CFA 21/OCT/21-4


National Mall between the 9th and 12th Street tunnels
Washington, DC
United States

National Mall Underground
New underground parking structure with an intermodal transportation facility, stormwater reservoir, geothermal wells, and visitor services welcome center
Review Type
Information presentation


Dear Representatives Norton and Raskin:

This letter responds to your request of 18 August 2021 to the Commission of Fine Arts to review and comment on a proposal by the National Mall Coalition for a new underground structure located within the National Mall between 9th and 12th Streets that would contain public parking, tour bus parking, a stormwater reservoir, geothermal wells, and a visitor welcome center. In its public meeting of 21 October conducted by videoconference, the Commission was pleased to hear an information presentation on the proposal and to provide the following comments.

In general, the Commission members welcome creative thinking about the National Mall and innovative ways to address a wide range of issues—whether aesthetic, operational, or environmental—affecting this highly prized symbolic space in the heart of the Nation’s Capital. Acknowledging the increasing threat of flash flooding in the Federal Triangle and along Constitution Avenue and the past damage to government and cultural institutions in this area, they thanked the Coalition for presenting this issue and for the opportunity to discuss it publicly. They expressed support for further study of how to address the flooding threat by various strategies, suggesting that this proposal to create a large underground structure to hold stormwater may be reasonable or even necessary in this location, and that it should be evaluated with the other options being explored cooperatively by various groups such as the Silver Jackets multi-stakeholder task force coordinated by the U.S. Army Corps of Engineers. Noting that many groups are working to address current issues of flooding and climate change, they encouraged system-wide thinking at local and regional scales beyond the scope of this proposal in order to allocate public resources most effectively. They also cited the strong potential of the underground geothermal energy facility included in this project, and they suggested it could be expanded beyond the proposed project area if feasible.

In their discussion, the Commission members questioned several aspects of the proposal regarding the accommodation of vehicles and visitor services. They recommended against the idea of bringing visitors underground as their threshold experience into this national symbolic space; they advised that the project would be more acceptable without the parking and visitor services components. They acknowledged the existing problem of tour bus parking, but they suggested that the issue may be better addressed through enforcement of regulations than with such a purpose-built underground structure; they also noted the operational impacts of accommodating physical safety and security measures for the public in such a prominent location. They also cautioned that the project would likely have significant visual impacts on the National Mall landscape due to many inevitable intrusions such as ventilation shafts, entrance and egress structures, and vehicular access and control points; they raised the concern that the insertion of such a highly utilitarian project in this landscape of the highest national significance may be antithetical to its purpose and character. In summary, the Commission members recommended further study of the programmatic components included in the Coalition’s proposal for their feasibility, effectiveness, visual impact, and appropriateness.

The Commission of Fine Arts commends the National Mall Coalition for its many years of citizen advocacy for the stewardship of the National Mall and looks forward to further discourse on potential improvements to this preeminent national symbolic landscape.

/s/Thomas E. Luebke, FAIA

The Hon. Eleanor Holmes Norton
The Hon. Jamie Raskin
United States Congress
Washington, DC 20515

cc: Judy Scott Feldman, Chair, National Mall Coalition
Lonnie G. Bunch III, Secretary, Smithsonian Institution
Robin Carnahan, Administrator, General Services Administration
Kym A. Hall, Director, Region 1–National Capital Area, National Park Service
Tom Vilsack, Secretary, U.S. Department of Agriculture
Kaywin Feldman, Director, National Gallery of Art
Marcel Acosta, Executive Director, National Capital Planning Commission