NATIONAL CAPITAL PLANNING COMMISSION

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COMMISSION MEETING

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OPEN SESSION

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THURSDAY, JUNE 4, 2026

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The meeting convened via Videoconference, at

1:00 p.m. EDT, William Scharf, Chair, presiding.

NATIONAL CAPITAL PLANNING COMMISSION MEMBERS PRESENT:

WILLIAM SCHARF, Chair, Presidential Appointee (At-Large)

STUART LEVENBACH, Vice Chair, Presidential Appointee

LINDA ARGO, Mayoral Appointee

MICHAEL BLAIR, Presidential Appointee

JESSICA BOWRON, U.S. Department of the Interior

STEPHEN BRUCH, Department of War

EVAN CASH, Office of the Chairman of the Council of the District of Columbia

ANITA COZART, Office of the Mayor of the District of Columbia

ARRINGTON DIXON, Mayoral Appointee

PAUL INGRASSIA, General Services Administration

NCPC STAFF PRESENT:

MARCEL C. ACOSTA, Executive Director JAMIE HERR, Urban Planner MEGHAN HOTTEL-COX, General Counsel & Secretariat LAURA SHIPMAN, Urban Planner MICHAEL WEIL, Urban Planner

CONTENTS

Commission Roll Call

4

Report of the Chairman 5 Report of the Executive Director 15 Legislative Update 17

Consent Calendar 19

ACTION ITEMS

United States Department of the Interior, 20 Memorial Avenue, Washington, DC – New Monumental Arch

United States Department of the Interior, 181 National Park Service, National Capital Region , Civil War Defenses of Washington General Management Plan Amendment

United States Department of Defense, 210 Department of the Air Force, 20 MacDill Boulevard, SE, Washington, DC – District Department of Transportation South Capitol Street Trail

Adjourn

P-R-O-C-E-E-D-I-N-G-S

(12:29 p.m.)

CHAIRMAN SCHARF: Good afternoon and welcome to the National Capital Planning Commission's June 4th, 2026 open session. First, Madam Secretary, could you please take the roll call?

MS. HOTTEL-COX: Yes. Commissioner

Cozart? COMMISSIONER COZART: Here. MS. HOTTEL-COX: Commissioner Bruch? COMMISSIONER BRUCH: Here. MS. HOTTEL-COX: Commissioner Bowron? COMMISSIONER BOWRON: Here. MS. HOTTEL-COX: Commissioner Argo? COMMISSIONER ARGO: I'm here. MS. HOTTEL-COX: Vice Chairman

Levenbach? VICE CHAIRMAN LEVENBACH: Here. MS. HOTTEL-COX: Chairman Scharf? CHAIRMAN SCHARF: Here. MS. HOTTEL-COX: Commissioner

Ingrassia?

COMMISSIONER INGRASSIA: Here.

MS. HOTTEL-COX: Commissioner Dixon?

COMMISSIONER DIXON: Here.

MS. HOTTEL-COX: Commissioner Cash?

COMMISSIONER CASH: Present.

MS. HOTTEL-COX: With those present, Mr. Chairman, we have a quorum.

CHAIRMAN SCHARF: Thank you, Madam Secretary. Noting the presence of a quorum, I'd like to call this meeting to order.

Today's meeting is live streamed and will be -- the video of it will be available on our website within a few days, as is our custom. If there's no objection, the agenda as posted is adopted as the order of business.

And now let's all stand for the Pledge of Allegiance. (Pledge of Allegiance.) REPORT OF THE CHAIRMAN CHAIRMAN SCHARF: Thank you all. Agenda item number two is the Report of the

Chairman, which is me. I'd like to say a few things before we get started.

First of all, this is the last meeting that we will have before we celebrate the 250th birthday of the United States of America.

As you all know, the United States of America is the oldest currently operating republic in the world. If anybody cites San Marino in contrast to that, I will fight you on the history of that point but I think it's really a remarkable milestone that this republic conceived in liberty has lasted as long as it has and is going as strong as it is.

As I've said at a number of previous meetings, Washington, D.C., as a city was conceived and in fact functions as the way that America holds itself out to the world.

And I think in light of that, the work that this Commission does is incredibly important, both to the city of Washington, D.C., and the region as it currently stands, and also to the expression of this nation's history that

this city often encompasses.

It's been a tremendous honor to lead this Commission over the last year. I was appointed to this Commission and designated as chairman almost exactly a year ago now. I guess -- I may be about a month short. I think next meeting will be over a year, but this is my last meeting before we hit that year-long milestone.

And it's just truly been an honor to get to work on the projects that we work on, whether it's the big stuff, Southwest D.C., Pennsylvania Avenue, or the smaller features that often pass unnoticed, 5G installations on the roofs of buildings, renovations to various park sites.

It's all important because this city is important to our nation. And I think the 250th anniversary of the Declaration of Independence is a good milestone and a good opportunity to reflect on what this city is and what this Commission does.

I think it's particularly fitting in

light of that, that two of the projects we have before us today are the Monumental Arch, which is intended to commemorate 250 years of American history, and also renovations to the Civil War defenses around this city.

I think it's important to remember that America has confronted great challenges over its 250 years; I think the Civil War probably foremost in that set of challenges. And I think there's a nice symmetry in a way, almost, for us to be looking -- symmetry is probably the wrong word, but some nice symbolism in that we're looking at these two projects as we approach our nation's 250th.

I'll also note, with respect to the Arch project, there was a site visit today that our staff arranged. I was very sorry to miss that site visit down to Memorial Circle and Arlington House. My other job pulled me out of that this morning.

I did see pictures on Commissioner Ingrassia's Instagram account, though. It

looked like y'all got some great views of the relevant viewsheds, and I just wanted to express my appreciation to NCPC staff for setting that up for the benefit of the Commission.

I've been down to that site on my own a number of times in the last few months, and really understanding the viewsheds and understanding the physical space, as with so much that we do on this Commission, is vitally important. So thank you for setting that up.

Today, we will be considering, or we will be voting, on comments on the concept plans for the Arch. I'll note for those present that this is not our final review of the project. That will come at a later meeting.

Looking forward, I'm excited to hear the presentation today. We have a relatively large number of individuals who've signed up to testify publicly on this project. I'm excited to hear that testimony as well.

One of those individuals even sent us pretty detailed architectural plans of their own

vision of how the Arch could be constructed differently, which I appreciated. We're going to have, as we have with all projects that come before us, a thorough process on this project, and I'm excited to get to go through that process with our Commission as we approach, ultimately, a final decision on that issue, or on that project.

I will say we've received media outreach in the last few days, in particular on an issue I'd like to speak about at a bit more length, and that's the applicability of the Height of Buildings Act to this project.

In the Executive Director's Report, or in the comments that we'll be voting on to approve today, we asked the applicant to address the Height of Buildings Act in the context of this project, and I'm excited to see the applicant -- assuming we approve the proposed comments, I'm excited to see the applicant do so.

I will note that 40 U.S.C. 8222(D),

which is in our organic authorizing statute, requires us to consider the height of projects when we vote on them, the height of projects in addition to a number of other features, and that is an obligation of ours. I'd also note that National Capital Planning Commission's traditional position has been that the Height of Buildings Act is enforceable against federal projects.

Meghan, our General Counsel, flagged this issue for me when we first received this project submission, and I've thought deeply about the issue of the Height of Buildings Act and its applicability.

On reflection, I find that NCPC's position is a little odd to me from a legal perspective. The Height of Buildings Act is codified as part of D.C.'s local zoning code. Traditionally, federal projects are not subject to local zoning requirements in that way, for reasons of the Supremacy Clause and other aspects of our system of ordered federalism

separation of powers, to be sort of blunt.

Applying the Height of Buildings Act as mandatory would also raise serious issues of sovereign immunity. The Height of Buildings Act includes both civil and criminal penalties enforceable in D.C. local courts against anyone who builds a building in violation of the Height of Buildings Act.

Typically, you would expect to see in a statute waiving sovereign immunity, an explicit waiver, which we don't have here.

Additionally, giving local D.C. courts jurisdiction over the federal government in that way, original jurisdiction over suits against the federal government, would be a departure from usual constitutional practice. Having realized this, I went down a very weird rabbit hole of studying every prior waiver granted by Congress against the Height of Buildings Act and the history of that act.

And I discovered an interesting historical quirk, which is that in 1930, two

projects, both of which exceed the limits prescribed by the Height of Buildings Act, were constructed, or construction began on two projects.

One was in addition to the Masonic Temple here in Washington, D.C., for which a congressional waiver was sought and which Congress approved. The other was the construction of the National Archives Building, which at 166 feet tall, exceeds the Height of Buildings Act, and no congressional waiver was ever sought for that, and Congress didn't speak to that.

I think that certainly raises the question about whether NCPC's longstanding position as to the mandatory nature of the applicability of the Height of Buildings Act to federal construction is in fact a correct reading of the law, and I hope that the applicant team will provide clarity to us as we go forward in the form of some sort of legal opinion or legal rationale or justification so

that when and if this project comes before us for final approval, this Commission can vote fully informed as to the legal issues that the Height of Buildings Act and the Height of this project implicate.

All that having been said, my view is that while this Commission should certainly consider the Height of Buildings Act in the context of our statutorily required consideration of the height of buildings that come before us, I believe, speaking personally, that the best reading of the law is that the Height of Buildings Act is not applicable to federal construction.

This is all a bit premature. I think that there's nothing about the presentation today or the action requested of this Commission today that requires us to fully consider this weighty issue at this time, but I did want to preview that for the Commission and for the project team who I know are present so that by the time this project comes before us for prelim

or final or prelim and final, that we have more guidance on this issue so that we can consider it fully as a commission.

All that having been said, it's great to be back with you again this month. I'm looking forward to our open session agenda. And with that agenda item, excuse me, number three is the report of our Executive Director Marcel Acosta.

REPORT OF THE EXECUTIVE DIRECTOR

EXECUTIVE DIRECTOR COSTA: Thank you, Chair Scharf. Good afternoon. I'm pleased to introduce three student interns who have joined this agency this summer.

First, we have Jay Bisser, who's a senior undergraduate pursuing a bachelor's in Environmental Policy and Planning at Virginia Tech. Second, we have Sylvia Cabas, who's a second-year master's candidate in Urban and Regional Planning at Georgetown University. Sylvia holds a master's in International Relations from Johns Hopkins University and a

bachelor's in History from the University of California at Berkeley.

Finally, we have Simon Handelman, who is a second-year graduate student at Virginia Tech pursuing a master's in Architecture with a concentration in Urban Design. Simon earned a bachelor's degree in Political Science from George Washington University. Welcome, everyone, and we're pleased that you've joined us.

That concludes my report, and my full report is in your packet, and I'm happy to answer any questions that you might have.

CHAIRMAN SCHARF: That may be the most well credentialed group of interns I've ever heard of. Welcome. This Commission is an incredible organization with an incredible staff.

I hope you all have a great experience here this summer. How long are you guys with us for? The whole summer? Oh, great. So you'll get at least one more meeting under your belt

before you leave us. Well, thank you for joining us.

Thank you for the work that you'll hopefully do in the forthcoming months, and obviously, if there's anything any of us can do for you all, please reach out and please let me know.

With that, do any commissioners have any questions or comments, either for Marcel or for our three interns? When I was in law school, it was called a cold call. I mean, this is -- hearing and seeing none. Agenda item number four will be the legislative update. Meghan, do you want to proceed?

LEGISLATIVE UPDATE

MS. HOTTEL-COX: I don't have any specific items to provide an update on this month, but I'm happy to answer any questions about pending legislation.

CHAIRMAN SCHARF: Do any commissioners have any questions about pending legislation? CONSENT CALENDAR

CHAIRMAN SCHARF: Hearing and seeing none, we'll proceed to agenda item number five, which is this month's consent calendar, for which we have two items. The first is an application from the D.C. Office of the Surveyor for approval of comments to the D.C. Council for the closing of a public alley in Square 571, and the second item is an application from the Department of the Navy for approval of a final master plan for the Naval Support Facility Suitland final area development plan and transportation management plan updates.

Are there any questions or comments from commissioners or matters of discussion from commissioners on these items on our consent calendar? Hearing and seeing none, is there a motion to approve the consent calendar as stated?

COMMISSIONER COZART: I motion to approve the consent calendar as stated.

CHAIRMAN SCHARF: Thank you, Commissioner. Is there a second?

COMMISSIONER ARGO: Yeah, I second it. CHAIRMAN SCHARF: Thank you,

Commissioner. Madam -- is there any discussion on this item before we proceed to a vote, or on this motion before we proceed to a vote? Hearing and seeing none, Madam Secretary, could you please confirm the motion and the second and take the vote by roll call?

MS. HOTTEL-COX: Yes. The motion was made by Commissioner Brooke and seconded by Commissioner Argo. Commissioner Cozart?

COMMISSIONER COZART: Yes.

MS. HOTTEL-COX: Commissioner Bruch?

COMMISSIONER BRUCH: Yes.

MS. HOTTEL-COX: Commissioner Bowron?

COMMISSIONER BOWRON: Yes.

MS. HOTTEL-COX: Commissioner Argo?

COMMISSIONER ARGO: Yes.

MS. HOTTEL-COX: Vice Chairman Levenbach?

VICE CHAIRMAN LEVENBACH: Yes.

MS. HOTTEL-COX: Chairman Scharf?

CHAIRMAN SCHARF: Yes. MS. HOTTEL-COX: Commissioner

Ingrassia? COMMISSIONER INGRASSIA: Yes. MS. HOTTEL-COX: Commissioner Dixon? COMMISSIONER DIXON: Yes. MS. HOTTEL-COX: Commissioner Cash? COMMISSIONER CASH: Yes. MS. HOTTEL-COX: The motion carries. CHAIRMAN SCHARF: Thank you, Madam

Secretary. ACTION ITEMS

CHAIRMAN SCHARF: With that, we'll move on to our open session items for today. We have three items scheduled.

UNITED STATES DEPARTMENT OF THE INTERIOR, MEMORIAL AVENUE, WASHINGTON, DC

– NEW MONUMENTAL ARCH

CHAIRMAN SCHARF: Agenda Item 6A is a request to approve comments on concept plans for the new Monumental Arch, and we have Jamie Herr from our team to present on that, and I believe

we have members of the project team present as well. Is that correct? I think so. Great. Jamie, whenever you're ready.

MS. HERR: All right. Good afternoon, Chairman Scharf and members of the Commission.

The U.S. Department of the Interior has submitted concept plans for a new Monumental Arch and Memorial Circle in Washington, D.C. for Commission comment.

At this concept review stage, the Commission provides comments on the project and requests additional information that will inform the Commission's action at its future preliminary and final review stages.

The project is proposed for Memorial Circle, an existing traffic circle on Columbia Island in Washington, D.C. The project site, circled in green, connects the Arlington Memorial Bridge to Memorial Avenue and the George Washington Memorial Parkway.

The site on Columbia Island is in between the Boundary Channel and the Potomac

River. To the southwest is the Arlington National Cemetery and to the northeast is Lincoln Memorial.

Now I'll give a brief overview of the site history. The need for a bridge connecting the northern and southern shores of the Potomac River in the area of the Arlington Memorial Bridge was documented as early as the mid-1800s. The concept for the bridge and avenue first emerged after the Civil War and gained momentum when it was included within the McMillan Plan, which proposed improvements to the Washington, D.C., park system.

According to the Cultural Landscape Report published by the National Park Service, the Memorial Avenue corridor was designed as a symbolic and physical link between the Lincoln Memorial, a tribute to the 16th American President, the entrance to Arlington National Cemetery, and Arlington House, the former plantation home of Confederate General Robert E. Lee.

The design of the corridor took shape amongst the City Beautiful movement, which promoted formal and classical treatments for architectural, engineering, sculptural, and landscape features, all of which were incorporated into the evolving designs for the Arlington Memorial Bridge and the Memorial Avenue corridor.

The corridor was built in phases. The Arlington Memorial Bridge was constructed between 1926 and 1932. The Boundary Channel Bridge was built between 1929 and 1930. Memorial Avenue was built beginning in 1930. And finally, Memorial Circle was constructed on Columbia Island in 1940.

Memorial Circle was designed as part of the western terminus of the Arlington Memorial Bridge as a means to connect to the George Washington Memorial Parkway, Arlington Boulevard, and Memorial Avenue.

The connections to and around Memorial Circle have changed significantly over the

years, as shown here in this progression from 1940 to 1966 and to 1988, which leads us to the current conditions with several connecting roadways at and below grade around the circle connecting to a variety of roadways.

Now I will review the existing site conditions in more detail. Safety improvements were completed at Memorial Circle in 2006 and 2007 that reduced the number of lanes around the circle. Along the north and south sides of the circle, the outermost travel lanes were replaced with concrete shoulder lanes. These were later replaced with pavers that remain today.

You can see in this 2016 image that the park police were adding digital signage and traffic cones to manage the traffic. Additional work in 2020 reduced the travel lanes in the circle to one, changed the paving materials, modified connecting roadways, and changed the pedestrian access and roadway efficiency by splitting this traffic island shown here in this image from 2025.

The most recent design changes I just noted from 2020 were intended to improve transportation safety at and near Memorial Circle while maintaining the memorial character of the area.

The goals were to reduce risks at key locations within the corridor and to reduce conflicts between trail, walkway, and roadway users. These changes including splitting the eastern traffic island to create continuous vehicular movement as shown here.

The changes restricted pedestrian access around the circle and currently there is no pedestrian access across Memorial Avenue on the east side of the circle or to the center of the circle itself.

Now with that as background, I will review the proposed design. The applicant is proposing a 250-foot tall arch as shown here in this rendering. According to the applicant, the purpose of the arch is to celebrate the triumphs of the American spirit, inspire patriotism and

love of country, and beautify our nation's capital.

The proposed arch consists of an arch structure with two legs at the height of 166 feet to the top of the mezzanine. The observation deck and statuary plinth is 24 feet above that and the larger central statue is 60 feet tall.

The exterior of the proposed arch will be primarily clad in stone. The vertical faces of the arch include several recessed or framed spaces that would typically house statuary or relief sculpture, though no specific details on these spaces has been provided.

The top area of the arch includes gold lettering quoting the American Pledge of Allegiance on both east and west facing sides. Above the primary arch structure and mezzanine is a recessed area housing the observation deck interior space and above that the proposed statuary.

Proposed statues include the 60-foot

tall central gold statue flanked by smaller gold eagles on each side. All the statuary is facing east toward the Lincoln Memorial. There are also additional gold decorative elements on the underside of the arch and on each vertical face.

The proposed interior of the arch includes ticketing and security, back of house space, stairwells, and elevators in the south leg with an exit hall, back of house space, stairwells, and elevators in the north leg at the ground level.

The plans include a stair hall, restrooms, program spaces, and stair and elevator lobbies in the mezzanine. Two of these staircases and one of the elevators in the center of the mezzanine provide access to the observation deck above.

Per the submission materials, the proposed arch sits within a plaza that includes granite pavers encircled by a seat wall and two pedestrian access points aligned with bollards. These two access points face east and west

aligned with the opening of the arch.

This enlarged detail of the proposed site plan shows the proposed apron, planting strip, stone barricade seat wall, granite pavers, and bollards proposed.

The circle is shown with new pedestrian crosswalks and post-mounted pedestrian actuated signals connecting visitors via pedestrian refuge islands next to the traffic circle.

Pictured here on the east side, two new crosswalks will start at the landing of the Memorial Bridge, crossing traffic onto a refuge island before crossing the circle drive lane into the arch plaza.

The applicant has stated the pedestrian actuated signals, pictured to the right, will be used to control vehicular traffic and allow pedestrians to use the various crosswalks.

And now I will review the vehicular and pedestrian accessibility topic and our recommendations.

As previously stated, the National Park

Service updated the design for Memorial Circle both in 2007 and 2020 to address efficiency and safety. Currently there is no pedestrian access via crosswalks to the circle or across Memorial Avenue on the east side of the circle.

The circle also sees heavy volumes of traffic, especially on the east side, from northbound Washington Boulevard to eastbound Memorial Bridge and from the bridge to northbound Arlington Boulevard. Both of these movements have continuous lanes around the east side of the circle.

The applicant is showing a change to the current design of the vehicular and pedestrian access to and around Memorial Circle as noted here.

As the arch is intended to be a visitor destination, a memorial circle is an integral part of the vehicular access between the Arlington Bridge and the George Washington Memorial Parkway with significant traffic volume. It will be important to ensure the

continued safe operation of the traffic network as well as the safe passage of visitors.

The applicant has indicated that they are working with several agencies to evaluate the transportation network to accommodate visitor access and minimize impacts to the road network.

Therefore, staff suggests the Commission recommend the applicant work with the Federal Highway Administration, District Department of Transportation, Arlington County, and other agencies as appropriate regarding any proposed changes or impacts to the social surface transportation network.

The plans do not provide details regarding visitor parking, loading, unloading, and ADA access. As the project introduces a visitor attraction to Memorial Circle, additional information is necessary to ensure the safety of those accessing the site and the minimizing impact of vehicular travel around the site.

As such, staff recommends the

Commission request the applicant submit for the next review a transportation or traffic study that identifies any potential impacts of the proposed project on the road network and level of service and evaluates proposed pedestrian access to ensure visitors can avoid pedestrian and vehicular conflicts and information regarding parking and loading and unloading for visitors to the arch to ensure safe access for those of all abilities and minimize disruption to the traffic network.

Next, I will review visitor safety and recommendations. The proposed arch is shown with an at-grade plaza surrounded by a seat wall with openings with bollards for pedestrian access aligned with the openings of the arch.

The submission includes some security elements including the seat wall, bollards, and security in the ticketing space. The seat wall as a security element is consistent with integrated design elements that NCPC policies

support. The seat wall is a security element.

Additional information regarding the overall risk and security approach will be helpful as part of the next review. Therefore, staff recommends the Commission support the use of the seat wall as a design security element around the arch plaza and requests a risk assessment and evaluation of the project to ensure the proposed design will address security considerations.

Next, I will review aviation safety and recommendations.

The location along the Potomac River is 3,000 feet from Ronald Reagan Washington National Airport near landing approaches for two runways. Part 77 of the Code of Federal Regulations outlines requirements for any construction that is more than 200 feet above ground level to file notice with the FAA.

The purpose is to determine whether the proposed construction would be a hazard to air navigation. The applicant has indicated they

are currently working with the FAA to evaluate whether the proposed project would impact air navigation given its proximity to Ronald Reagan Washington National Airport.

Any recommendations that are identified by the FAA review process should be incorporated into the design prior to the Commission's final action. Therefore, staff suggests the Commission recommend the applicant continue consultation with the FAA to evaluate potential impacts of the proposed project on air navigation and provide an update to the Commission as part of the next review and advises that any design recommendations provided by the FAA should be incorporated into the proposed project prior to the Commission's final action.

The next section will cover viewsheds and related recommendations.

The proposed location of the arch is at the center of Memorial Avenue and the sight line, design, and landscape features of Memorial

Avenue, which includes Memorial Circle, are contributing elements of the National Register-listed Arlington National Cemetery Historic District and Arlington Memorial Bridge.

The panoramic views from Arlington House at Arlington National Cemetery to the west and the Lincoln Memorial to the east have been in place since the 1920s and reflect the visual connectivity characteristic of the McMillan Plan. This alignment from the Lincoln Memorial to Arlington House was originally designed as a memorial symbolizing reunification of the North and South after the Civil War.

The bridge and Memorial Avenue serve as the ceremonial entrance to Arlington National Cemetery, the nation's most hallowed ground and the final resting place for more than 400,000 service members, veterans, and family members.

The applicant has included several before and after views of the proposed arch in the submission. This first view on the left shows the current view of the Arlington House

along the axis of Memorial Avenue toward the Lincoln Memorial and beyond. The view on the right shows the proposed arch in Memorial Circle.

As noted, the rendering from the submission indicates that the proposed arch will block the view of the Lincoln Memorial from Arlington House.

This is the existing view on the left from the Lincoln Memorial Circle looking west toward Arlington House. This is the rendered view on the right of the proposed arch in Memorial Circle. This proposed view alters the view of Arlington House and Arlington National Cemetery from the Lincoln Memorial.

This is the existing view from Parkway Drive northwest along the edge of the Potomac River looking southwest towards Arlington Cemetery on the left. On the right, this is the rendered view of the same location with the proposed arch.

On the left is an existing view from

the Lincoln Memorial Terrace looking west and on the right is the rendered view with the proposed arch.

Given the importance of these views, staff suggests the Commission encourage the applicant to provide as part of the Section 106 process of the National Historic Preservation Act any design options that were explored to avoid or minimize impacts on the visual connection between Arlington House and the Lincoln Memorial.

In addition, staff suggests the Commission request the applicant provide as part of the next review updated photo visualizations of existing and proposed pedestrian level views from additional locations noted here. A view from the north steps of the Jefferson Memorial looking toward the Lincoln Memorial. Views from the George Washington Memorial Parkway, one looking south toward the circle from a point immediately south of I-66 and one looking north toward the circle from a point near the LBJ

Memorial Grove.

In this section, I will review recommendations on design development.

Consistent with Comprehensive Plan policy, the Commission has historically focused on preserving Washington's picturesque horizontal character and reinforcing the Height of Buildings Act.

The Height of Buildings Act of 1910, amended in 2014, is a federal law that limits building height and NCPC has always applied the Height of Buildings Act to federal projects.

The project appears to include a combination of habitable space and architectural embellishments at a height of 250 feet. As such, further information will be necessary to understand how the project comports with the Height of Buildings Act. As such, staff suggests the Commission request the applicant provide as part of the next submission an analysis and justification for the project's height in light of the Height of Buildings Act.

This submission does not yet include information on any proposed lighting, stormwater management approach, and most of the site and building materials. These are necessary elements for the Commission to review as the design advances.

Therefore, staff suggests the Commission recommend the applicant work with the District Department of Energy and Environment regarding the proposed stormwater management approach and requests the applicant provide as part of the next submission information regarding the following topics.

The proposed arch and site materials palette, including cladding, paving, pedestrian features, and security elements. The proposed lighting strategy, including nighttime renderings from key views demonstrating the lighting concepts in context, and the proposed stormwater management strategy.

Finally, our recommendations for the applicant to consider in terms of project

coordination that were not previously mentioned.

NCPC has an independent responsibility to comply with the National Historic Preservation Act and the National Environmental Policy Act. NCPC intends to designate the applicant as the lead federal agency for the purposes of compliance. NCPC will not take a final action until both these processes have been completed.

As such, staff requests the Commission recommend the applicant work with the District of Columbia State Historic Preservation Office and other consulting parties regarding the National Historic Preservation Act Section 106 process and recommends the Commission request that the applicant provide as part of the next submission updates on the Section 106 process and the NEPA evaluation process as completion of both are required for NCPC final action.

This concludes the presentation. As noted previously, at this concept review stage, the Commission provides comments and requests

additional information from the applicant that will inform subsequent Commission review. I've incorporated these recommendations into the presentations, so I will not read them again, but they are included here for your reference.

In conclusion, staff recommends the Commission approve the following concept comments on the proposed monumental arch located in Memorial Circle on Columbia Island in Washington D.C.

Finally, I do want to acknowledge that NCPC has received a substantial number of public comments on the project. The vast majority of the comments received were in opposition and the most common concerns related to the impact to the setting of Arlington National Cemetery, views, height, and scale, and safety.

The applicant team and the architect are here to answer any questions the Commission may have and staff is available as well. Thank you.

CHAIRMAN SCHARF: Thank you, Jamie. Do

any commissioners have any questions either for Jamie or for the project team? Yeah, Commissioner.

COMMISSIONER CASH: I do want to ask, so has this -- it's gone through CFA, it's now coming through NCPC. Most projects like this that I think of as memorials or commemoration go through NCMAC, the Memorial Advisory Committee. Has this gone through that process? Is this considered a memorial? What is this -- like what processes is it going through, other than us and CFA?

MS. HERR: So, the question on the Commemorative Works Act is one that NCPC has historically deferred to the applicant agency on complying with, and in this instance they have advised that the Commemorative Works Act does not apply, and so therefore the -- we're deferring to their determination that the Commemorative Works Act doesn't apply here.

COMMISSIONER CASH: Okay. That leads me a bit to a follow-up question. So, in the

staff report I noted that it said the purpose of the -- according to the applicant, the purpose of the arch is to celebrate the triumphs of the American people, inspire patriotism and love of our country, and beautify our nation's capital.

Is that in some kind of congressional finding, some kind of finding by a commission set up to set up this non-memorial -- like where does that finding come from, or is it just what the applicant put onto the application?

MS. HERR: It's just what we've been informed by the applicant.

COMMISSIONER CASH: So, this isn't any kind of -- this is just the applicant saying this is patriotic and it's not like -- this didn't go through Congress or anything like that?

MS. HERR: It did not.

COMMISSIONER CASH: Okay, thanks.

CHAIRMAN SCHARF: Yes, ma'am.

COMMISSIONER COZART: So, I think this is for the project team. Wanted to know what

the timeline was for initiating Section 106.

CHAIRMAN SCHARF: Yep.

PARTICIPANT: We don't have a timeline set just yet. We're going through the processes, and it'll be when we receive approval. Then we'll be able -

COMMISSIONER COZART: I'm sorry, it's when you receive approval? I don't think your mic is working.

PARTICIPANT: Oh, sorry.

COMMISSIONER COZART: You said -- could you repeat your response?

PARTICIPANT: Yeah, the -- we're going to be going through the -

PARTICIPANT: We can't hear.

PARTICIPANT: I'm not a tech guy, I apologize.

PARTICIPANT: (Unintelligible) Department of the Interior. The Section 106 Initiation Consultation package will be given out to consultative parties tomorrow.

COMMISSIONER COZART: Thank you.

CHAIRMAN SCHARF: Any other questions for -- yeah, Stuart.

VICE CHAIRMAN LEVENBACH: I have one. So, what kind of data are generated in the traffic study? Because one thing I noticed is that cars don't necessarily use that circle to that same extent as you go all the way around. So, if you're trying to figure out how to route pedestrians, what types of data are generated and how would you use it in order to figure out access to the monument?

PARTICIPANT: Yeah, and I'll speak loudly so I can make sure if you guys don't hear me back here, just lift up your hand.

So, we've been working with the Department of Transportation in Volpe Center, which is the leading governmental agency -

PARTICIPANT: We can't hear.

PARTICIPANT: All right. Thank you. City is -- we're working with the Department of Transportation in Volpe Center, which is the leading governmental agency as relates to

traffic studies.

So, from the studies that have been conducted in coordination with the Federal Highway Administration, the south side of the circle experiences the least amount of traffic. There are several movements on the circle that do experience the most amount of traffic, particularly during peak hours.

That is when you're going northbound from Washington Boulevard over the bridge and then subsequently later in the day, you get the westbound traffic over Arlington Memorial Bridge and then northbound then onto Arlington Boulevard.

So, that is one of the things that we'll be addressing subsequently is those traffic movements and making sure that has the least amount of impact in coordination with the signalization.

So, right now, coming north on Arlington Boulevard, it's the Rapid Beacon. So, if you get a lot of pedestrians, it's not

actuated right now, but it's constantly beeping.

Thank you.

MS. HOTTEL-COX: Is it on?

PARTICIPANT: Hello?

CHAIRMAN SCHARF: No, no difference.

PARTICIPANT: Okay. So, right now, it's Rapid Beacon signalization. So, if you don't actuate it, it automatically detects pedestrian movement, which then results in the flash that's going up and the traffic then comes to a stop.

What we're contemplating for both the construction phase as well as for the ultimate completion of the arch, that would be pedestrian actuated. So, one of the main considerations, though, is you don't want traffic building up, so there will be a minimum of run green time (phonetic).

So, if there's multiple lines of people coming up, you just can't keep up with the signalization and have traffic come to a complete stop. So, it would be a minimum of run

green time, traditionally, that's 80 seconds, but after 80 seconds of one green time, if a pedestrian comes up and pushes it, and the traditional walk/stop, the walk time would come up and then the pedestrian would be able to cross.

CHAIRMAN SCHARF: Can I ask a total -do you have a follow-up, Stuart? What's the arch made out of? Like, what's the building material?

PARTICIPANT: So, the structure will be cast-in-place concrete.

CHAIRMAN SCHARF: Okay.

PARTICIPANT: That will be the majority of the structure, and then the cladding will be granite. Now, we haven't selected the exact type of granite yet, but those under consideration are Sierra White, Mount Airy, which is the composition mostly of the bridge, and then also Bethel White, which would be Union Station and Natural History Museum (unintelligible).

CHAIRMAN SCHARF: And then the gold ornamentation, I'm guessing that's something plated with gold?

PARTICIPANT: Yes, it'll be a silicon bronze, and then we'll have them go -- much like the statues on the other end of the bridge that (unintelligible).

CHAIRMAN SCHARF: Is there a concern with sort of tarnishing of the gold over time, or what does that look like as the -- you know, 20 years from now, how different is it going to look than it does in the -

PARTICIPANT: So the Arts of War were

-they were recently renovated in, I think, the 1970s, so they're coming up and they're being renovated now. So, the restoration is required on gold plating over probably the course of 30 to 40, 50 years.

CHAIRMAN SCHARF: Okay. So that's a pretty long run time as these things go. The FAA study, what's the status of your guys' consultations with FAA?

PARTICIPANT: That's ongoing.

CHAIRMAN SCHARF: Okay.

PARTICIPANT: So, FAA has already compiled a preliminary finding for the arch at 250 feet. Those studies will be incorporated into the environmental assessment as an appendix for you all to see.

CHAIRMAN SCHARF: Great. And then, I guess, last question, and this may be for the architect, for Mr. Charbonneau, was any thought given to making the arch taller and the statuary shorter? Or, I guess, how did you all arrive at the proportions? I know -- I like the goal of reaching 250 feet total, but sort of how did that kind of come together?

PARTICIPANT: There's some historic precedent for monumental architecture on Columbia Island. So, part of the proposal to make it white for the bridge -

CHAIRMAN SCHARF: Right.

PARTICIPANT: -- included columns with sandstone on top of them. The height of those

columns were 166 feet, so we're referencing the

history of the site.

CHAIRMAN SCHARF: Gotcha.

PARTICIPANT: Having the arch proposed at the same height. So, to answer your question, no, we've looked at this (unintelligible).

CHAIRMAN SCHARF: Gotcha.

COMMISSIONER DIXON: Mr. Chairman?

CHAIRMAN SCHARF: Yes, Commissioner Dixon.

COMMISSIONER DIXON: Yeah, I have two or maybe three questions. First, is there any maintenance issues in terms of long-term maintenance being dealt with or looked at? Secondly, the bollards could be maybe replaced with some more useful, like chairing that also offers a similar protection, but give tourists a place to relax rather than -- or be useful devices.

The other thing, I was kind of curious about how this arch compares with other arches

that are around the globe. You know, are we unique enough or what it might compare, how it would compare. Those three questions, Mr. Chairman.

PARTICIPANT: So, the first one in terms of maintenance, that's why we had selected granite for the exterior cladding. Granite has a compressive strength reaching 3,500 psi and a very low water absorption rate. So, the exterior materials are selected for the longevity, including the silicon bronze.

The other question regarding a place for the pedestrians and visitors to sit, there is a seat that goes around the entire perimeter on both legs of the arch, and then we have a seat wall, which is on the perimeter of the circle as well.

So, there'll be ample places for pedestrians to have a rest.

COMMISSIONER DIXON: But is there still a need for the bollards if those devices are there?

PARTICIPANTY: Yeah, the bollards, it just didn't seem appropriate to have a seat wall going around the entirety of the circle, and that if there was ever to be a procession, that the east and the west sides of the seat wall would be open.

CHAIRMAN SCHARF: And then the last question was comparing the size of this arch to other, sort of, other examples around the world.

PARTICIPANT: The size, it probably most, the Arc de Triomphe is probably the closest in terms of size and composition. It lacks any kind of ornamental columns on it, and that was specifically chosen because this arch was to feature narrative sculpture on the outside, so that the columns interrupted the space for that. That's why we selected it without any columns on it but historically, triumphal arches would have ornamental columns on the outside.

CHAIRMAN SCHARF: And I would note that this arch is less than half the height of the

Gateway Arch in my hometown of St. Louis, Missouri.

PARTICIPANT: It's not even comparable. It sits by the river.

CHAIRMAN SCHARF: Are there any other questions for either Jamie or the project team? Paul, Commissioner Ingrassia?

COMMISSIONER INGRASSIA: Thank you, Chair. Just a quick question about the inside of the arch. If you could -- you know, we have these great visuals, how it will look on the exterior, but maybe you could talk a little bit more about, you know, how large you expect the inside to be, how visitors might navigate up to the top, to the observatory deck. You know, someone who's been to the Arc de Triomphe in Paris, it could be a little tricky navigating to the top, so maybe you could talk a little bit about accessibility and how visitors plan to enjoy their time there.

PARTICIPANT: I mean, I could talk through it, but it's a little bit easier than

usual. So the arch is entered on one side. So the idea is that visitors will circulate up one leg, and then they could go to the observation deck and then circulate back down on the other leg.

So it's kind of a circuitous movement through, and that will address security concerns because, you know, we want to be able to screen visitors as they enter.

CHAIRMAN SCHARF: There we go.

MS. HOTTEL-COX: You need a mic.

PARTICIPANT: So on the south side, we have the ticketing security. So this would be the main entrance as folks enter into the arch. They'll have the opportunity of either taking this elevator or this one, or they could also take a stair all the way up if they'd like to.

Once you're up, now you've got to cross over to the center, and so that happens on an upper level. So this is really just below the observation deck, this floor plan here.

So you come in, you've got a space here

which you would enter into, and then there's a stair hall. So there's two stairs on either side and then an elevator in the center, which would go up within the center of the statue base on the upper floor on the observation deck.

So these stairs will lead out into a stair hall as well as the elevator, and then the observation deck that can be accessed either on the east or the west, the doors leading out to either side.

And then this area here in its entirety is open for visitors to be able to observe basically a 360-degree view of the surrounding area.

Visitors, when they're leaving, would come down on this set of stairs and these elevators, and then they'd come out on the ground level on the north side and then to an exit hall and then come out.

So just want to make sure that there's safety features in place for anybody coming in, and then the traffic flow can go through.

The Park Services estimated that they'd be able to accommodate probably about 80 occupants per hour, so similar to the Washington Monument.

So that's the spaces, the public spaces would have some level of ornamentation. There's also opportunities for exhibit spaces, particularly on the upper level.

CHAIRMAN SCHARF: And have we seen renderings of what the views will be like from the observation deck? Have those been submitted to us?

MS. HOTTEL-COX: They were not submitted to us.

PARTICIPANT: Those are not, but we now have them, and we can include them in the next submission package.

CHAIRMAN SCHARF: My guess is that it's a pretty stunning view, and I think that would be helpful as we sort of -- as we consider this project going forward. Are there any other questions either for Jamie or -- yes,

Commissioner.

COMMISSIONER CASH: So a couple things. Actually, Commissioner Dixon's question about how this compares to other arches just kind of got me back to some research I was doing earlier, and my earlier question about what does this commemorate.

And I was looking up, so for example, the Arc de Triomphe commemorates Napoleon's military victories. The India Gate recognizes fallen soldiers. The Monumento de la Revolucion is the Mexican Revolution, and Washington Square Arch is Washington's inauguration centennial.

Again, we're kind of left without anything. But I did want to take just a point of privilege for D.C. laws, because you did mention this during your opening, the Height of Buildings Act. And I just wanted to ask through the Chair to the General Counsel.

So the Height of Buildings Act, the Chair mentioned this is essentially a local law, but could you clarify whether the D.C. Council

or any of the local authorities have any ability to change that law, or if it's purely Congressional and that the Council is prohibited from having any kind of review over that?

MS. HOTTEL-COX: Sure. So it is a federal law. The Council does not have any authority to amend the Height of Buildings Act, and it is one that I believe Jamie said in the presentation was amended as recently as 2014.

And as the Chair noted, NCPC has historically taken the position that the Height of Buildings Act does apply to federal projects. I'm happy to share some of that background, but I'm also happy to supplement that for the next filing.

COMMISSIONER CASH: Sure. And the Chair also mentioned enforcement of the Height of Buildings Act would be by local authorities or the local courts. Could you clarify whether the local courts are appointed by the President or the Council or have any local ties or jurisdiction?

MS. HOTTEL-COX: By the President.

COMMISSIONER CASH: Thank you.

CHAIRMAN SCHARF: Anything further? With that, we'll proceed to the public testimony that we have on this item.

Thank you, Jamie, by the way. That was comprehensive and informative as always. We have 30 people signed up to speak on this matter, a combination of in-person and virtual.

We're going to hear from witnesses in groups of five, reserving any questions that the Commission has for members of the public until after we make it through those five witnesses, just to keep things rolling.

Our first witnesses -- oh, as is our custom here, individuals speaking on behalf of themselves will be given three minutes. Individuals speaking on behalf of an organization will be given five. To keep things moving, we will enforce those restrictions pretty rigorously.

Our first five witnesses are, I'm going

to butcher some of these pronunciations and I apologize in advance for that, are Edward Stierli, Priya Jain, William Vaughn, Susan Douglas, and Gary Langston.

Mr. Stierli, who I believe is here in person, is representing the National Parks Conservation Association.

Sir, if you want to take the podium, you have five minutes and please proceed when you're ready.

MR. STIERLI: Thank you. Good afternoon. I'm Ed Stierli. I'm the Mid-Atlantic Senior Regional Director for the National Parks Conservation Association.

NPCA, we're a non-profit, non-partisan organization. We have 1.9 million members and supporters around the country and we've advocated on behalf of the National Parks and the National Capital Region for decades.

We submitted detailed written comments, but I'm going to pretty much hit the high notes and underscore what I think you should all hear

before you advance this proposal.

And just to be clear about something up-front, I mean, NPCA, we support, strongly support, commemorating America's 250th anniversary of this country. We support investments that honor American history and that strengthen our national parks. But that is not what is before you today. What's before you today is a request to approve a 250-foot monumental structure on National Park Service land in what is the most significant commemorative landscape in the United States. And doing this without Commemorative Works Act process that Congress requires, without a completed environmental impact statement, without a Section 106 consultation under the National Historic Preservation Act.

And so this Commission, you know, as you advance this, you have the authority and the responsibility to say that that is not acceptable, and we urge you to exercise that as you advance this.

So, let me focus on three things. So,

first is the law, the law that was mentioned earlier, the Commemorative Works Act, which is not a suggestion. It was enacted by Congress in 1986, because, prior to that, you know, the ad hoc monument placement that was happening created the exact kind of conflict with what we're seeing right now before this Commission. The Area 1 requirements under that law require preeminent significance determination, consultation with the National Capital Memorial Advisory Commission, and congressional action. And, to our knowledge, none of those steps have been completed.

The Administration's argument, thus far, has rested on a 1920s bridge authorization for columns that were never built. But that authorization was directed to a now-dissolved commission to undertake a long-completed project, subject to a spending limit that's also been exhausted. So to treat that statute as the authorizing a massive and costly new project a

century later, really defies any reasonable reading of congressional intent. If a single authorization for one commemorative structure conferred perpetual authority to build limitless future monuments within the same vicinity, the monumental core of Washington would be chaos.

This Commission should require a legally supported demonstration that Area 1 process had been completed before taking any action to advance this proposal, because that's what the law requires.

Second, I want to talk about the physical reality of what this arch would do. You know, 30 funeral services are conducted at Arlington National Cemetery every single day; 400,000 veterans and their families are interred there. The landscape between the Lincoln Memorial and Arlington were deliberately designed to honor that relationship, as was discussed earlier.

The Arlington Memorial Bridge was built low, with classical restraint, precisely so the

view between the memorial and the cemetery would remain unbroken. That was not an accident. It was a civic act of design that took decades of planning.

A 250-foot arch at Memorial Circle, topped with the gilded statues and an observation deck, would be placed at the exact point where visitors transition from the Lincoln Memorial to the cemetery. Visitors approaching Arlington from Washington would no longer experience that measured, solemn procession across the bridge. They would instead pass through a structure that's at fundamental odds with the character of the ground beneath it.

You'll likely hear from a lot of veterans saying that this would dishonor their service, and their concerns deserve real weight here today.

Third, the viewshed. The western axis of the National Mall represents more than 120 years of very deliberate planning and legal protection, much of which has occurred through

this commission, if not all of it.

The McMillan Plan of 1902 established a compositional logic that every generation has built upon since. You know, long, uninterrupted viewsheds, which we enjoyed wonderful photos of. I know through the progression throughout history, I was more astounded at how little it has changed over time, and how remarkable that would be for any city in the world.

The Washington Monument was designed as a singular, vertical punctuation of this entire composition, and nothing of comparable scale has ever been introduced into the Mall in this corridor, except this arch now. That impact would be irreversible.

So, you know, I've heard it said, I'm still comparably to many -- I've only lived in this area for about a dozen years, and Washington is not a static city. There's been a lot of change. That's true. Washington has grown thoughtfully, deliberately, and through a lawful process that's protected its most

significant commemorative landscape, while making room for new expression. That's the framework that Congress built for the city, and, unfortunately, that's what is at risk of being bypassed here.

So, you know, we urge the National Capital Planning Commission, you all, to take -to decline to advance this project until Congress has authorized this memorial through a joint resolution, because they deserve the protection, and you have an obligation to provide it. Thank you.

CHAIRMAN SCHARF: Thank you, Mr. Stierli. Next up, we have Priya Jain, who's representing the Society of Architectural Historians, and who will similarly have five minutes to provide your testimony. I believe Ms. Jain is with us virtually. You can proceed whenever you're ready.

MS. JAIN: Okay. Good afternoon, Commissioners, and thank you again for the opportunity to speak. My name is Priya Jain,

and I'm a licensed architect in the State of Texas.

I offer these comments as a private citizen and as chair of the Heritage Conservation Committee of the Society of Architectural Historians. These views do not represent those of my employer, Texas A&M University.

The Society of Architectural Historians is a non-profit, founded in 1940, and is the leading organization for architectural history in North America. The proposal before you to build a new 250-foot monumental arch is in one of the country's most significant historical and urban ensembles.

After reviewing the submission made by the Department of the Interior, we feel that it negatively impacts the architectural context of its setting, disrupts views to existing historic monuments, and runs counter to decades of design and preservation guidance for this area prepared by none other than the applicant itself.

We want to begin by countering the claim that the architectural history of the site supports construction of tall, triumphal arches, or that the proposal respects the legacy of the 1901 McMillan Plan for Washington, D.C.

At the last Commission of Fine Arts meeting, the Department of the Interior presented various images of historic unbuilt bridges and monuments from 1877 to 1934, leading the Commissioners to note that the site has a history of heroic designs and this proposal builds on the McMillan Plan.

In fact, the architectural history of this area reveals the exact opposite. Many of the unbuilt proposals that were presented predate the 1901 McMillan Plan and the subsequent siting and construction of Lincoln Memorial, completed in 1922.

In fact, many of the early 19th century unbuilt designs were not even in the same location as the present Arlington Memorial Bridge, which was designed in 1923 specifically

to be a low-profile structure to not disrupt the sight lines between Arlington House and Lincoln Memorial.

Where the current Memorial Circle now sits, the McMillan Plan and its subsequent development in the 1920s and '30s showed an elliptical plaza with two 166-foot tall columns that are now being used as some sort of justification for the monumental arch, but historic renderings and descriptions show clearly how materially different they are.

The proposed 1920s slender columns were situated not in the center but one on either side of the bridge. The Washington Post in 1928 noted, and I quote, Two stately columns would be framing in but not interfering with the view of the Lincoln Memorial from the direction of Lee Mansion, end quote.

Simply put, they were completely different in design, size, height, proportion, and location to the current arch. For the past century, all federal planning and design studies

have only reinforced the importance of maintaining low profiles and avoiding any tall or permanent structures in this area.

NCPC's own Memorials and Museums Master Plan from 2001 noted, and I quote, that The existing circle at the west end of Memorial Bridge is not seen as an appropriate location of a future memorial, end quote.

The most recent 2024 Cultural Landscape Report for Memorial Avenue Corridor, commissioned by the Department of the Interior and meant to serve as a guide for future planning, calls to preserve the corridor's axis viewshed connections, and significant vistas that were foundational to its design and ongoing function.

It goes on to note that within Memorial Circle, protection of views is key.

Even though the applicant did not make substantive changes to the proposed arch as requested by the CFA in their April review, like removing the statues on top to reduce height or

introducing open archways to facilitate views, the CFA voted to fast-track the project by granting their final approval -

We urge the NCPC not to replicate this pattern. Instead, we implore you to take seriously the comments included here and in the NCPC's own Executive Director's recommendation and insist that the applicant provides the requested information, addresses concerns, and complies with applicable laws and regulations before advancing this design to preliminary and final approval. Thank you.

CHAIRMAN SCHARF: Thank you, Ms. Jain. Next up, we have Mr. William Vaughan, who I believe is here with us in person.

MS. HOTTEL-COX: Mr. Vaughan wasn't able to make it, so we can move on to Susan Douglas.

CHAIRMAN SCHARF: Mr. Vaughan is not here, so we will move on as suggested by our General Counsel to Susan Douglas. Ms. Douglas, you have three minutes to provide your

testimony. Please proceed when you're ready.

MS. DOUGLAS: Chairman Scharf and Commissioners, I am horrified by how quickly the arch project is moving through the approval process in spite of strong public opposition and compelling reasons for halting this plan.

My concerns about the Arch are as follows. There's a law that bars all construction on federal parkland in the nation's capital without the express authority of Congress. The administration said it would not seek congressional approval and will instead rely on an authorization from 1925 related to a project never built.

Using a 100-year-old loophole to avoid congressional approval is specious. The Arch is a vanity project for Trump. Ostensibly meant to honor America's 250th anniversary, Trump admitted at a dinner last year that the Arch was being built for him. Video of those comments is widely available online.

Presidents should not build their own

memorials; rather, leave that for others after their legacy has been established.

Building the Arch on Memorial Circle is a desecration of the sacred space where 400,000 soldiers and family members are buried. The grotesque size of the Arch would block the historic sight line between the Lee Mansion at Arlington National Cemetery and the Lincoln Memorial.

This view was intended to symbolize north-south reunification after the Civil War.

At 250 feet, the Arch will dwarf everything in its midst and ruin the vista for the 70,000-some drivers who cross D.C.'s Grand Entrance each day. Construction of this Arch will create a traffic nightmare in an already busy corridor.

The FAA has launched a study of the possible flight safety risks given the Arch's proximity to Washington National Airport and its complex flight patterns. This is standard procedure and could take up to nine months.

Memorial Circle is already under permit for testing and boring in preparation for construction work because the soil in this area is predominantly dredged alluvial soil and is considered a poor choice for a massive stone monument.

Extensive and expensive foundational supports will be required to support the Arch.

Congressman Don Beyer is so concerned about the project that he recently co-sponsored a bill to block the Arch, stating the project is tasteless and disrespects those buried at the cemetery, including his family members.

Public Citizen has filed a lawsuit on behalf of several Vietnam veterans and an architectural historian to block the construction of the Arch. Any discussion of the Arch is premature at most pending resolution of all these studies and lawsuits.

That aside, this Arch must be stopped. Democracies do not construct memorials to living presidents. Disrupting the historically

significant view is an affront to our history, to the men and women at Arlington National Cemetery who gave their lives in service to our country and to those who remember them -

CHAIRMAN SCHARF: Ma'am.

MS. DOUGLAS: It is Arch insanity.

CHAIRMAN SCHARF: Thank you, ma'am. Thank you, Ms. Douglas. Next up, we have Gary Langston. Mr. Langston, you have three minutes to provide your testimony. Please proceed when you're ready.

MR. LANGSTON: Thank you. I'm a veteran. I'm a resident of Washington, D.C. My parents are interred in Section 66 of Arlington Cemetery. My dad was himself a Vietnam veteran, two tours there flying helicopters. My mom was kind of a traditional Army wife, also a nurse who served in Army hospitals at times. My wife -- my wife -- my personal wife is a veteran of the Persian Gulf War, and we have several ancestors who served in the military going back in history. These are my personal comments.

Any memorial -- and we're mixing the terms memorial and monument in this discussion, and I think that's an important distinction, must respect those interred there, their descendants, current and the future generations.

I think what does this arch look like in another 250 years. The linkage of the memorial, it's more than Arlington House and the Lincoln. It's the avenue, it's the hemicycle, the women's memorial behind it, Kennedy's grave site, the eternal flame -- the eternal flame, all of that.

The vistas are wonderful from there. You don't need another structure to provide those vistas around Washington.

So that said, what's required here is a solemn memorial, if anything, rather than a monument. Now, the way to do that, of course, in my opinion, is to follow the law, gather input from appropriate stakeholders. That includes those where the viewshed is impacted from grave sites, not just those that are

existing today, but those that will exist in the future.

All that said, I've got six specific comments on the content, some of which you've partially addressed in input.

The multiple views of the viewshed, very important. I would add two -- I would add get views that simulate winter, get views that simulate night, and get views that simulate not just a view from the other major monuments, Jefferson, et cetera, but from other locations within the cemetery and elsewhere.

The second thing about viewshed that I would emphasize is the night views of the skyline of Washington and the memorials are, it's breathtaking.

Today, and in my statement, there are a couple of photos, the lighting is subdued. The Air Force Memorial, Arlington House, the flagpole over Fort Myer, and the Iwo Jima Memorial. Anything that would -- there needs to be a lighting plan, and it needs to respect that

view scape.

Lastly, I think the most important piece of this is whatever is done there should be a unifying factor for the country. And at present, there are elements of the design of the arch that I fear won't stand the test of time, and I've included those as well.

CHAIRMAN SCHARF: Thank you for your comments, sir. So -

MR. LANGSTON: And if I may, I offer to anyone -- I'm glad to hear that folks have walked Memorial Avenue in the circle, but walk with veterans inside the cemetery. You'll learn a lot.

CHAIRMAN SCHARF: Thank you, sir. And thank you for your and your family's service to our country, sir.

We're going to move on now to our next group of five witnesses who are Laura Downey, Danilo Feliciano, Carol Quillen, Susan Madden, and Brian Green. Laura Downey, who I believe is with us virtually, Ms. Downey, can you hear us?

MS. HOTTEL-COX: It seems Ms. Downey has not joined the meeting, so we can move on to Mr. Feliciano.

CHAIRMAN SCHARF: Mr. Feliciano, who I believe joined us at our last meeting as well. Good to have you, sir. You'll have three minutes to provide your testimony, and please proceed when you're ready.

MR. FELICIANO: Thank you very much, and thank you very much to all the members of the NCPC. One nation under God, indivisible, with liberty and justice for all. On this arch, the word indivisible is missing.

February 7th, 2025, the current president established the White House Faith Office. April 21st, 2026, the current president released a video for America Reads the Bible event, where he reads 2 Chronicles 7:11-22, where the Lord God says, seek my face.

One nation under God, Exodus 34:17, Thou shalt not make to thyself any molten gods.

One nation under God. Deuteronomy

4:15, Keep therefore your souls carefully. You saw not any similitude in the day that the Lord God spoke to you in Horeb in the midst of the fire.

One nation under God. Ezekiel 14:6, Therefore say to the house of Israel, thus saith the Lord God, be converted and depart from your idols and turn your faces away from all your abominations.

One nation under God, Jeremiah 51:17, Every man has become foolish by his knowledge, every founder is confounded by his idol, for what he hath cast is a lie and there's no breath

One nation under God. Habakkuk 2:18, What doth the gravest thing avail, because the maker thereof hath graven it. A molten and a false image, because the forger thereof hath trusted in a thing of his own forging to make dumb idols.

One nation under God. Psalm 113:12-16, this is in the Vulgate, by the way. The idols of

the Gentiles are silver and gold, the works of the hands of men, they have mouths and speak not, they have eyes and see not, they have ears and hear not, they have noses and smell not, they have hands and feel not, they have feet and walk not, neither shall they cry out through their throat, but them that make them become like unto them and all such as that trust in them.

One nation under God. Isaiah 42:17-23, They are turned back, let them be greatly confounded, that trust in a graven thing, that say some molten thing, you are our God, hear ye deaf and ye blind, and behold that you may see, who is blind but my servant, nor deaf but he to whom I have sent my messengers, who is blind but he that is sold, or who is blind but the servant of the Lord. Thou mayest see as many things, wilt thou not observe them. Thou hast ears open, wilt thou not hear. And the Lord was willing to sanctify them and to magnify the law and exalt it, but this is a people that is

robbed and wasted, they are all the snare of young men and they are hid in the houses of prisons, they are made a prey and there is none to deliver them, a spoil and there is none that saith restore. Who is there among you that will give ear to this, that will attend and hearken for times to come.

One nation under God. Romans 1:22-23, For professing themselves to be wise, they became fools and they changed the glory of the incorruptible God into the likeness of the image of a corruptible man and of birds and of four-footed beasts and of creeping things.

One nation under God. Acts 17:29, Being therefore the offspring of God, we must not suppose the divinity to be like unto gold or silver or stone in the graving of art and device of man.

So when our government has a golden statue crafted and places the words one nation under God beneath it, I have to wonder, to what God are they attempting to place the United

States of America underneath?

With humility, I thank you for receiving this testimony. Respectfully, my name is Danilo Augusto Feliciano and I am a veteran. God bless you all.

CHAIRMAN SCHARF: Thank you, Mr. Feliciano, and thank you for your service to our country as well. Carol Quillen, who I believe is here with us, is going to be speaking on behalf of the National Trust for Historic Preservation. Ms. Quillen, you have five minutes. Please proceed whenever you're ready.

MS. QUILLEN: Thank you, Mr. Chairman. Mr. Chairman and members of the National Capital Planning Commission, my name is Carol Quillen and I serve as President and CEO of the National Trust for Historic Preservation. Thank you for the opportunity to be here and to share these comments with you.

This Commission works on behalf of the American people. You play a critical role, questioning, reviewing, and -- embody both our

founding ideals and our ongoing commitment to build a more perfect union.

The value you bring was clear during this Commission's review of the National World War I Memorial. Over a series of meetings, this Commission helped modify the original submission to respect the iconic water basin that defined the site and improved pedestrian access.

The result was a substantially improved design that created a more fitting memorial to our nation's heroic service members.

Since our founding, we Americans have understood the symbolic power of Washington,

D.C. Our capital is a planned city. In their design, context, and relationship to each other, our most meaningful buildings and monuments communicate our system of government and the principles on which it is based.

Achieving this has required deliberate planning, humility, and respect for what has gone before. Each generation has left its mark by proceeding in carefully calibrated steps that

recognize our complex history and our aspirations.

It's our responsibility to remember this two-century-long tradition of design discipline, to strive to be worthy of this inheritance, so that we may in turn pass it on.

From this perspective, the Arch poses significant risks. It flouts centuries of planning. It would diminish some of our nation's most powerful landmarks, and its hasty design, lack of consultation, and rush to construction undermine the ideal of government by and for the people.

And, finally, to highlight these risks, we respectfully offer specific comments on the project's proposed location, height, scale, and design.

First, the proposed location. The center of Memorial Circle is not an appropriate place to construct a monument equivalent in height to a 20-story building. The colossal bulk of the proposed arch would block the

hallowed vista from the Lincoln Memorial, across Arlington Memorial Bridge, to Arlington National Cemetery, and Arlington House.

One of the American people's most sacred landscapes, this visual link communicates the magnitude of the Civil War, the obligation its unimaginable cost imposes on all Americans, and the aspirations of a post-Civil War reconciliation in a new birth of freedom.

Although there have been earlier proposals to place structures here, including one for two memorial columns, these were modest. The proposed columns would have framed the view of Arlington House and the Lincoln Memorial, not interrupted it. And after reflection, none of these earlier proposals were built.

Second, with its height and scale, the proposed arch would overwhelm neighboring landmarks. It's double the size of the Lincoln Memorial. It's also inconsistent with the Height of Buildings Act that protects the plan of the city.

Third, constructing this mammoth arch at the entrance to Arlington National Cemetery would brazenly disrespect the cemetery's solemn character.

As the hallowed resting place of 400,000 veterans and their families, Arlington Cemetery is a powerful reminder of American military sacrifice, selfless service, and national unity. The triumphal arch would communicate a jarring indifference to the sacrifice of our veterans, and mar the outward view for military families and visitors.

Finally, the applicant has not yet initiated review under Section 106 of the National Historic Preservation Act.

This law clearly mandates that this review be completed prior to approval. Submitting these plans for collaborative review would signal respect for the rule of law; it would improve the project, and honestly, it would help protect the President's legacy.

Our concerns are serious. We

respectfully urge you to withhold your approval for this project until the legally required Section 106 process has been completed, and so that it has the benefit of the careful scrutiny that our capital city, the American people, and the President deserve.

The National Trust has decades of experience collaborating with the NCPC, and we remain ready to help. Thank you very much for the opportunity to speak.

CHAIRMAN SCHARF: Thank you, Ms. Quillen. Thank you, Ms. Quillen. Next, we have Susan Madden, who I believe is joining us virtually. Ms. Madden, are you with us?

MS. HOTTEL-COX: It seems Ms. Madden has not joined, so we can move on to Brian Green.

CHAIRMAN SCHARF: Brian Green. Mr. Green, are you with us?

MR. GREEN: I am. Thank you very much.

CHAIRMAN SCHARF: Thank you, Mr. Green. You have three minutes to provide your

testimony. Please proceed whenever you're ready.

MR. GREEN: Thank you. My name is Brian Green. I'm an architectural historian in Richmond, Virginia.

The Commission of Fine Arts has already granted final approval for this proposal. This Commission is reviewing it for the first time.

I want to spend my three minutes explaining why that sequence is not a reason to defer to CFA's judgment, but to exercise your own.

The CFA voted on May 21 to approve the proposed arch, despite receiving approximately 600 public letters, of which 99.5 percent were in opposition, and without requiring full schematic designs.

An FAA aerial hazard review required for any structure exceeding 200 feet remains unresolved. A federal lawsuit filed by Vietnam War veterans under the Commemorative Works Act of 1986 is actively pending.

This Commission is being asked to

provide concept approval within that same incomplete legal and regulatory framework. The CFA's vote does not discharge this commission's independent responsibility.

The site is the problem that no design adjustment can solve. Memorial Circle occupies the midpoint of the commemorative axis of McMillan Commission design to carry the symbolic weight of National Reunion, the line from the Lincoln Memorial across Arlington Memorial Bridge to Arlington House above the National Cemetery. The circle's openness was not a vacancy awaiting a monument. It was a spatial release the axis required.

The Women in Military Service for America Memorial inscribes that axis in physical form and achieves its presence without imposing scale, and holds the sequence open for the cemetery beyond.

A 250-foot arch, more than twice the height of the Lincoln Memorial, would not enter

that sequence. It would end it. Consider what 250 feet means. It is the equivalent of an 18to 19-story commercial building, or a 25- to 27story residential tower.

At that height, this would be the tallest classical triumphal arch in the world, 86 feet taller than the Arc de Triomphe in Paris, and 53 feet taller than the closest example, which has gone unmentioned today, the Arch of Triumph in Pyongyang, North Korea.

These dimensions were not achieved by analyzing the site. They were chosen to correlate with America's 250th anniversary, and to produce the largest triumphal arch ever built. And this Commission is being asked to place it at the entrance to Arlington National Cemetery.

The revised design, made at the President's request, retained the winged eagle and golden eagles, while only removing the ground level golden lions. The project architect described the arch as not primarily a

monument dedicated to the dead, but to the living.

Arlington Cemetery hosts hundreds of funeral services every month. It is, by any measure, dedicated primarily to the dead. This approach to it from the bridge has seen, for nearly a century, a deliberately restrained approach. A price tag of at least $100 million does not change that.

The Commemorative Works Act requires congressional authorization, an environmental assessment, and a finding that the site is appropriate. None of these conditions has been met. The administration's claim that 1920s legislation connected to Arlington Memorial Bridge already provides the necessary authority is not a serious substitute for that process.

MS. HOTTEL-COX: Time.

CHAIRMAN SCHARF: Mr. Green, I'm sorry, your time's expired.

MR. GREEN: Thank you very much.

CHAIRMAN SCHARF: We appreciate you

joining us. Do any commissioners have any questions for these five witnesses? Hearing and seeing none, we'll proceed to our next five witnesses, who are Jimi Shaughnessy, James Lardner, Ralph Nix, David Parker, and Teresa Lucas.

Jimi Shaughnessy, I believe, is with us in person. I may be butchering the pronunciation of your name. If I am, I apologize, sir. You have three -

COMMISSIONER DIXON: Mr. Chairman?

CHAIRMAN SCHARF: You have -- yes, Commissioner Dixon?

COMMISSIONER DIXON: Yeah, I would just -- I wanted to get Professor Green to -- if he had another comment about particularly his historical review of other arches.

CHAIRMAN SCHARF: Okay. Mr. Green, do you want to address Commissioner Dixon's question?

MR. GREEN: There we go. Can you hear me, please?

CHAIRMAN SCHARF: Yes, we can hear you, sir.

MR. GREEN: Wonderful. I'm sorry, Mr. Dixon, I did not hear the question. I was transitioning over from the other room.

COMMISSIONER DIXON: Yeah, I just wanted you to complete what you were saying, more or less, and share some of your more views about the other arches globally.

CHAIRMAN SCHARF: Mr. Green, can you hear us? Did we lose him?

MS. HOTTEL-COX: Seems like he's dropped. He's back.

MR. GREEN: I apologize, sir.

CHAIRMAN SCHARF: Okay. Commissioner Dixon wanted you to finish your comments about the relationship between this arch and other historical arches. Is that correct, Commissioner Dixon?

COMMISSIONER DIXON: That's correct. Thank you.

CHAIRMAN SCHARF: The point I was

trying to make is that this is -- this would be the tallest in the world. And the closest one is the Triumphal Arch in Pyongyang, North Korea. And my assertion is that it didn't -- we didn't get to the height of this monument by studying the site to determine what would be best, what would be most appropriate, what would be most honorific, but simply matching the number 250, and -- which had the added benefit of being taller than the one in North Korea.

Did that answer your question, sir?

COMMISSIONER DIXON: Yes. Was that also part of your testimony that you wanted to give when you were stopped?

MR. GREEN: Oh, no, no. I was -- I had one line left, which was to say thank you very much for the opportunity to speak here.

COMMISSIONER DIXON: Well, that's an important line. Thank you very much for your work, Professor -

MR. GREEN: Thank you, sir.

COMMISSIONER DIXON: -- and also for

your service with me on the NCPC as a commissioner. Thank you.

MR. GREEN: Oh, you're welcome, sir. It was a privilege.

CHAIRMAN SCHARF: Professor, you're very welcome, and thank you for joining us and for clarifying that.

MR. GREEN: Thank you.

CHAIRMAN SCHARF: If there's nothing further for Mr. Green or the other witnesses we just heard from, we'll proceed on to the next group, starting with Mr. Shaughnessy.

MR. SHAUGHNESSY: Thank you. The pronunciation is correct, probably the first one to do that.

CHAIRMAN SCHARF: Oh. Oh, wow.

MR. SHAUGHNESSY: Appreciate it. Thank you.

CHAIRMAN SCHARF: Of course.

MR. SHAUGHNESSY: Good afternoon, Chairman, Commissioners. My name is Jimi Shaughnessy, and I'm here to voice my opposition

to the planned construction of the Memorial Arch.

I speak as a private citizen, a Marine Corps combat veteran, son of a veteran, grandson of generations of combat veterans spanning nearly 200 years.

Buried in Section 60 are my great-grandfather and great-grandmother. He, a combat veteran who led the charge on horseback against Pancho Villa and would go on to serve in both World Wars. She, a combat nurse who tended to wounded young men during World War II.

They didn't question whether they should serve, only how long they would be permitted to. As a young Marine, I was impressed by their example. Their commitment to service and country became values I carried through my enlistment and combat tour, a tour in which I lost friends before I could learn their full names.

For what died the sons and daughters of America? Was it fame? Will your children line

up to be fodder for the vain? Now, potentially, a gigantic arch will cast a shadow on my resting family, friends, and leathernecks, as vanity is rewarded with a momentous symbol of selfishness.

A 250-foot arch is a profound disruption and insult at the entrance to sacred ground. The space at the gates of Arlington Cemetery exists as a threshold, a transitory passage between service and burial.

To preserve this integrity, it must remain open and unobstructed. Service members and their families navigate many transitions throughout a military career and beyond. The transition out of the military is among the most dangerous periods a service member will face.

That final transition from service to eternal rest is not theirs to manage, it is ours. It falls to us, the living, to receive our wounded and our dead with the highest esteem and care. An arch is not what they need. Who is the arch for? Is it for me? The President has already answered that question. And yes,

it's for him.

This arch would obstruct the sight line of the Arlington Memorial Bridge, a symbol of unity and reconciliation connecting those divided by war and grief. Rather than honoring that unity, it deepens a wound that has not fully healed.

Hasty construction is no path to a monument worthy of this nation. Previous memorials were shaped by extensive public input and rigorous agency review, ensuring that the final design reflected our shared values. This proposal has had neither.

Others have already raised the serious safety hazards of placing a monument in a roundabout at a high traffic intersection, consistent with this administration's pattern of placing pedestrians in harm's way.

Funding has been stripped from the Department of Veterans Affairs, the National Park Service, and Department of Interior, degrading the capacity of these very agencies

that provide direct services to veterans and their families.

If we are to truly support the men and women who serve in uniform, direct this money to those agencies. How will this project be funded? With our tax dollars? With the redirected entrance fees from parks across the country? Anonymous donations flowing into undisclosed funds?

We deserve an answer. No one needs this arch. It's inappropriate, unnecessary, insulting. It's a waste of our land, our time, and our money. If the President wants his own arch, he can sift through the rubble of the East Wing demolition piling up along the banks of the Potomac and build one himself. Thank you.

CHAIRMAN SCHARF: Thank you, Mr. Shaughnessy, and thank you for your service to our country and for your family's service. Next up, we have James Lardner. Mr. Lardner, whenever you're ready, you have three minutes, and please proceed.

MR. LARDNER: Thank you. I want to say a word about one of Washington's great glories, the Lincoln Memorial, the Lincoln Memorial in general, and the Lincoln Memorial after dark.

I've lived here most of my adult life. The sight of the Lincoln Memorial in the nighttime with the wondrous glow that it casts into the sky is a spectacle that never fails to move me. Others, including veterans and family members, have pointed out that the proposed arch would alter the character of Arlington National Cemetery, that it would interrupt a sight line meant to forever symbolize the reunification of North and South after the Civil War, that its massive size and winged figures on top evoke the celebratory architecture of dictatorships -democracies.

Those are powerful considerations. Beyond them, this gigantic structure would block our view of the Lincoln Memorial day and night from most places on the Arlington side of the river, and with its decorative floodlighting and

the FAA-mandated -- it would make the Lincoln Memorial in the nighttime a dimmer and less striking sight from almost every direction.

By conferring your approval, you would diminish something precious in order to add something -- unplanned and uncalled for. Thank you.

CHAIRMAN SCHARF: Thank you, Mr. Lardner. Next up, we have Ralph Nix, who I believe is also in person. Mr. Nix, you have three minutes to provide your testimony, and please proceed whenever you're ready.

MR. NIX: Thank you, sir. Okay, thank you, sir. I did serve in the United States Navy as a hospital corpsman. I've had experiences that a lot of people in this room have not had. I've seen our soldiers, airmen, sailors take their last breath. I've seen families break down outside the ICU rooms, mothers, fathers, grandparents, children, wives. A lot of these are buried in the cemetery.

And, you know, for me, it's not about

right or wrong. It's not about left or right. It's not about the height. It's not about whether Congress approved it or not. It's about the people that's in that cemetery that cannot speak today because they died serving our country.

And it's about morals. It's about respect and disrespect. And to me, this is a disrespect to those who have given their lives up for this country in World War I, World War II -- and now Iran.

So for me, it's -- you know, Congress probably should approve this. Somebody needs to start respecting people who have given their lives to this country. You know -- because I'm going to use my three minutes. I found the comment of the St. Louis Arch appalling. This is not St. Louis.

This is Washington, D.C., and you're wanting to block some of my comrades who gave the ultimate sacrifice. Has anybody asked the families of these service members -- about this?

This is a disgrace. And thank you for your time.

CHAIRMAN SCHARF: Thank you, Mr. Nix, and thank you for your service to our country. Next up, we have David Parker, who I believe is with us virtually. Mr. Parker, you have three minutes to provide your testimony and you can proceed whenever you're ready.

MR. PARKER: Thank you, Chairman Scharf, and Commission members. I am David Parker, practicing architect for 35 years and a fellow of the American Institute of Architects.

As a preservationist, I appreciate your thoughtful deliberation of the current proposal. The location between Arlington Cemetery and the Lincoln Memorial at Memorial Bridge is a National Register-listed site, which, as noted in your own executive director's project summary, quote, was designed to create a physical and symbolic connection between the North and South, close quote.

The overriding significance of this

physical relationship and the viewshed between these solemn landmarks cannot be diminished and should not be impeded or obscured. The height of the proposed arch exceeds Washington's Height of Buildings Act of 1910, which generally limits structures to a maximum of 130 feet, and its proximity to Reagan National Airport is of serious concern since the FAA must approve any structures higher than 200 feet within two miles of a major airport.

Your report observes that the proposed arch is 3,000 feet from Reagan National Airport, substantially closer than two miles, and in the immediate flight path of two major runways there.

The immense size of the proposed arch has been touted by the applicant as a requirement in order to be larger than any other triumphal arch in the world, as though physical scale and dominance is more essential than meaning or appropriateness of its scale to this very specific context and setting.

The symbolism of the proposed arch itself is contradictory and incongruent in this place. Triumphal arches throughout history have been built to, quote, symbolize specific military victory and political power, or to honor victorious generals and emperors while acting as state propaganda, close quote.

This historical association is inconsistent with the vague justifications currently being offered for this immense structure.

The purpose of this arch, according to the applicant, is, quote, to celebrate the triumphs of the American people, close quote, but the overriding solemnity of this specific location is ignored by this generalized trope.

The Commemorative Works Act signed into law by President Ronald Reagan on November 14th, 1986, requires that the proposal not interfere with, encroach on, or -- an existing commemorative work and, to the maximum extent practicable, that it protects open space,

existing public use, and cultural and natural resources.

The pair of tall columns cited as precedent that were once suggested but never built here have been used as justification for the height and also for why the current proposal doesn't need congressional approval.

Note the historic image behind me showing those columns compared to the present arch. Based upon historical drawings, those columns were only 14 feet in diameter and were 272 feet apart, as opposed to the present arch itself, which has a width of 170 feet and a depth of 90 feet. Clearly, the columns were never built, would not have affected views, however, the immense arch most definitely will.

Besides your approval, pursuant to the Commemorative Works Act, the Triumphal Arch must be approved by Congress. Thank you for your thoughtful consideration of this highly consequential proposal.

CHAIRMAN SCHARF: Thank you, Mr.

Parker. Next up, we have Teresa Lucas, who I believe is also here with us virtually. She is representing the Walnut Street Historical Society and therefore will have five minutes to provide testimony. Ms. Lucas, are you with us?

MS. HOTTEL-COX: I don't believe Ms. Lucas has joined the meeting, so we can move on to questions.

CHAIRMAN SCHARF: With that, do any commissioners have questions for any of this previous group of witnesses, starting with Mr. Shaughnessy?

COMMISSIONER CASH: Mr. Chairman?

CHAIRMAN SCHARF: Yes, Commissioner.

COMMISSIONER CASH: Yeah, I actually wanted to go back to Mr. Parker, because I thought his background image was actually very informative, because we've heard a lot of the talk of these -- the former columns that were supposed to go there -

CHAIRMAN SCHARF: The four columns.

COMMISSIONER CASH: Yeah, the columns,

and I think that Mr. Parker's background image showed that, so I have a couple questions actually for Mr. Parker, if he's still online.

CHAIRMAN SCHARF: Mr. Parker, are you still with us, or can we bring him back or -- I don't know how the system works exactly.

MR. PARKER: I'm here. Can you hear me?

CHAIRMAN SCHARF: We can hear you. I think Commissioner Cash wants to see your diagram.

COMMISSIONER CASH: Yeah. So this is perfect. So this is the first that I've seen this at least superimposed with the proposed arch. Could you talk a little bit more about the size and the scale? I think you said they were 14 feet in diameter, but could you talk a little bit about the size and scale of what was proposed there under this former permit, compared to what we're looking at here?

MR. PARKER: Yes, I'd be happy to. The columns, and from the period, the historic

drawings, they were 14 feet 6 inches in diameter and 166 feet high, and they were not -- they were beyond the Memorial Bridge, and they were 272 feet apart.

And that really has not been recognized, the fact that they didn't block anything, either in their dimension or in their placement.

And the other thing that I would note, apropos of that, is that if you compare them with the arch, the arch is 170 feet wide and 90 feet deep. Compare the mass of that with a column that is only 14 and a half feet wide.

COMMISSIONER CASH: So -- and you said the columns were more than 270 or something like that feet apart from each other. So I was up at Arlington House this morning and looking down the hill and looking at some of the graphics that we had in the slide deck.

The archway seems to really blot out from up there the view of the Lincoln Memorial, but I'm getting the sense that from this

picture, the two columns are far enough apart that if you were up at Arlington House, I'm guessing it would more likely kind of frame the Lincoln Memorial than block out the image. Is that fair to say?

MR. PARKER: That's absolutely correct. And that's what they were intended to do, to frame the view.

CHAIRMAN SCHARF: Mr. Parker, I'm just curious. The 1924 commission report makes reference to, I think it's called the July 9th column in Paris, or the July column in Paris. I know that that column has sort of an interior staircase. Do you know if that was a piece of the original design of these two columns, or were they just closed off architectural features or what were they supposed to be like as planned?

MR. PARKER: The drawings that I've seen didn't show any internal staircases in them. Yeah.

CHAIRMAN SCHARF: Thank you, sir. Are

there any other questions for Mr. Parker? Hearing none, thank you again, sir.

And with that, we'll proceed to our next five witnesses, who are Paul Romano, Victoria Fox, Stephen Rhodes, Shady Migally, and David Weinberg. Mr. Romano, I believe, is here with us in person. Sir, you have three minutes to provide your testimony, and please proceed whenever you're ready.

MR. ROMANO: If we can get the microphone to work, right? Is it working?

CHAIRMAN SCHARF: Loud and clear.

MR. ROMANO: Okay. My name is Paul Anthony Romano III. I live in Springfield, Virginia, and I'm a Vietnam veteran. I was a medic in Vietnam. I flew medevac in air rescue.

I've never protested for or against anything in my life, but now at 76, I'm stepping forward. I raised my right hand and swore to this document here in 1968, the Constitution of the United States, to protect it against all foreign and domestic enemies, and would bear

allegiance, true faith and allegiance, to the same that I will obey the orders of the President of the United States and the officers above me, according to regulations and the Uniform Code of Military Justice.

Here today, I stand in strong opposition to the building of the arch at Memorial Circle. It is nothing more than an ego arch for the current occupant of the White House. It's a slap in the face to every veteran who is laid at rest, not only at Arlington, but every national cemetery around the world.

In 1994, I had the great privilege and honor to attend a reunion for all the veterans who fought in Italy in World War II, my stepdad being one of them, who also received the Silver Star, two bronze medals for valor, and was a POW for a short period of time.

I spent 16 days with the greatest generation of men and women who were called and they stood the watch. Just like all the individuals that are laid to rest at Arlington

National Cemetery, they all stood the watch.

I have personal friends there, guys I grew up with, went to high school with, junior high school here in Arlington, guys like Andy Castelda, Sean Mashburn, Jerry Lockridge, John

W. Kennedy, Roger Holyfield, and Butcher Hall. These young men that I grew up with, but would never have the chance to grow old with them, and someday I will be laid to rest as well at Arlington.

Only Congress can approve the building of this arch. This administration has bypassed every legal process in any project they have wanted to do in Washington, by adding the current occupant's name to the Kennedy Center, tearing down the East Wing of the White House, which they said they wouldn't touch, to build the big beautiful ballroom. They were only going to use private donations. And a certain member of the Senate wants to pass a $1 billion legislation to add funds to the big beautiful ballroom.

It is time to put this madness to stop. When the legislation was introduced in Congress for the first time for the World War II Memorial, it was 1987. Then similar legislation was brought forth in '89, '91, and '93. In '93, President Clinton signed Public Law 103-32, authorizing the American Battle Monument Commission to establish a World War II Memorial in the District.

Not to bore you with a lot of other dates, but from 1987 until November 11, 2000, before groundbreaking started. It took 13 years to approve it, and then took another four years, and it was dedicated on May 29th, 2004. So from the time the first legislation to its dedication was 17 years, not a few months.

CHAIRMAN SCHARF: Mr. Romano, I'm sorry, but your time has expired, sir.

MR. ROMANO: Thank you. I appreciate it. It's time to stake a stand, ladies and gentlemen. Stand the watch and turn the arch down.

CHAIRMAN SCHARF: Thank you for your testimony, Mr. Romano, and thank you, as I've said to others, for your service to our country. Next up, I believe we have Victoria Fox, who's with us virtually.

MS. HOTTEL-COX: I don't believe Victoria Fox or Stephen Rhodes, our next witness, are here, so I believe we can move on to Shady Migally.

CHAIRMAN SCHARF: I don't know whether Shady Migally is -- Mr. Migally, are you there?

MR. MIGALLY: Yes, I'm here.

CHAIRMAN SCHARF: Okay. You have three minutes to provide your testimony. Please proceed whenever you're ready.

MR. MIGALLY: Good afternoon, Chairman and Commissioners. My name is Shady Migally. I am an American architect and founder of ME Innovations, with more than 22 years of professional experience in architectural design across multiple countries.

I want to begin by saying that I fully

support the vision of creating a monumental arch to celebrate America's 250th anniversary, but not in its current form. It would be a missed opportunity to rely on copying historical European landmarks, especially the Arc de Triomphe in Paris, and then add a winged statue to achieve a height of 250 feet.

We are a nation of innovators and leaders, capable of creating our own history and completing what our ancestors began.

I believe this historic opportunity deserves a uniquely American solution that reflects our identity, culture, symbolism, innovation, and leadership.

As an architect motivated by patriotism and professional commitment, I developed and submitted an alternative American design that responds directly to the Commission of Fine Arts' recent feedback and public concerns. The proposal preserves the historic sight lines and visual relationship among Lincoln Memorial, Arlington House, and Arlington National Cemetery

through a more open architectural form that frames these landmarks rather than competing with them.

It also improves visitor circulation and safety through dedicated drop-off areas and short underground access to reduce conflict with traffic, while enhancing the public experience with museum spaces and panoramic rooftop observation towers.

Most importantly, the design creates a meaningful civic tradition. Every July 4th at noon, sunlight accesses through a calibrated oculus in the arch roof and illuminates our stone datum on the ground, inscribed with words from the Declaration of Independence.

In that moment, architecture, history, science, and national memory come together in a shared public experience, a renewed reminder of the ideals on which this nation was founded, and what Lincoln later described as a new birth of freedom.

This would become a global event,

drawing the world's attention to this historic moment every year, one that honors our past, inspires our future, and gives the American people a civic tradition that belongs uniquely to them, and a source of pride for generations to come.

Thank you.

CHAIRMAN SCHARF: Thank you, Mr. Migally. I wanted to, also, thank you for -- I know you sent a few hard copies of your proposal to us here at NCPC. I'll make sure that we deliver at least one of those to the project team.

I reviewed it with a number of my fellow commissioners early, earlier today, and I appreciate the obvious attention that you paid to -- or the attention that went into creating that proposal.

COMMISSIONER DIXON: Mr. Chairman?

CHAIRMAN SCHARF: Yes. Commissioner Dixon?

COMMISSIONER DIXON: Is there a chance

we can share an image of that with the -- with us today? Can he share an image of that?

CHAIRMAN SCHARF: Mr. Migally, do you have the ability to bring up a digital image of your proposal right now? Or maybe you could email us the deck that you sent us, and we can circulate that to the Commission.

MR. MIGALLY: I can -

MS. HOTTEL-COX: We're not able to share during the meeting, but we -- I believe, Mr. Migally, you shared the image with your testimony, and it is already online.

CHAIRMAN SCHARF: Oh, great.

MS. HOTTEL-COX: So individual commissioners can view it there.