the park is closed.

The lodge blocks sightlines for visitors viewing the White House and walking through the park. Despite various attempts by the Park Service to improve the structure, little can be done to correct its problems without significant and costly renovation and rehabilitation efforts.

Circulation Impacts

The size of the concrete barriers impedes pedestrian access to the north part of Lafayette Park, particularly for people crossing in the middle of the street who must then walk along the barriers to reach a break or crawl over them. The location of the barriers approximately 8' to 10' back from the curb bisects and constricts pedestrian movement on the sidewalk. On Jackson and Madison Places, the barriers, a U.S. Secret Service vehicle used for security, and planters on the sidewalk at the intersection of these streets with H Street further constrict access. Metro buses stop along the south side of H Street, the barriers also continue obstacles for passengers getting on and off buses. The unwelcome appeal of the barriers may discourage visitation to the historic buildings around the park.

Deliveries are limited by the placement of the temporary barriers, and illegal parking on H Street causes traffic delays. Traffic flow on H Street is affected by the temporary barriers at Madison and Jackson Places because there is no space for waiting vehicles to be checked before entering the site.

Security Impacts

The existing concrete barriers do not meet security requirements for the area.

Natural Resource Impacts

The overall impact of the no-action alternative on natural resources appears to be negligible. While the barriers may harbor rats, they do not impede the flow of water during rainfall, nor do they affect other local wildlife.

Park Operations Impacts

Bringing the closed restrooms up to code and Uniform Federal Accessibility Standards (UFAS) would require extensive renovations and financial investment. The concrete barriers on the sidewalk would make snow removal and sidewalk cleaning more difficult.

ALTERNATIVE B—PROPOSED ACTION

Cultural Resource Impacts

The bollards, which would be of the same design as those along E Street, would not introduce any new materials, colors, or textures within Lafayette Park or President's Park, but they would represent a new element in the historic landscape. The bollards would be visible from surrounding historic properties, but they would be much less intrusive than the existing concrete barriers. Their color, scale, and detail would be compatible with other historic resources in the park. Placing the bollards south of the sidewalk would ensure that they remained in the background and would not intrude on the site's historic setting and design. Because the bollards would be nonhistoric elements introduced into a historic environment, there would be a adverse effect under the Advisory Council on Historic Preservation's '`Regulations for the Protection of Historic and Cultural Properties" (36 CFR 800; see page 30).

Removing the lodge structure on the north side of the park would create a more symmetrical appearance and entryway to Lafayette Park that would emphasize the site's formal design.

Installing drop inlets, an associated underground stormwater line, and the bollard foundation could affect archeological resources that have not been identified to date. The National Park Service would ensure that archeological monitoring was conducted by qualified personnel during excavation to minimize any potential adverse effects.

Visual Resource Impacts

Replacing the temporary concrete barriers with permanent bollards located behind the existing stone curbing would enhance the appearance of the north side of Lafayette Park. Visitors would be able to see through the bollards into the park. The bollards would provide an appropriate level of security, and their small scale would not be a significant intrusion on the historic setting. Unlike the temporary concrete barriers, debris would not collect at the base of the bollards. Even though the bollards would be new elements on the site, visitors would find them less intrusive on the historic landscape than the concrete barriers are now.

The bollards would be linked with a continuous charcoal gray granite capstone, and the bollards themselves would use materials, colors, and textures already within President's Park as a means of integrating them into the landscape and lessening their visual impact. The bollards would have the same design, shape, and color as those along E Street south of the White House, and the black color would reduce their visibility. Using an existing bollard design would help establish a uniform design and sense of continuity for elements throughout President's Park.

Placing the bollards behind the existing park stone curb, as well as recessing them at pedestrian entryways, would present a clean, welcoming image to the public that would emphasize the historic stone curb and its outline of the park, rather than a necessary security element.

Installing narrower vehicular entries and level crosswalks at the entrances to Jackson and Madison Places would be a noticeable, but minor, change from the present. The level crosswalks would pose little visual intrusion because they would be the same height as the road crown and the sidewalk on either side of the roadways, thus emphasizing the pedestrian nature of the site.

During bollard installation, existing quarter-round granite curbing would be cleaned, and any sections that had been lost over the years (or replaced by concrete) would be replaced with matching stone materials, thus restoring these historic park elements. Existing paving would be retained or replaced if damaged during construction.

Removing the lodge structure would help create a more welcoming impression and a more symmetrical appearance and entryway to the north side of Lafayette Park. Removing the lodge would also improve visual access through the park, as well as toward the White House and adjacent historic structures. The lodge detracts from the dignity and character of the site.

Visitor Use Impacts

Providing bollards along the north edge of the park in place of the temporary concrete barriers and placing the bollards behind the stone curb, as well as recessing them at pedestrian entryways, would present a more welcoming scene, enhancing and emphasizing public access. The site would no longer appear to be under construction, so visitors would be encouraged to spend more time in the park and its immediate environs.

During installation of the bollards there would be short-term increases of dust and noise. Permit parking on Jackson Place would be reduced during construction. These effects would be an annoyance to pedestrians and park visitors and users, but they would cease after construction.

Demolishing the lodge structure would remove a building already closed to visitor use for health reasons.

The level crosswalk, new paving materials, and curb and gutter lines at the entrances to Jackson and Madison Places, as well as at the gatehouses and vehicle checkpoints, would pose no hazard for pedestrians using the streets as they would be the same height as the sidewalks on either side of the roadways. This would emphasize the pedestrian nature of the area.

Circulation Impacts

The bollards would provide physical and visual access to the north edge of Lafayette Park, thus making pedestrian movements easier. The recessed bollard line at pedestrian entries would create a circulation vestibule and clearly identify entries. Setting the line of bollards back from H Street on Madison and Jackson Places would improve access to the buildings adjacent to the northeast and northwest corners of the park.

Providing narrower vehicular entries and level crosswalks at the street entrances would further indicate that the streets were closed to public vehicular traffic. Crosswalk paving materials, as well as curbs and gutters, would identify vehicle openings and pedestrian areas.

Deliveries would be accommodated without affecting security and without vehicles having to park illegally on H Street. Providing waiting space for vehicles being cleared to enter either Jackson or Madison Place would allow for better traffic flow on H Street.

Security Impacts

Implementing the proposed action would meet security needs. Narrower road openings at Jackson and Madison Places would define vehicular entryways and enhance security by discouraging accidental entries by unauthorized vehicles.

Natural Resource Impacts

The overall impact of the proposed action on natural resources in the Lafayette Park area would be small. Due to the limited area and depth of construction there would be no notable permanent change in groundwater quality or volume of stormwater runoff. Appropriate stormwater management practices and erosion control measures would be implemented in the design and construction of the bollards, the foundation, and drop inlets. An approximate 30" wide swath of grass would be lost as a result of construction behind the stone curb.

The bollard system and drop inlets would require excavation, which could cause damage to the root systems of trees along the north edge of the park; however, it is unlikely that any trees would be lost. Root pruning well in advance of construction could minimize damage to these trees. Fencing tree root zones would ensure protection, and aerating root zones upon completion of construction would help the trees recover from associated stress (see appendix C). Special care would be taken to preserve a large American elm on the northeast side of the park by moving the bollard line slightly and using appropriate excavation and root pruning methods.

Any trees lost in the park area would represent a concomitant loss of habitat for small mammals and birds. There would be short-term impacts to local wildlife due to construction activities. Removing the temporary concrete barriers would reduce habitat for rats.

Park Operations Impacts

The maintenance equipment and supplies now stored at the lodge would need to be stored at an offsite location. Removing the concrete barriers on the sidewalk would facilitate park maintenance, including snow removal and sidewalk cleaning. Lawn mowing would be easier because the foundation cap could be used as a mow strip, thus protecting the historic curbs from further damage

CONSULTATION AND COORDINATION

FEDERAL COMPLIANCE REQUIREMENTS

Cultural Resources

One of the National Park Service's mandates is to preserve and protect cultural resources in areas under its administration, as stated in the act of August 25, 1916, that established the service and in specific legislation such as the Antiquities Act of 1906, the National Environmental Policy Act, and the National Historic Preservation Act (described below). Cultural resources in Lafayette Park are to be managed in accordance with these acts and in accordance with chapter 5 of the NPS Management Policies, NPS-28: Cultural Resource Management Guideline, the Secretary of the Interior's Standards and Guidelines for Archeology and Historic Preservation, and other relevant policy directives.

As part of its cultural resource management responsibilities under section 110 of the National Historic Preservation Act ( 16 USC 470), as amended, the National Park Service inventories and evaluates all cultural resources on lands under its jurisdiction or that may be affected by agency actions. Cultural resources are evaluated by applying the criteria for inclusion on the National Register of Historic Places. Both a cultural landscape plan and an archeological evaluation of President's Park, including Lafayette Park, were undertaken as part of the planning process for a comprehensive design plan for the White House. To ensure that significant properties outside President's Park would not be inadvertently affected by NPS actions, national register and national historic landmark forms were gathered for all properties within the area of potential effect, extending generally from I Street on the north to Pennsylvania Avenue on the south, and from 15th Street on the east to 17th Street on the west. Additionally, the historic preservation officer for the District of Columbia was contacted regarding other historic properties in the area that may be eligible for inclusion on the National Register of Historic Places.

Section 106 of the National Historic Presentation Act of 1966, as amended, establishes the obligations of the federal government regarding activities proposed for or affecting properties on or eligible for listing on the National Register of Historic Places. Federal agencies are required to take into account the potential effects of their activities on protected resources and to allow the Advisory Council on Historic Preservation and the state historic preservation officer an opportunity to comment. An action is determined to have "no effect," an "adverse effect," or an effect that is "not adverse" on cultural resources. Toward that end, the National Park Service is working with the D.C. historic preservation officer and the Advisory Council on Historic Preservation to meet the requirements of section 110 and the July 1995 "Prograrnmatic Agreement among the National Conference of State Historic Preservation Officers, the Advisory Council, and the National Park Service." This agreement also provides for a number of programmatic exclusions for actions that are not likely to have an adverse effect on cultural resources. Security barriers in President's Park do not qualify as a programmatic exclusion. Thus, review by the D.C. historic preservation officer and the Advisory Council on Historic Preservation is required during the design stage and before implementation.

A section 106 form ("Assessment of Actions Having an Effect on Cultural Resources") will be completed following approval of this plan but before implementing the proposed action. This form documents project effects, outlines actions proposed to mitigate such effects, and documents that the proposed action is the implementation of an approved plan. Cultural resource management specialists will use this form to review and certify all proposed actions affecting cultural resources.

All ground-disturbing actions will be preceded by an archeological evaluation to determine the level of archeological investigation required before construction can begin. If any such resources are identified, the D.C. historic preservation officer and the National Park Service will evaluate their potential for inclusion on the National Register of Historic Places. If any resources are determined eligible for listing, appropriate measures will be undertaken to preserve them. Archeological evaluation will be carried out before, or in conjunction with, construction.

Because all alternatives recommend a course of action that has an adverse effect on cultural resources listed on the National Register of Historic Places, the National Park Service will work closely with the D.C. historic preservation officer and the Advisory Council on Historic Preservation to determine a course of action that would avoid, reduce, minimize, or mitigate the effects.

Natural Resources

The National Environmental Policy Act of 1969, as amended, and the Council on Environmental Quality implementing regulations (40 CFR 1501, et seq.) require public involvement in the environmental analysis process. This Environmental Assessment meets NEPA and NPS informational requirements, and the National Park Service has provided for public review and input.

President's Park is in a mandatory class II clean air area. Under the Clean Air Act, as amended (42 USC 7401, et seq.), maximum allowable increases of sulfur dioxide, particulate matter, and nitrogen oxide beyond baseline concentrations established for class II areas cannot be exceeded. During any construction or site restoration activities, the National Park Service will take all practical measures to limit fugitive dust and noise. In accordance with section 118 of the Clean Air Act, the National Park Service will work with the District of Columbia to ensure that all activities in President's Park meet the requirements of federal and local air quality programs.

In accordance with section 7 of the Endangered Species Act of 1973, as amended (16 USC 1531, et seq.), consultations with the U.S. Fish and Wildlife Service indicate that no threatened or endangered species or habitat critical to their survival would be affected. The Resource Conservation and Recovery Act (42 USC 6901) and its implementing rules by the Environmental Protection Agency establish performance standards for generators, transporters, and disposers of hazardous waste. Any such wastes generated or removed from the site will be disposed of through NPS procedures, which are compatible with requirements of the act.

D.C. PERMITTING REQUIREMENTS

During the design and construction permitting process, the National Park Service will contact the permitting office of the District of Columbia to determine application procedures for all permits that may be required. Compliance will be made with all applicable requirements.

APPENDIX A: SIGNIFICANCE OF HISTORIC STRUCTURES AND DISTRICTS IN
OR NEAR LAFAYETTE PARK

American Peace Society National Historic Landmark. This structure is a large Victorian townhouse at 734 Jackson Place dating from the 1860s. From 1911 to 1948 it was the home of the American Peace Society, "the oldest organization in America engaged exclusively in efforts to promote international peace." This structure is also a part of the Lafayette Square National Historic Landmark District. (NHL 1974)

American Revolution Statuary. This nomination includes outdoor statues throughout Washington that are maintained by the National Park Service. Four sculptures in Lafayette Park—the Lafayette, Kosciuszko, von Steuben, and Rochambeau statues—are included. Their significance, apart from the important people and events in the military and political history of the United States, lies in their significance to the history of sculpture and the monumentation of the city. These sculptures are also a part of the Lafayette Square National Historic Landmark District. (NRHP 1978)

Ashhurton House (St. John's Church Parish House) National Historic Landmark. This residential structure at 1525 H Street is four stories with a mansard roof, massive stone frame window surrounds, and a "brownstone finish" exterior. The house is significant as the home of the British legation during the 10 months of negotiations that resulted in the Webster-Ashburton Treaty of 1842, resolving the long-standing dispute with Great Britain over major segments of the boundary between the United States and Canada. This structure is also a part of the Lafayette Square National Historic Landmark District. (NRHP 1973)

Blair House National Historic Landmark. This two-story, yellow stucco townhouse at 1651 Pennsylvania Avenue was constructed between 1824 and 1827. It is significant for the great number of nationally prominent dignitaries who have resided or been received there and as a center of social gatherings, the meeting place of great leaders, and the setting for great events for more than 150 years. The Blair House, also a part of the Lafayette Square National Historic Landmark District, is the presidential guest house. (NHL 1937)

Carnegie Endowment for International Peace National Historic Landmark. This three-story structure at 700 Jackson Place is a modest townhouse constructed in 1860 in the Italianate style. From 1911 to 1948 this structure was headquarters for the Carnegie Endowment for International Peace, a research and education organization. It is significant for its association with this social/humanitarian organization. This structure is also a part of the Lafayette Square National Historic Landmark District. (NHL 1974)

Decatur House National Historic Landmark. This structure at 748 Jackson Place was constructed in 1819 for Commodore Stephen Decatur. Designed by Benjamin Henry Latrobe, the most famous U.S. architect of the early 19th century, it is a brick Federal style structure with a stone foundation. It is significant as one of the few remaining structures associated with Latrobe, and the fact that it was the home of a famous 19th century military hero and subsequently the residence of several important Washington political figures. This structure is also a Dart of the Lafayette Square National Historic Landmark District. (NHL 1960)

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NOTE: The year that a structure or district was listed on the National Register of Historic Places (NRHP) or designated a national historic landmark (NHL) is shown in parentheses at the end of the listing. Several properties have multiple designations; in these cases only the highest designation is listed; for a complete listing of all designations, consult the "Cultural Landscape Report" (EDAW et al., 1995).

Lafayette Square National Historic Landmark District. This district includes the area generally from 15th to 17th streets, and from State and Treasury Places on the south to the north side of H Street, excluding the White House grounds. Properties that contribute to the district are Lafayette Park, the Old Executive Of lice Building, the Treasury Building, Renwick Gallery, Blair House, the former American Peace Society house, the former Carnegie Endowment for International Peace building, Decatur House, Chamber of Commerce, Hay-Adams Hotel, St. John's Episcopal Church and the Ashburton House, Veterans Administration, the Cutts-Madison house, the old Cosmos Club annex, the Tayloe-Cameron house, National Courts Building (Federal Circuit Court of Appeals and U.S. Court of Claims), Treasury Annex, Riggs National Bank, American Security and Trust Company, and National Savings and Trust Company. Many of these structures are also separately listed on the national register. Lafayette Square is also a part of L'Enfant Plan of the City of Washington, District of Columbia, National Historic Landmark District. The Lafayette Square National Historic Landmark District is significant for its association with the L'Enfant plan for the city of Washington, its association with landscape designer Andrew Jackson Downing, whose concept has been adhered to over the years for its symbolic significance as "the people's park," and for the architectural significance of the structures surrounding the square, which are rooted in the Federal period but express architectural styles through 19th century Victorianism, early 20 century Edwardian, and the 1920s Beaux Arts. The landmark form notes commercial, military, and political significance. (NHL 1970)

L'Enfant Plan of the City of Washington, District of Columbia, National Historic Landmark. This national historic landmark recognizes the significance of the L'Enfant plan to the beauty and history of the city of Washington and identifies those aspects of the original plan that remain, as well as those modifications made in accord with the McMillan plan of 1901-02. The period recognized dates from 1791 to World War II. It celebrates the only American example of a comprehensive baroque city plan with a coordinated system of radiating avenues, parks, and vistas laid over an orthogonal system. It is significant for its relationship to the creation of the new United States and its federal capital; for its design by L'Enfant, and the subsequent development and enhancement by numerous significant persons and groups responsible for the city's landscape architecture and regional planning; and for its well-preserved, comprehensive, classical Beaux Arts design. Listed as part of the landmark are Lafayette Park, Federal Reservation 1 (President's Park between Pennsylvania and Constitution Avenues and between 15th and 17th Streets, NW, except for the White House and grounds); all public streets and avenues throughout the study area; vistas on 16th Street through the study area, on F Street from the Treasury east, on Connecticut Avenue from the White House north, on New York Avenue from the White House north, and from the Old Executive Office Building south, on Pennsylvania Avenue, and on Vermont Avenue from the White House north. (NHL 1997)

St. John's Church National Historic Landmark. Benjamin Latrobe designed St. John's, which was constructed in 1815-16, in the form of a Greek cross. A later addition transformed it into the Latin Cross extant today. It is of brick and yellow stucco with white trim. A lantern cupola sits above a flat dome at the intersection of the wings. An entrance portico with Doric columns fronts the west addition. The structure is significant as the work of a master architect, as a notable example of late Federal architecture, for its association with various presidents and other important American statesmen, and as one of the three original structures remaining around Lafayette Park. St. John's Church is also a part of the Lafayette Square National Historic Landmark District. (NHL 1960)

U.S. Chamber of Commerce. This structure at 1615 H Street is a four-story limestone Beaux Arts classical revival building designed by Cass Gilbert, one of the most accomplished architects of the early 20th century; it was completed in 1925. While the colonnaded corner building has been altered over the years, its appearance from the street is virtually unchanged. It is significant for its association with the U.S. Chamber of Commerce, which has represented American business interests in Washington since its inception in 1912. The building is also a contributing element of the Lafayette Square National Historic Landmark District. (NRHP 1992)

Planning Team and Consultants