Minutes for CFA Meeting — 20 September 2018

The meeting was convened in the Commission of Fine Arts offices in the National Building Museum, 401 F Street, NW, Washington, D.C. 20001, at 10:00 a.m.

Members present:
Hon. Earl A. Powell, Chairman
Hon. Elizabeth Meyer, Vice Chairman
Hon. Edward Dunson
Hon. Liza Gilbert

Staff present:
Thomas E. Luebke, Secretary
Frederick J. Lindstrom, Assistant Secretary
Sarah Batcheler
Mary Catherine Collins
Kay Fanning
Daniel Fox
Tony Simon
Jessica Stevenson

I. Administration

A. Approval of the minutes of the 19 July meeting. Secretary Luebke reported that the minutes of the July meeting were circulated to the Commission members in advance. Upon a motion by Mr. Powell with second by Mr. Dunson, the Commission approved the minutes. Mr. Luebke said that the minutes will be made available on the Commission’s website.

B. Dates of next meetings. Mr. Luebke presented the regularly scheduled dates for upcoming Commission meetings, as previously published: 18 October 2018, 15 November 2018, and 17 January 2019. He noted that no meeting is scheduled in December.

C. Introduction of new staff. Mr. Luebke introduced Mary Catherine Collins, a preservation specialist who joined the staff in early August to work on project reviews in the Old Georgetown historic district. He summarized Ms. Collins’ training in historic preservation and conservation practices, and her work experience with the National Park Service and the city government of Alexandria, Virginia. Most recently, she has worked on the renovation of the Cannon House Office Building.

D. Report on the approval of one object proposed for acquisition by the Freer Gallery of Art. Mr. Luebke reported Chairman Powell’s approval earlier in the morning of the Smithsonian Institution’s proposed acquisition of a stoneware plate for the permanent collection of the Freer Gallery of Art. The early 19th-century plate is of the Japanese ishizara type, with glazing that includes a horse-eye motif and spiraling lines; it is an example of the simple designs that later inspired the folk craft movement in the early 20th century. He noted that the plate is offered as a donation. Chairman Powell emphasized the beauty of the artwork.

E. Report on the publication of Palace of State: The Eisenhower Executive Office Building. Mr. Luebke reported the publication during the summer of the Commission’s book on the Eisenhower Executive Office Building. At a public event held at the National Building Museum on the evening of 10 September, Mr. Luebke presented an overview of the book, then participated in a panel discussion that included the Commission’s historian, Kay Fanning, as well as GSA’s director of planning and design quality, Mina Wright, who had been involved in preservation efforts for the building in the 1980s. He noted that the book documents the subsequent restoration work that has been undertaken. He said that the Commission staff has been working on the book for more than three years, and extensive photographic and archival material was provided by the General Services Administration.

II. Submissions and Reviews

A. Appendices

Mr. Luebke introduced the three appendices for Commission action. Drafts of the appendices had been circulated to the Commission members in advance of the meeting.

Appendix I – Government Submissions Consent Calendar: Mr. Lindstrom reported that only a minor change has been made to the draft appendix, to note the name of the sculpture proposed for the Barry Farm Recreation Center; the D.C. Department of General Services eventually provided the name as Iwah, by local sculptor Jay Coleman. Upon a motion by Mr. Powell with second by Ms. Meyer, the Commission approved the revised Government Submissions Consent Calendar.

Appendix II – Shipstead-Luce Act Submissions: Ms. Batcheler reported several substantial changes to the draft appendix, in addition to minor wording adjustments and the notation of dates for receipt of supplemental materials. Two cases have been added to the appendix (case numbers SL 18-108 and 18-147); both were held open from previous months, and are now listed with favorable recommendations. Two cases have been removed from the draft appendix (SL 18-193 and 18-198); these projects will likely be included on a future appendix. The recommendation for one project has been revised to be favorable, based on the relocation of the proposed sign (SL 18-177). She noted that the favorable recommendations for six projects are subject to the anticipated receipt of supplemental materials, and she requested authorization to finalize these recommendations when the materials are received. Chairman Powell urged continued consultation to resolve these cases. Upon a motion by Ms. Meyer, the Commission approved the revised Shipstead-Luce Act appendix. (See agenda item II.D for an additional Shipstead-Luce Act submission.)

Appendix III – Old Georgetown Act Submissions: Ms. Stevenson reported that the only changes to the draft appendix are minor wording adjustments and notations for the receipt date for the revised drawings for one project. She added that the appendix includes 42 projects. Upon a motion by Ms. Meyer, the Commission approved the revised Old Georgetown Act appendix.

B. National Park Service

1. CFA 20/SEP/18-1, United States Marine Corps War Memorial and Netherlands Carillon. Arlington Ridge Park, George Washington Memorial Parkway. New comfort and visitor contact station. Concept. Secretary Luebke introduced the concept design for a new park ranger station and public restroom facility in Arlington Ridge Park, part of the George Washington Memorial Parkway south of the Rosslyn neighborhood of Arlington, Virginia. The park is the site of the U.S. Marine Corps War Memorial and the Netherlands Carillon, a memorial bell tower given to the United States by the Netherlands in appreciation of aid following World War II. He said that the proposed building would replace an existing temporary installation of several portable toilet units. It would be sited south of the Marine Corps War Memorial and the park’s drop-off and parking areas, along one of the main pedestrian walks. He asked Peter May of the National Capital Region of the National Park Service to begin the presentation.

Mr. May said that this small project had actually required an act of Congress: in response to a proposal in the 1990s to add the Air Force Memorial to Arlington Ridge Park, Congress had enacted that no additional structures could be built here, which has now been waived to allow for this new proposal. He introduced Alison Ledwith of EYP Architecture and landscape architect Becky May of Rhodeside & Harwell to present the design.

Ms. Ledwith described the project site within Arlington Ridge Park, which lies directly across the Potomac River along the primary axis of the National Mall, and indicated the site’s relation in plan to the park’s two memorial structures. She said that most vehicular traffic is limited to the circular drive surrounding the Marine Corps War Memorial. A bicycle and pedestrian paths curves east and then south, close to the project site. The new structure’s orientation was based on analysis of the site’s microclimate; the project team determined that the main environmental issue to be addressed is the winter wind, which typically comes from the north and northwest.

Ms. May described the park’s existing circulation system: a concrete path leads down the slope from North Meade Street, along the park’s western boundary; this connects to an asphalt path for pedestrians and cyclists that runs east–west along the project site and then north–south through the park, connecting the Marine Corps War Memorial and the parking area with the Netherlands Carillon. Oak trees line the circular road around the Marine Corps War Memorial; otherwise, the park’s landscape is open lawn with irregular groupings of trees, primarily deciduous shade trees but also including ornamental flowering trees and evergreen trees. At the southwest end of the park is a wooded area, extending to just behind the proposed building site.

Ms. May said that the proposed building site slopes downward to the southeast, and the existing walk system would be modified and moved slightly to the south to meet accessibility standards along the slope. The walk would be approximately level along the front of the building, providing access to a small plaza sheltered by the overhang of the building’s rectangular roof. The plaza would be paved with precast concrete unit pavers; benches at the east and west sides of the plaza would be extended from the building walls, and an additional freestanding bench would be at the center of the plaza. An additional north–south walk would provide access to the building from the circular road and parking area of the Marine Corps War Memorial. An area of supported turf would be located around the intersection of these walks, directly in front of the plaza, reinforced with a layer of plastic rings below the lawn; this area could be used for portable toilets, tents, and trailers associated with special events, and it would be strong enough for vehicles to drive on. She added that this supported turf will be visually integrated with the surrounding lawn, part of the prevailing landscape character of the park. Most existing trees would be preserved; groupings of trees on the west side of the building site establish some visual separation between the park and the residential neighborhood to the west, while the lawn allows views into the proposed plaza for safety. Four mature trees are proposed for removal, to be replaced in kind; their removal allows the building to be set further back within the edge of the wooded area and facilitates the grading of the walks providing access to the building.

Ms. Ledwith said that the building has been conceived as a small pavilion constructed of simple materials in dark colors to blend in with its surroundings. The primary material will be a dark-colored, elongated brick; although brick is not used for other structures in the park, it is common in nearby buildings. She observed that the two memorials are built of “noble” materials, including bronze, granite, and steel; these are too honorific for the comfort station, but the selected brick is intended to have a similar, if more modest, effect as granite. The benches would be made of the same brick, with granite seats. Bronze and granite would be used as accent materials, in colors recalling their use in the two memorials.

Ms. Ledwith said that the plaza beneath the overhanging roof would provide shade, as well as shelter from rain, in this relatively open park. The top of the roof would be white to reflect heat; the soffit is envisioned as wood, preferably cedar. The ranger contact station would be glazed to facilitate the ranger’s interaction with visitors and view of the park. She said that as the surrounding landscape grows, it will partially obscure the building from view.

Ms. Ledwith described the proposed plan: three restrooms—a men’s room, a women’s room, and a smaller single restroom—and along the west side, the ranger contact station projecting toward the front, an office behind it, and a mechanical room at the rear. Glazed brick is proposed for the more secluded inner area of the plaza, with the intent that its color would serve as a wayfinding tool in lieu of signage. She indicated the sliding gate between the inner and outer areas of the plaza, allowing the inner plaza and all of the interior spaces to be easily secured—an important feature because the restrooms will be closed at night.

Ms. Ledwith presented the four elevations. On the west, the facade would be mostly a solid plane of brick, with a panel allowing access to the mechanical equipment. The north facade facing the plaza would have the glazed contact station and brick walls. The south facade would have clerestory windows to admit daylight into the larger restrooms, reducing the energy use; she noted that any light spill from these windows would be in the direction of the woods, avoiding visual impact on the two memorials. The east elevation would have also have clerestory windows to admit natural light to the smaller restroom. Chases in the restrooms are designed to allow for maintenance of equipment without workers having to enter the building.

In summary, Ms. May said that the simple material palette will complement the existing materials used in the park, which include cool tones and many shades of gray. The asphalt of the new walk will resemble the existing walks, the supported turf is intended to appear like other lawn areas, and the plantings will continue the character of the existing landscape.

Ms. Meyer said that her comments would focus on the building more than the landscape design. She commended the presentation and the strategies for material selection.

She acknowledged the massing concept as a response to the environmental analysis, which emphasized the extreme condition of winter winds from the northwest, leading to an asymmetrical massing to block these winds. But she observed that the siting result is to overemphasize the north–south centerline of the building by aligning it directly with the north–south approach walk. The view from the walk is focused on the symmetrical grouping of the two restroom entrances, which she called too honorific for this function; she added that if the restroom doors are open during the day, anyone approaching would see directly inside. She asked whether this was the intention, or if the building’s placement could be slightly shifted; she recommended that the focus of the siting be on the public plaza space, adjacent to the ranger station. She emphasized that apart from this odd issue, the building layout appears to be successful.

Ms. Meyer asked for further information about how the sloping terrain would be accommodated on the site. Ms. May responded that the slope would flatten at the plaza, but no retaining walls would be needed on the plaza’s perimeter. Ms. Meyer expressed support for this solution. She added that the winter winds could be further deflected if the building’s roof were slightly sloped. She summarized that these are small suggestions to refine a sound strategy; her comments are focused on the issues of wind and access because these appear to be the primary drivers of the design, along with the program.

Ms. Gilbert asked how the size and placement of the supported turf area had been determined. Ms. May responded that the 10- by 30-foot area was requested by the National Park Service and is sited adjacent to a corner of the entrance walks. Ms. Gilbert recommended splitting this area to place it on both sides of the north–south walk, making it more symmetrical, because in actuality the structure of rings beneath the turf will always be visible; she said that this area should be integrated within the design instead of appearing to be simply tacked on. Ms. May responded that the anticipated use of this supported turf would be studied more closely to determine how much space would be needed.

Ms. Gilbert questioned the light color of the proposed mortar, suggesting a color that blends more closely with the dark brick. Ms. Ledwith responded that the design team already intends to make this adjustment; she indicated some of the images included as precedents, where the more uniform coloring of bricks and joints has resulted in walls resembling stone.

Ms. Gilbert asked if the bench in the center of the plaza could be extended out from beneath the overhanging roof, and whether its size is adequate. Mr. May responded that it would be four feet wide, sufficient to include a backrest in the middle for back-to-back seating. Ms. Ledwith added that the length had been chosen so that wheelchairs could be accommodated on either end, which would be difficult if the bench were extended.

Mr. Dunson expressed support for the design, citing its quality and simplicity. He encouraged further consideration of how to reconcile the issues of circulation, safety, and the symmetry and balance of the design. He supported the suggestion to shift the building’s footprint to provide a better focus for the approach view while maintaining clear sightlines for safety. Ms. Ledwith added that one reason for the decision to orient the two restroom entrances toward the approach walk is that the ranger station will not always be staffed, and the proposed layout would allow police officers driving through the park to have clear sightlines. Ms. Gilbert asked if the building would have nighttime lighting; Ms. Ledwith said that daytime lighting would be provided as required by code, but the building will be closed and unlit at night.

Secretary Luebke summarized that the Commission members have provided comments about the proposed configuration and its overly formal axiality. He suggested that further review could be delegated to the staff, or the proposal could return for further concept review. Ms. Meyer said that she would be comfortable with delegation to the staff but stressed her concern that security questions are playing too large a role in decisions about siting; she emphasized her concern that the primary visitor approach will be from the Marine Corps War Memorial, and the proposed siting would have visitors looking directly into the restrooms. She offered a motion to approve the concept with these comments, and to delegate review of the final design to the staff, with the understanding that the next submission would return to the Commission if it is not responsive. Upon a second by Mr. Powell, the Commission adopted this action.

2. CFA 20/SEP/18-2, Reservations 398 and 399. Tenley Circle at Wisconsin and Nebraska Avenues and Yuma Street, NW. New landscape and pedestrian amenities. Concept. Mr. Lindstrom introduced the second project from the National Park Service, a proposal for the rehabilitation of the landscape on the two parcels of Reservation 398 that comprise Tenley Circle, at the intersection of Wisconsin and Nebraska Avenues and Yuma Street, NW, and the nearby triangular parcel Reservation 399 to the northeast. He asked Peter May of the National Park Service to begin the presentation.

Mr. May said that this project presents an opportunity for the National Park Service to make park improvements in conjunction with a private partner. He introduced Connie Fan of LSG Landscape Architecture to describe the proposal.

As background, Ms. Fan described two reports that provide a framework for the project: the 2010 “CapitalSpace” report from the National Capital Planning Commission, which called for improving the network of green spaces throughout Washington; and the 2015 report from the Rock Creek Conservancy, “Revitalizing Rock Creek Park,” which advocated for the improvement of the city’s traffic circles and smaller parks. She noted occasional cooperative efforts between local citizens or the D.C. government to work with the National Park Service in improving small reservations. For the current project at Tenley Circle, the Wisconsin Avenue Baptist Church, in partnership with Sunrise Senior Living, has offered to improve the small parks in conjunction with the construction of a new shared building on the existing church site abutting the east edge of Reservation 399. Sunrise will fund the design and rehabilitation of these parks, and will collaborate with the church to maintain Reservation 399 for a few years; they will not maintain the parcels comprising Tenley Circle.

Ms. Fan described the context and existing conditions of the parks, located approximately one-fifth of a mile south of the Tenleytown Metro station and on the western edge of an extensive residential neighborhood. Mature street trees—mostly London plane—line Nebraska Avenue and Yuma Street; because of overhead utility lines, most of these trees have been cut back and are in poor condition. The two parcels of Reservation 398 are roughly semicircular, framing Wisconsin Avenue and defining the space of Tenley Circle. She described the landscape of these parcels as overgrown and difficult to maintain: deciduous trees around their perimeter; a perimeter hedge of pyracantha, which tends to collect trash; and an inner circle of crape myrtles surrounding a patchwork of understory plantings. Reservation 399, located on the outer side of the Tenley Circle roadway, is an elongated triangular area of lawn stretching north from Yuma Street, with Nebraska Avenue on the west and the Wisconsin Avenue Baptist Church on the east; many pedestrians cut through this reservation to reach nearby transit, resulting in a social trail. The reservation slopes down approximately four feet toward the southwest.

Ms. Fan presented the proposed new landscapes, focusing on the Reservation 399, which is intended as an “urban oasis.” In addition to the existing eight-foot-wide concrete sidewalk along Nebraska Avenue, a secondary walk of tinted concrete would be installed in place of the social trail toward the southern end of the park, and an additional meandering walk would roughly parallel Nebraska Avenue; she provided samples of the proposed muted colors for the concrete. A small plaza of approximately 600 square feet would be created at the intersection of the two walks, with bluestone inserts, a bench, and an interpretive wayside providing information on the Fort Circle Park National Recreation Trail that passes through this area. Abundant understory plantings would be installed along these walks and on the lawn. Two berms, approximately three to four foot wide, would protect the plaza and seating from the heavy traffic of Tenley Circle and Nebraska Avenue. The site would continue to drain toward Nebraska Avenue, and automatic irrigation systems would be installed. She noted that the D.C. Department of the Environment has approved the proposed amount of hardscape because it would be less than 1,000 square feet. The two parcels of Reservation 398 would have street trees at their perimeter to define the edges of Tenley Circle and Wisconsin Avenue, along with arcs of understory trees and smaller plantings to further frame the central lawn areas. She described the plant palette as consisting of hardy native plants drawn from a successful understory palette that the National Park Service developed for Georgetown’s Rose Park. Reservation 399 is currently not lit; the proposal includes twelve- or fourteen-foot-tall gooseneck lamps of a variety used in Rose Park, supplementing the existing cobra-head lights around Tenley Circle. Site furnishings, such as benches and the wayside, would conform to National Park Service standards.

Chairman Powell invited comments from the Commission members. Mr. Dunson commented that the design may be proposing too many trees; he observed that the existing trees in Tenley Circle, in conjunction with the understory plantings, obstruct views and close off the parcels from the surroundings, creating blind spots for drivers,. He suggested removing the street trees on the Wisconsin Avenue edges of each half-circle, which would clarify the circle’s shape, enhance the park-like appearance, and improve the sense of connection between the two halves of the circle as well as their relation to the triangular reservation to the northeast. Ms. Fan responded that the street trees around the circle are all healthy and proposed to be retained; one missing tree would be replaced to create a continuous circle. She said that the understory flowering trees are likewise existing and healthy, and also would remain. The overgrown pyracantha hedge would be replaced with a new low hedge, in front of which eight-foot-wide layered planting beds would replace the existing understory plantings.

Mr. Dunson observed that the triangular reservation would extend along the rear of the new Sunrise residential building; he asked how the landscape design would define public versus private space. Ms. Fan responded that the clear guidance from the National Park Service is not to favor any private user in the design of this space; she clarified that the west facade of the planned new building would have no direct access to the public parkland. Mr. Dunson asked if the public would be able to use all the green space on this side of the building; Ms. Fan said that the entire area is open to the public, up to the building wall. Mr. Dunson commented that the proposed walks through the park, in conjunction with the topography, may suggest a layering of space that defines zones that are more public or private.

Mr. May provided a further response, noting that the demarcation of public versus private space has been an ongoing concern for the National Park Service: the private developer in this type of project may perceive the park as providing an attractive yard for the building. He emphasized that this is never the intent of the National Park Service; likewise, for this project, the church and Sunrise do not intend to create private space. Mr. Dunson commended these intentions but asked how use of the public zone would be controlled; Mr. May responded that the church and Sunrise both consider that keeping this parcel open to the public will be to their benefit.

Ms. Meyer supported Mr. Dunson’s comments. She asked how the first floor of the building along this rear elevation would be used, and whether it would have windows; she also asked about the relation between the finished floor elevation and the adjacent park topography. Ms. Fan responded that toward the north, the west side of the first floor would be lined with residential amenity spaces, and the second floor would have residential units; the church sanctuary would be on the south. She added that the grade difference is approximately two feet between the park and the interior floor. Ms. Meyer asked whether the National Park Service has established standards or criteria for trails connecting the individual Fort Circle parks; Ms. Fan responded that there are no standards, only the expectation that these parks should be connected through a series of green spaces.

Ms. Meyer expressed her strong endorsement of this private initiative to improve the landscapes. Referring to Mr. Dunson’s comments about the obscured sightlines across Tenley Circle, she suggested reinforcing the public nature of the circle by designing the landscape as a perimeter of large trees defining the circle, or a grove evenly extending across both halves—in either case omitting all understory trees and plantings. She observed that Tenley Circle does not require the same scale as the triangular parcel nor the same number of layers, from low plantings to sub-canopy and canopy trees. She emphasized that simplification would improve the design; she added that the existing smaller trees could be transplanted somewhere else.

Regarding the triangular reservation, Ms. Meyer provided several recommendations to reinforce its public nature. She advised greater emphasis on the new walks, such as by lining them with regularly spaced trees. Toward the east side, she observed that the proposed foundation plantings would make this area appear like private space; she instead recommended extending the lawn up to the building, and placing the low plantings along the walks to give them strong spatial clarity, defining the public realm in three dimensions instead of just two. She commented that the plaza needs to be more than a “rug” in the middle of the park amid the convergence of the walks; like the walks themselves, the plaza would benefit from greater spatial definition, and she recommended expanding the plaza paving to encompass the adjacent walks. She advised placing the trees further from the building to cast more shade during the later part of summer days, improving the building’s microclimate and reducing energy costs. Referring to a recent book by landscape architect Laurie Olin, Be Seated, she said that a bench in the public realm should be longer than six feet; she recommended that the two proposed benches be sited more clearly as edges of the plaza to further define it as an outdoor room. She emphasized her support for the overall direction of the proposal, commenting that the design includes all the necessary parts but they need to be consolidated.

Ms. Gilbert observed that the trees along Yuma Street have had their leader branches cut off to accommodate overhead wires, which she identified as a city-wide problem, and these larger trees could better be located closer to the building. She agreed with the recommendations of the other Commission members to create a more open landscape in Tenley Circle; noting the numerous problems with the many different existing plantings that have not been maintained, she questioned the proposal to plant yet another garden that would not be maintained. She observed that Tenley Circle is the scene of much activity, with a traffic circle and two bus stops; the new landscape would attract even more people, but they will not be able to enjoy flowerbeds located next to busy streets. For the triangular reservation, she commended the decision to place a new walk along the alignment of the existing social trail. She suggested that the plaza should not merely be a remnant shape but a defined area that can function as a place of respite. She asked if an analysis has been conducted of existing trees; Ms. Fan responded that the project team’s arborist has done an analysis.

Chairman Powell noted the complexity of the project and expressed support for the comments provided. Secretary Luebke summarized that the fundamental question concerns the character of these spaces, and whether the triangular park will read as if it contributes to a larger formal idea about the public space; he noted the Commission’s support for the general direction. Chairman Powell and Ms. Meyer suggested that the Commission review the project again at the concept level; Ms. Meyer added that the proposal included an appropriate amount of plant and landscape material, but fundamental issues still need to be worked through in consultation with the National Park Service. The discussion concluded without a formal action.

Chairman Powell departed at this point, resulting in the loss of a quorum; Vice Chairman Meyer presided for the remainder of the meeting. Mr. Luebke noted that the recommendations for the remaining submissions would be subject to confirmation by a quorum at the Commission’s next meeting.

C. District of Columbia Department of Transportation

CFA 20/SEP/18-3, Small cell infrastructure in public space, throughout the city. Draft guidelines for the installation of low-power antennas for cellular and data communication. Final. (Previous: CFA 19/JUL/18-1, Information presentation) Mr. Fox introduced the submission for draft guidelines to regulate the installation of small-cell telecommunications infrastructure within public space throughout the city. He said that the National Capital Planning Commission (NCPC), on behalf of the D.C. Department of Transportation (DDOT), introduced the small-cell initiative in an information presentation to the Commission of Fine Arts at the July 2018 meeting; the Commission had commented on the great potential impact of this privately owned public infrastructure and had emphasized that the project requires a public advocate to protect public values, not just a facilitator to implement private enterprise. Regarding the development of the guidelines, the Commission had requested that they be context sensitive, and had encouraged the involvement of other design professionals such as artists and industrial designers. The Commission had also supported the use of dedicated poles for small-cell sites, and had encouraged collocating the infrastructure to reduce the potential impact of multiple poles in public space.

Mr. Fox said that the draft guidelines document is being coordinated by DDOT and is a collaborative staff effort of the Commission of Fine Arts, NCPC, and the D.C. Office of Planning including the D.C. Historic Preservation Office (HPO). The guidelines are intended to protect significant views and manage visual clutter in public space by regulating the location and appearance of small-cell installations, including the light standards on which the installations can be attached, the number of installations allowed per block, the total height of the installations, and the components of the installations that are permitted above ground. The currently submitted guidelines incorporate some of the Commission’s suggestions; however, requests such as holding a design competition and including additional design professionals in the process were not realized. He said that after the final guidelines are approved and adopted, DDOT staff reviewers would use the guidelines along with the Master License Agreement (MLA) between the D.C. government and the small-cell providers as the basis for a programmatic review process to evaluate the small-cell permit applications; permits that do not conform to the guidelines would require additional review by the Commission and other agencies. Secretary Luebke emphasized that the small-cell installations would be important public infrastructure, and that the initiative raises complex issues. He noted that the Commission lacks a quorum for the review of this case, and that no action would be taken on the submission; however, the Commission could provide comments and recommendations, and more discussion of the project is expected at a future meeting. Mr. Fox asked Kathryn Roos, public-private partnership manager at DDOT, to present an overview of the small-cell initiative along with the draft guidelines.

Ms. Roos began by emphasizing that the MLA with each of the private-sector providers, required in order to install small-cell infrastructure, sets out broad parameters and fees associated with the installation of the infrastructure. She said that small-cell infrastructure may be installed on certain assets owned by the D.C. government, such as streetlights, but the government itself is not deploying the infrastructure. She said that DDOT and the Public Space Committee (PSC), a D.C.-Government body that oversees the nonstandard uses of public space, would each have roles in permitting the installations in the public right-of-way. She described this process generally: after review by the PSC, oversight is delegated to DDOT, which would then issue temporary or permanent permits for uses of public space. The intention is that the PSC—as well as CFA, NCPC, and HPO—will adopt a final version of the guidelines, which would reduce the overall future review work of agency staffs. Applications for small-cell installations would ultimately be submitted to DDOT for review and approval using the guidelines as a basis. If the installations do not conform to the guidelines, further review would be required, which may include a hearing in front of the PSC, as well as review by CFA, NCPC, HPO, and the local Advisory Neighborhood Commission (ANC).

Ms. Roos said that this new technology will increase the capacity of cellular networks to meet growing consumer demand; DDOT recognizes that guidelines are needed to facilitate the installations while still protecting the unique built environment of the nation’s capital. She said the goals of the guidelines include:

  • avoiding negative impacts on important view sheds and vistas, particularly within the L’Enfant Plan and the Monumental Core;
  • minimizing the impact on the character of designated historic districts and landmarks;
  • protecting open access and circulation to public spaces;
  • and minimizing the visual and physical clutter within the public right-of-way.

Ms. Roos said that DDOT is interested in improving the draft guidelines based on feedback from the Commission, other stakeholders, and the general public. The guidelines incorporate information and best practices developed by other cities, as well as technical requirements and documents provided by the small-cell providers. She noted that the guidelines are intended to supplement, not supersede, local and federal laws and regulations, and that the installations must still conform to D.C. and federal regulations.

Ms. Roos described the typical small-cell installations, which are composed of antennas and equipment that must be placed close to the ground, near potential users; this often results in attaching small cells to streetlights or new poles within the public right-of-way. Aspects of their appearance that would be regulated by the guidelines include the color, height, and placement of the antennas and equipment, as well as the type and appearance of the poles to which these components may be attached, including new stand-alone poles. She said that the guidelines also address the specific placement of small cells within the streetscape itself; important adjacencies include their distance from certain streetscape elements such as trees and doorways, as well as the distance between individual installations.

Ms. Roos presented the “Permissible Installation Types and Location” matrix from the draft guidelines. She said that this matrix is organized by the ownership of existing poles on which small cells may be attached, set against other criteria such as pole type and cabinetry installation appearance. The locations considered in the chart are the Monumental Core area, composed of the L’Enfant city, the Shipstead-Luce Act area, and the Old Georgetown Act area; D.C.-designated historic districts; and the remainder of the District. She described the various existing poles included in the matrix: the metal “5A” poles and wood poles owned by D.C. and found mostly in alleyways; pendant poles owned by D.C.; new stand-alone pendant or Washington upright poles, which would be owned by the small cell providers; and wood poles owned by third-party utilities such as Pepco and Verizon. She said that the small-cell providers most commonly want to install their infrastructure on the pendant poles. Both teardrop and cobra-head light fixtures are found on pendant poles, but only poles with cobra-head fixtures would be allowed to have small-cell installations, because teardrop fixtures have a decorative arm and finial that would be significantly altered by the antenna portion of small cells. She said that the guidelines would allow the installation of new pendant or Washington upright poles for small-cell installations because they would be aesthetically similar to existing poles. In addition, small-cell providers would be allowed to attach only the antennas to the D.C.-owned poles listed in the matrix; at these poles, the associated equipment would need to be enclosed in a below-grade underground vault to minimize the visual impact of this equipment.

Ms. Roos presented illustrations of potential installations on existing D.C. streetlights. On the illustration of a 5A pole, she indicated the potential appearance of a two-foot antenna affixed to its top, as well as a secondary collar-type antenna attached below the armature of the cobra-head light fixture; she reiterated that the associated equipment would be in an underground vault. She then presented an illustration of a similar installation on a pole that is fluted and tapers towards its top. Ms. Meyer asked if installations such as those shown in the illustrations would have one or both of the antenna types shown. Ms. Roos responded that information from small-cell providers indicates that installations could have any combination of the two antennas; however, she said she is not sure of the specific criteria that providers use to determine which combination to install. She then presented illustrations of potential installations on stand-alone poles; she noted the extensive discussions during the development of the guidelines regarding the appropriate method of reducing the intrusiveness of this type of installation. Small-cell installations would not be permitted on existing Washington upright poles with globe-type fixtures, which she said are common within the Monumental Core area; instead, new poles for installations in these areas would be required to have detailing and fluting very similar to Washington upright poles. In some cases, poles would need to be taller to accommodate the technical requirements of small-cell installations. She said the other allowable stand-alone pole would be the pendant pole, without any streetlight attachment. The small-cell providers could modify the specifications for the existing poles and work with the manufacturers to produce new poles; in each case, these poles would be owned and maintained by the small-cell providers, not by the D.C. government. She added that these poles would need further design and specification.

Ms. Roos then presented a map showing the general location of the 5A, pendant, and D.C.-owned wood poles throughout the District; she said there are more than 11,000 pendant poles with cobra-heads. She noted that few existing poles within the Monumental Core area would be allowable for attaching small-cell infrastructure. However, this area represents a large potential customer base for the providers, who are likely seeking to install a large number of small-cell sites in the area. Therefore, the guidelines stipulate the permissible placement of small-cell installations on either existing or new poles, in the “Permissible Spacing and Frequency of Installations” matrix. She defined several of the parameters for the matrix: a block, which is defined as an entire linear block, including each side of the street; and a blockface, which is defined as one side of one block along a street. The first column of the matrix lists ranges for the various blockface length intervals in the city; the second column addresses the number of small cell facilities that are permitted per blockface outside the Monumental Core area and historic districts. For example, along a blockface that is up to 150 feet in length, only one small-cell installation would be allowed, regardless of the number of carriers; a total of two installations would be allowed on the block, including the blockfaces on both sides of the street. She said that as the blockface length increases, the number of permissible installations also increases, to a maximum of six per blockface outside the Monumental Core area and historic districts. Within the Monumental Core area and historic districts, the number of permissible installations would essentially be reduced by one, with a maximum number of five per blockface. She said the minimum distance between small-cell installations on a single blockface in all areas of the city would be 60 feet; within the Monumental Core area and historic districts, this minimum would increase for longer blockfaces. She said the matrix also addresses the allowed number of carriers per block. To avoid carrier monopolies on a single block, the number of sites per carrier per block would be limited to one, increasing to two for blockface lengths greater than 600 feet. She said these constraints were developed with consideration given to the maximum operating radius for small cells—approximately 500 feet—as they were understood by the agencies drafting the guidelines, and she believes these dimensions would result in a fair distribution of small-cell sites for each provider. She said that the guidelines also stipulate the sequence in which providers must consider sites. For example, if a permissible streetlight is available, providers would have to attach to that first before installing a stand-alone pole. However, on a block with additional space available, new stand-alone poles would be allowed, provided they otherwise comply with the guidelines. She concluded by presenting a map of Washington showing the boundaries of the L’Enfant plan, the Shipstead Luce-Act area, the Old Georgetown Act area, and other D.C. historic districts.

Ms. Meyer thanked Ms. Roos for her presentation and invited public comments. Elsa Santoyo, a director of the Citizens Association of Georgetown (CAG) who chairs its Historic Preservation and Zoning Committee, addressed the Commission to describe CAG’s concerns about the small-cell initiative. She said that the Federal Communications Commission (FCC), at its upcoming meeting on 26 September, is planning to vote on an order that is intended to ease the deployment of small-cell infrastructure. She characterized the order as a ban on local regulations intended to prohibit or impede deployment of small-cell infrastructure. She said that the FCC order would establish reduced time limits for the review of a permit application; for example, attaching small cells to existing poles would only have a 60-day period for a full review, and new facilities would have a 90-day period. She said she is concerned by the notion that the deployment of fifth-generation (5G) cellular service and the related infrastructure is a certainty. She noted that some communities in California have stopped the deployment of small-cell infrastructure altogether, and lawsuits will likely follow the FCC’s order. She said that there are skeptics of 5G technology in government and in the private sector, and she quoted William Webb, Motorola’s former Director of Corporate Strategy who is now a telecommunications industry consultant: “5G doesn’t bring anything I can imagine you can’t deliver with 4G.” She said that Mr. Webb is skeptical of 5G technology and compares it to the Concorde, a discontinued supersonic jet service that is characterized as a commercial failure, in spite of its superior speed, because of the service’s high ticket prices.

Ms. Santoyo said that an additional concern is radio frequency transmissions. The public has been told that the small-cell radio frequency levels emitted at ground-level would fall within FCC guidelines; however, if one visits the FCC website to research these guidelines, one is then sent to the Food and Drug Administration’s website, which itself cites the International Agency for Research on Cancer, part of the World Health Organization (WHO). This information states that radio frequency fields and extremely low-frequency electromagnetic fields are possibly carcinogenic to humans. She said WHO also notes that cell bay stations operate at higher power than cell phones. The radio frequency exposure from these stations is lower than from cell phones because they are mounted on towers, but the small-cell installations will be closer to people. She also referenced the website www.environmentalhealthtrust.org, which she said is informed by scientists who are not paid by the telecommunications industry; this website publicizes studies and other citations that examine the “very dangerous effects of the small cell radiation,” particularly from 5G technology, which produces a different type of radiation than tower-based cellular installations.

Ms. Santoyo said that the potential visual clutter of small-cell infrastructure is another area of concern. She cited discussions regarding a potential mandate for providers to collocate, or “hotel,” their installations to reduce the number of poles in public space; however, she said that individual discussions with providers have made clear that the stand-alone poles necessary to accommodate multiple carriers would be taller, approximately 20 to 25 feet in height, and have a larger diameter, from 18 inches to more than 20 inches, with four collocated carriers. Therefore, hoteling may not solve the problem of visual clutter, because the larger poles would have their own visual impact. Finally, she said that providers have not addressed specific questions about alternatives to the proposed antenna designs, such as considering different mounting locations or different types of antenna installations; as an alternative, she asked if microcells, picocells, or femtocells are available, and if the antennas could be mounted on the back side of building parapets. She added that the new technology would not be provided to the community for free, and would likely entail additional costs for consumers.

Jim Wilcox, a commission member of ANC 2E in Georgetown, said that he would provide comments on his own behalf; ANC 2E has not yet considered the draft guidelines. Mr. Wilcox said that he is impressed with the experience of the Commission of Fine Arts regarding design issues and landscape architecture, which is especially pertinent to this proposal, and he expressed appreciation for the Commission’s letter in response to the NCPC information presentation in July 2018, particularly the stated support for increased hoteling. He commented that Comcast, a major provider of internet services in the District, has not signed a MLA nor requested approval of their own proposed technology; he said this strongly suggests that faster internet service can be provided without the installation of small-cell technology on poles. He said he shares the concerns of many regarding the potential appearance and number of poles required for the installations, and Ms. Santoyo’s concern regarding the potential diameter of new poles. However, he said that he trusts the Commission of Fine Arts to favorably guide the design of the installations toward a reasonable solution consistent with the Georgetown neighborhood and historic context. He said it is troubling that providers have expressed in meetings that they do not support proposed limits on the number of installations, since the community may actually wish to decrease the number of small-cell installations permitted. He commented that the illustrations shown in the guidelines are favorable when evaluated against the various designs presented by the providers. He said that another concern is related to equipment enclosures: while the community would prefer the equipment to be placed in below-grade vaults—as is required in some jurisdictions—the providers wish the equipment to be above ground; materials indicate some enclosures could be five feet tall and very wide, which would be inconsistent with the historic streetscape of Georgetown. He added that he recently appeared before the Committee of 100 on the Federal City, and its members are also concerned about the small-cell initiative.

Joe Gibbons, chairman of ANC 2E, confirmed that his commission has not yet considered the guidelines document, but ANCE 2E has passed resolutions and held a town hall regarding the initiative. He said the website smallcelltownhall.com contains additional information about the town hall; he thanked the providers, particularly AT&T and Verizon, for presenting slides and answering the community’s questions at that meeting. He noted the discussion at the town hall regarding the consequences for consumers if only one carrier per block is permitted. He said there is a concern regarding future plans once the providers secure small-cell locations in the public right-of-way: providers may state that they need these locations for small cells, but that they have also said in meetings that they may not install 5G technology, and that they will not specify which generation technology will be installed on the poles. He said that 4G and 5G small-cell installations use different technology, and the providers themselves source their equipment from different companies, such as Qualcomm and Ericsson. The concern is not necessarily with the business model of the providers, but he said that a uniform design mandated by the Commission of Fine Arts would be beneficial; he cited the example of most modern cars being able to run on the same type of gasoline, and the small-cell companies should be able to adapt their technology to a uniform design. He said that he has attended many meetings with Ms. Santoyo and Mr. Wilcox regarding small cells in which most attendees have been lawyers, not architects or landscape architects; he said this likely results in responsible stewardship of the companies and their associated stock prices, but the people responsible for this important initiative are not designers with expertise in the built environment. He said that the providers are interested in establishing footholds in the community, and their claims on existing or new poles are likely placeholders for future business interests. He said that he has advised CAG to develop a system of “technology captains” who would document small-cell installations in Georgetown neighborhoods, an effort similar to Georgetown’s public safety block captains. For example, he said the workers installing the small-cell infrastructure would likely position antennas based on performance standards, rather than aesthetic standards, and this type of work should be documented so it can be evaluated by DDOT. He compared this scenario to the Commission’s design review process: while the Commission or its staff would review certain design details presented by landscape architects, such as the placement of a hedge in a park, they would not be present on site when technical challenges require modifications that have aesthetic impacts. He said that he would like the Commission and its Old Georgetown Board to have continued jurisdiction over the small-cell installations even after the guidelines are adopted as a part of the existing process of project referral from the D.C. government to the Commission; this would include staff-level reviews of the installations. He said this oversight would be necessary to ensure future technology, such as 6G or 7G infrastructure, conforms to the historic character of the Georgetown historic district.

Mr. Gibbons noted that an additional concern regarding the small-cell initiative includes the ten-foot minimum distance between installations and buildings. He commented that this is too short a distance, and it is unclear whether this distance would be measured from the center of the pole or from a projecting antenna. He expressed concern that the antennas would be visible from a second- or third-story window. He said it is also unclear if the providers would be permitted to trim trees in a manner similar to Pepco. He concluded by commenting that the fast-moving small-cell initiative is being pushed by technology and not design; he questioned whether the FCC can issue rules that supersede the Commission’s review; and he reiterated that he would like the Commission to retain its jurisdiction throughout the small-cell permitting process.

Vice Chairman Meyer again recognized Ms. Santoyo, who asked to provide additional comments. Ms. Santoyo said that she agrees with the comment of an NCPC member that “design guidelines are the kinds of things that you can drive a truck through.” The guidelines should therefore include very precise dimensions and stipulations. She added the concern that DDOT has asked for providers’ comments on the guidelines, which she likened to “asking the fox to review the design guidelines for the henhouse,” especially since the guidelines were developed using specifications from the providers’ marketing materials.

Ms. Meyer acknowledged the concerns raised by the public regarding the difference between an approved drawing and the final built condition; she said that this requires thinking about the project and the guidelines with greater nuance than was first understood. She also observed that utilities within public space are usually complicated undertakings with physical connections such as wires, and this is so much more complex.

Ms. Gilbert commented that the visual impact of a 32-foot pole is difficult to understand in the abstract, and she suggested creating full-size mockups of small-cell installations on both sides of the street on select blocks in the Monumental Core area. Ms. Roos responded that full-size mockups have not been constructed, but NCPC has studied the implementation of the guidelines with particular regard for the spacing and maximum number of poles on a block; she said that NCPC may wish to share these results. Elizabeth Miller, director of physical planning for NCPC, said that her office has performed such studies regarding the application of the guidelines, including consideration of potential stand-alone poles; she offered to share the studies with the Commission of Fine Arts staff. Ms. Gilbert commented that the streetscape is a three-dimensional space framed by two blockfaces, and the street segments are also parts of larger corridors; she agreed with Ms. Miller on the benefit of having a better understanding of the height relationships among the various streetscape elements.

Ms. Meyer commented that the city is composed of numerous types of public spaces with unique experiential qualities; for instance, the Monumental Core is different from the city’s more residential neighborhoods. She expressed concern regarding the distribution of allowable pole types on which small-cell equipment could be installed, as shown in Map 2 of the guidelines; she observed that the least amount of regulation is proposed for the neighborhoods that need it the most, particularly east of the Anacostia River. She cited the stated goal of the guidelines to have equitable treatment of all areas of the city, while noting that equal treatment and equitable treatment are different goals. She said that some areas already suffer from degraded streetscapes because they have primarily wood poles, rather than Washington upright poles with globe-type fixtures; therefore, the widespread installation of small-cell infrastructure on these existing wood poles would have a much different impact than is currently imagined. She recommended developing three-dimensional, parametric design drawings to help understand the relationship of installations to the heights of buildings, trees, and other existing poles, as well as to the widths of sidewalks and streets. She acknowledged that this would require much drawing and analysis, but emphasized that the effort is necessary for understanding the impact of this proposed infrastructure on the wide range of places found in Washington, which include the Monumental Core, older historic districts such as Georgetown, and the varied neighborhoods throughout the city. She said that the matrices in the guidelines to not provide the spatial information necessary to evaluate the impact of the small-cell installations. Ms. Roos clarified that the blank areas on Map 2, without markers for existing DDOT-controlled 5A, pendant, or wood poles, are likely areas with third-party wood utility poles. She acknowledged that areas east of the Anacostia River have more DDOT-controlled wood poles, aside from major thoroughfares with pendant posts; Ms. Meyer said that these DDOT-controlled wood poles are the concern.

Mr. Dunson commented that the permissible installations matrix included in the guidelines gives the impression that a great wave of small-cell installations will be inundating the city, and he questioned how the impact of installations would be mitigated. He observed that the matrix identifies three different areas within the city that would have different criteria for regulating the installations; he instead suggested applying the most restrictive criteria across the entire city. He commented that the entire city could be considered historic, and that valuing one community over another should be avoided. He recommended initially allowing a small number of poles—perhaps 1,000—as an initial test condition, followed by a determination of whether the providers’ coverage goals could be attained with this small number, perhaps aided by the implementation of new technologies. He said that an aggressive stance challenging small-cell installations should be taken, and less stringent mitigation techniques should be avoided; for instance, burying equipment below-grade in underground vaults should be required for all small-cell installations in the city. He predicted that siting studies will show a proliferation of poles across the city whose impact will have to be minimized using artistic methods.

Ms. Roos responded that the guidelines development has been a process of challenging and pushing back against the small-cell providers. The approach has been to find balance; she said that Mr. Dunson’s comments are relevant and will be taken into account during the revision of the draft guidelines. Mr. Dunson commented that current technology appears unrefined and could be improved aesthetically, thereby reducing the visual impact on all communities across the city. Ms. Roos expressed appreciation for Mr. Dunson’s comments as well as the request for full-size mockups. She clarified that small-cell installations would still have to conform to other D.C. regulations, such as those stipulating the installations’ permissible distance from other objects in public space such as curb cuts, driveways, and trees. Mr. Dunson emphasized that a floor on the number of poles has not yet been achieved, and he reiterated his suggestion to make available to providers a small number of poles to test their coverage and technological boundaries.

Ms. Gilbert asked about the apparent urgency to install small-cell infrastructure. Ms. Roos said that DDOT has received significant pressure to establish the review process so that the small-cell initiative can move forward, and she expressed appreciation for the cooperation from CFA and NCPC in developing the guidelines. She added that the providers would have to answer questions regarding the urgency of the technology. Ms. Gilbert recalled that the information presentation in July 2018 included discussion of elevated equipment enclosures the size of a mailbox, but no design with precise dimensions for these components has been presented to the Commission. Ms. Roos agreed that the equipment enclosures are significant components of the small-cell assemblies, and the guidelines therefore require installing the equipment in underground vaults in many locations. She confirmed that at-grade enclosures would be approximately the size of a large mailbox, and she offered to provide general images of above-ground equipment enclosures. Ms. Gilbert asked how large the equipment enclosures would be if installed on poles; Ms. Roos responded that she has seen the dimensions of some equipment enclosures to be approximately 5’-7” tall, 1’-8” wide, and 8” to 10” deep. Ms. Gilbert asked if the guidelines allow for installing this type of equipment enclosure on third-party poles, resulting in a neighborhood with a proliferation of these types of unsightly installations. Ms. Roos responded that the guidelines as currently drafted would allow this scenario; she clarified that cabinet enclosures of this type would be allowed only on 5A poles, which are mostly in alleyways, and on wood poles controlled by either DDOT or third-party utility providers.

Ms. Meyer said that small-cell installations with this type of equipment enclosure would be problematic, especially in consideration of social justice issues across all the city’s neighborhoods; she acknowledged that this issue may be beyond the jurisdiction of DDOT. She commented on the contrast between the elegance and precision of contemporary consumer cellular devices and the obtrusive appearance of the infrastructure systems required to support them; she reiterated that talented designers could shape this infrastructure to minimize its visual impact, thereby bolstering community support for the new infrastructure. She noted the irony that while most residents would welcome increased service capacity, there is little apparent support from the community for the imposition of more visual clutter in the public realm. She concluded that this is a design issue that will not be solved by using superficial fixes to beautify the small-cell equipment once it is installed, and that holding a design competition simply to figure out ways to apply superficial alterations to the existing technology would not be appropriate. She strongly advised engaging talented designers to make this infrastructure as small and unobtrusive as possible, and she emphasized that the public agencies tasked with studying these issues should inform the small-cell providers that providing better designs for this infrastructure would avoid a lengthy, acrimonious process of design review and community consultation. She also acknowledged the public health issue regarding the infrastructure, particularly regarding its proximity to bedrooms and other living spaces for children. She recommended additional study of the solutions achieved in major European cities, which are often better at incorporating new technologies into the public realm.

Ms. Roos expressed appreciation for the request to study European cities. She said that several international cities, particularly capital cities, were studied when developing the draft guidelines; the finding was that these cities have not seen widespread deployment of small-cell infrastructure. For instance, the City of London is beginning to permit small-cell deployments, but no additional information regarding the infrastructure’s appearance was found; additional research has included specific London-area boroughs and other European, Canadian, and Asian cities, with little information discovered. Ms. Miller of NCPC added that according to her research, Europe appears to be behind the U.S. in its deployment of small-cell infrastructure.

Mr. Dunson commented that Europe is ahead of the U.S. with regards to the design of street furniture, and that we often “piggyback” on these advanced designs. He observed that Washington’s existing lampposts and fixtures were developed at particular times with particular performance standards, ranging from iconic early twentieth-century Beaux-Arts designs like the Washington upright poles—which are not considered suitable for small-cell equipment installations—to more functional modern designs like cobra-head fixtures. He therefore recommended developing a new holistic design typology for the small-cell installations—perhaps by completely reconceiving the cobra-head light fixture typology—rather than allowing a discordant kit of parts to be clumsily attached to existing or new streetlight poles. He emphasized to DDOT that this infrastructure requires a new, ground-up conceptualization that combines new technology with good design in order to avoid a cluttered streetscape. He also acknowledged the public health concerns regarding small-cell technology; Ms. Roos responded that DDOT does not have any control over decisions regarding health concerns.

Ms. Gilbert commented that allowing individual providers to maintain their own poles without further oversight could be problematic. Ms. Roos responded that only new stand-alone poles would be maintained by the providers; DDOT-controlled streetlights would remain assets of the D.C. government, even if small-cell equipment is attached. Ms. Gilbert asked about any oversight of the poles maintained by the providers—for example, whether any regulations would mandate regular repainting of the poles. Elliott Garrett, DDOT’s public space permit manager, responded that DDOT’s public space inspection division enforces the standards and guidelines related to permits that regulate private entities’ use of public space; DDOT would inspect for safety or maintenance issues and then work with the providers to bring their installations into compliance. Ms. Meyer asked if the D.C. government would be able to recover the potentially substantial costs associated with managing and monitoring these private installations. Ms. Roos acknowledged the extensive work that would be required to issue and enforce these permits; she said that the MLA sets the fees for the small-cell installations, and a one-time fee of $1,000 is required to enter into the MLA with the District. Ms. Meyer commented that this fee seems low. Ms. Roos acknowledged that it is not much money, but added that there is a public right-of-way fee associated with the review of the permit applications, as well as a rental fee for installing small-cell infrastructure on DDOT-controlled assets or in the public right-of-way. She added that the FCC is considering capping fees at approximately $270 per installation; although DDOT does not support this fee cap, it may be mandated by federal regulations.

Mr. Dunson expressed support for the construction of full-size mockups of small-cell assemblies. Ms. Meyer agreed, and reiterated her request for three-dimensional drawings depicting the installations in the streetscape as an additional way to evaluate the potential impact of this infrastructure. Ms. Gilbert added that the inevitable disturbance to the ground plane—caused by the digging and removal of paving associated with installing the infrastructure—has not yet been discussed; she said this disturbance would result in patches of asphalt all over the city, and any materials would have to be replaced in kind and with great precision. Ms. Roos responded that this concern is addressed by current DDOT regulations, which stipulate that a certain area around the digging site must be restored as it was before the work, and materials must be replaced in kind; for instance, brick sidewalks would need to be restored to brick. Ms. Gilbert said overseeing this work would be time-consuming for DDOT.

Ms. Meyer commented that Commission members not present are knowledgeable about urban design issues and would be able to provide valuable comments on the project; with no quorum for this review, she recommended that the discussion regarding the small-cell initiative continue when more members are present. Secretary Luebke said the Commission’s comments would be summarized in a letter and transmitted to the applicant, subject to confirmation by a quorum at the next meeting.

Mr. Luebke requested that the Commission clarify its advice on several issues with the small-cell initiative. He first asked if the Commission supports the programmatic approach outlined for the review process. Ms. Meyer said that it makes sense to implement guidelines to alleviate the need for the various agencies to review individual infrastructure installations; Mr. Dunson agreed that he generally supports the concept of using guidelines. Mr. Luebke then asked if the Commission supports prohibiting small-cell installations on existing historic lamppost types. Ms. Meyer noted the consensus of the Commission members not to support allowing any small-cell installations on historic existing Washington upright poles. Mr. Luebke confirmed that this restriction is included in the draft guidelines, but said that the guidelines would permit installing small-cell equipment on modified stand-alone Washington upright or pendant poles without light fixtures; he added that these installations would not be permitted on pendant poles with teardrop fixtures. Ms. Meyer responded that a mockup would be essential in determining what should be allowed. Mr. Luebke said that additional discussion would be required regarding this topic, especially due to the many providers and manufacturers involved in the small-cell initiative.

Ms. Meyer observed that some of the illustrations in the guidelines depicting potential small-cell installations resemble lampposts with cylindrical light fixtures, commonly associated with Frederick Law Olmsted Jr., that are installed on the National Mall; she asked if this existing design could be modified and used for stand-alone small-cell poles. Ms. Roos responded that these Olmsted lampposts on the Mall are controlled by the National Park Service, not DDOT. She said that 18 feet is the tallest height for the Washington upright pole; Mr. Dunson said that the Olmsted lampposts may be 22 feet tall. Mr. Luebke suggested that the Olmsted lampposts could be considered in further studies.

Finally, Mr. Luebke noted that the Commission staff has prepared a revised matrix—“Allowable Small Cell Installations in D.C., by pole type and location”—that could serve as an alternative to the “Permissible Installation Types and Locations” matrix currently included in DDOT’s draft guidelines. He said that the staff’s matrix would allow for more flexibility in the Shipstead-Luce Act area, which varies in character from the city’s urban core to sparsely developed areas adjacent to Rock Creek Park. He asked if the Commission would support incorporating this conceptualization of the matrix into the guidelines. Ms. Meyer recalled Mr. Dunson’s suggestion to apply the most restrictive standards across the entire city; Mr. Luebke said this suggestion could be incorporated into the matrix, while clarifying that additional flexibility would be beneficial in regulating the installations in the Shipstead-Luce Act area. Ms. Roos suggested that the suggestion to apply equally restrictive guidelines across the city would benefit from a discussion regarding equity, and these two concepts as they have been presented may be working at cross purposes. Mr. Luebke clarified that the Shipstead-Luce Act area overlaps with other areas included in the current chart’s Monumental Core area; giving the Shipstead-Luce Act area its own column in the matrix would allow for guidelines better suited to the varying conditions of this federal jurisdiction. He said that the more restrictive standard would apply in these overlapping areas; for instance, in the areas where the L’Enfant city and Shipstead-Luce Act area overlap, the more restrictive standards for the L’Enfant city would apply.

Ms. Meyer expressed appreciation for the new matrix developed by the staff, but she commented that it would benefit from revisions that account for the concept of equity. Mr. Luebke acknowledged this guidance while reiterating that the matrix currently in the guidelines may prove to be unworkable for the Shipstead-Luce Act area. Ms. Meyer agreed with the need for more flexibility in the guidelines, but she emphasized that greater flexibility should not result in the undesirable condition of large, refrigerator-like equipment boxes installed on every wooden pole in historically disadvantaged neighborhoods. Ms. Roos said that she is seeking to clarify if the Commission is requesting one standard applied across the city or a greater variety of standards. Mr. Dunson responded that he considers the entire city a historic district; Ms. Meyer agreed. Mr. Luebke said that additional consultation would be necessary to resolve these issues.

Vice Chairman Meyer concluded by summarizing the Commission’s support for the sensibilities evident in the guidelines, and expressing appreciation for the valuable comments provided by the public. Ms. Roos thanked the Commission for its comments and suggestions, noting that the process is in its early stages. The discussion concluded without a formal action.

D. D.C. Department of Consumer and Regulatory Affairs—Shipstead-Luce Act

SL 18-208, 4101 Arkansas Avenue, NW. Single-family residence, additions to convert to two-family residence. Revised concept. (Previous: SL 18-171, July 2018) Ms. Batcheler introduced the revised concept design for the renovation of and additions to a single-family residence at 4101 Arkansas Avenue, NW, to convert it to a two-family residence. She summarized the Commission’s previous review of the project in July 2018, when it approved the concept design with recommendations to further study the proportions and articulation of the facades; to clarify the hierarchy of materials, details, and window openings; and to simplify the roofline. She asked architect Rocio Gonzalez, who owns and resides in the house, to present the design.

Ms. Gonzalez indicated the site’s location at the intersection of Arkansas Avenue and Taylor Street, at an entrance to Piney Branch Parkway, part of Rock Creek Park. The long, narrow site has a dramatic acute angle at its southwest end, facing the parkway. She described the surrounding residential neighborhood: on the opposite side of Arkansas Avenue are brick Modernist row houses from the 1940s, known as the Tiffey Townhomes, characterized by layered brick facades and the use of wooden trellises as accents; on the same side of Arkansas Avenue as the project site, extending to the north, is a row of simpler two-story brick houses with some Modernist details; and Taylor Street, running east from the south edge of the project site, is lined on both sides with row houses, primarily traditional in style. To the east side of the project site is the western end unit of the row houses on the north side of Taylor Street, separated by an empty lot belonging to the owner of that house.

Ms. Gonzalez said that throughout the review process, the proposal has been to create two units, labeled Unit A on the north and Unit B on the south. In previous proposals, the entrances to both units were west-facing along Arkansas Avenue; in the current revised concept, the entrance to Unit B has been moved to the southeast, around the site’s acute angle. She said that this change allows for several improvements: distinguishing the two different units on the primary facade along Arkansas Avenue; a better articulation of the dramatic acute corner; and the creation of two distinct outdoor areas.

Ms. Gonzalez described the existing house, a one-story freestanding brick house with a bay window dominating its front facade. She said that she intends to keep the outline of the brick house to articulate the first floor, while adding a second and third story above; the existing carport at the northeast would be demolished. The existing bay window would be retained as part of Unit A, along with the existing house’s two bedrooms and partial basement. A new bay window would be created on the corner in Unit B, wrapping around the acute angle. The second floor of each unit would have two bedrooms and two bathrooms, and each third floor would have additional bedroom and office areas. The bay windows in both units would be expressed through all three floors. The new fence would extend to Taylor Street, stepping down to a height of three feet or less. She added that zoning regulations prohibit the roof deck that was previously proposed.

Ms. Gonzalez indicated several details on the proposed elevations. At the north end of Unit A, the two new upper floors would overhang the first story. The existing bay window in Unit A would be widened and its height increased, and some of the window heights would differ between the two units. She said that the design establishes a hierarchy among the windows for the different types of rooms, including kitchens, hallways, and vertical windows for the two stairwells.

Ms. Gonzalez presented the proposed materials. The first floor would retain the brick of the existing house. She described the wood siding material selected for the projecting volumes and the upper floors—a Japanese charred cypress siding in different shades, which she said will weather well and retain its color. The different volumes would be expressed as a main building mass in gray siding, and planes in a black shade that wrap around this mass. Horizontal trellises would be used over the entrances and added as vertical details on the facade to emphasize that the single building comprises two separate units. In the center of the rear facade on the east, a vertical plane of a third color of wood siding would tie the brick of the first floor with the other two floors; she said that this rear elevation would be given a simpler treatment. Patio doors from both units would lead to the small back yard area. Unit A would have an exterior stairwell along the northeast facade leading down to the basement. Drainage from the roof could be through downspouts or along a stainless steel vertical cable system.

Ms. Gonzalez described the intent for the landscape, noting that the many large street trees on Arkansas Avenue partially obscure views of and from the property. The existing entrance steps would be moved to the north to integrate the landscape design with the entrance to Unit A. The slope rising approximately three feet from the sidewalk would be planted with groundcover; a low concrete wall, approximately two feet high, would be built at the top of the slope to provide some privacy for the outdoor areas.

Ms. Meyer invited comments from the Commission members. Ms. Gilbert asked for further explanation of the reasons for the material choices and composition, including the choice to use one color of the wood siding on the front facade and a different color on the rear. Ms. Gonzalez responded that she had wanted to retain the brick of the existing one-story house because this is the predominant material of the residential neighborhood. She wanted to then introduce other natural materials in unconventional ways that would reflect the Modernist aesthetic of Arkansas Avenue, and yet differ from the expression of the Tiffey houses on the opposite side. One factor arguing against the use of additional brick was its high cost, although she noted that the charred wood siding is also quite expensive. She said that its great appeal overrode concern about its cost: it is a natural material, with the feel of having been crafted by hand, appropriate for the house’s small scale. She said that she envisions the house as a sculpture emerging from Rock Creek Park, with materials and forms that are a mix of Modernist, natural, and sculptural influences, and a handmade but crisp aesthetic. Ms. Gilbert expressed appreciation for this description.

Mr. Dunson acknowledged the strong distinction that is now apparent between the two units, rather than treating the duplex house as a single building. Ms. Gonzalez responded that she had decided on this aesthetic strategy based on a comment from the Commission; she expressed her appreciation for the review and consultation process with the Commission and staff, which she said has improved her design.

Ms. Meyer commended Ms. Gonzalez for her hard work in revising the proposal; although the building is small, it is important because of its highly visible site near Rock Creek Park. She commented that the design has noticeably improved through its evolution, and that Ms. Gonzalez had successfully resolved the design while maintaining her own vision and also a consideration of the building’s urban role. She said that moving the entrance to Unit B has allowed Ms. Gonzalez to reconsider the site as a whole, while avoiding the sense of density that would have resulted from having the two entrances next to each other. She commented that the materials are more convincing in the samples than in the renderings, which tend to be too bright and vibrant; she observed that the contrast between the lighter gray and orange wood samples is more subtle than it appears in the presentation, which would help emphasize the continuity between brick and wood.

Ms. Meyer said that her major comments concern the landscape design. She noted that the low wall would visually relate this site to adjoining properties, as it demarcates how the terrain is folded and the upper level defined. It would also distinguish a semi-public from a semi-private zone, a normal condition for transitional, in-between yard spaces in Washington. However, she said that the acute corner of the site would probably still feel somewhat exposed; she suggested creating more privacy by planting a scrim of low, multi-stemmed trees, approximately fifteen feet in height. She commented that the fence along the southeast edge of the site may be too busy in appearance, with excessive stepping along its top, lacking the crispness and simplicity of the design for the house; she suggested using fewer steps, perhaps placing the greatest height where the fence would be visible from the living and dining rooms. She emphasized her support for the design and congratulated Ms. Gonzalez for her success in improving the design’s clarity while retaining the idiosyncratic quality of both building and site.

Ms. Gilbert suggested replacing some portions of the fence with a vegetal screen, commenting that an interplay between fence and trees would create an attractive threshold while marking the striking southern corner. She commended the decision to emphasize this corner with the entrance to Unit B, which shifts the orientation away from Arkansas Avenue.

Mr. Dunson supported Ms. Meyer’s comments. He expressed support for the addition of the low wall, commenting that he hopes it will be allowed by regulations because it would improve the way the building meets the ground. Ms. Meyer asked for clarification of the regulations pertaining to the property line in relation to the configuration of the landscape terrace. Ms. Batcheler responded that the site design requires review by the D.C. Office of Planning and the Public Space Committee of the D.C. Department of Transportation. In brief, property owners are allowed to do certain things in public space, such as to build retaining walls up to a certain height, to add fences below a certain height if they are 50 percent open, and to install plantings except for tall, dense hedges. Ms. Meyer said that, given these stipulations, Ms. Gonzalez could consider altering the fence design, perhaps replacing some segments of fence with taller vegetation of a single species, such as a multi-stem tree, which would provide privacy, volume, and mass, and allow her to relate the design of the fence and plantings.

Mr. Dunson asked if the Commission could have the opportunity to review a mockup of the proposed materials, including larger samples. Secretary Luebke responded that if the Commission is now satisfied with the proposal at the concept level, then a mockup could be reviewed as part of a final design presentation at the permit application stage; or, if the Commission does not require a mockup, the staff could conduct the permit review and, if the proposal is satisfactory, place the submission on the Shipstead-Luce Act appendix. Ms. Batcheler said that the detailing of this building is of such importance that the staff would work closely with the applicant, but the staff has not requested a sample installation, such as a mockup of the building corner with the bay window. She added that having the applicant as owner, architect, and contractor makes the review process easier. Mr. Dunson agreed that the staff’s careful oversight and close consultation would be satisfactory, and the Commission does not need to review a mockup.

Vice Chairman Meyer agreed with Mr. Dunson that it is important to know that the staff will be assessing such details as the relation between the wood and brick, and their planar treatment, for the review of the final design. She summarized the apparent consensus of the Commission members present to support the concept design; she offered a motion to approve the revised concept with the comments provided, subject to confirmation by a quorum at the next meeting, with the expectation that the project will return as a final design on the Shipstead-Luce Act appendix, or on the agenda for presentation if the staff deems it necessary. Upon a second by Mr. Dunson, the Commission members present adopted this motion.

E. United States Mint

Mr. Simon introduced the three submissions from the U.S. Mint. He said that the first review is for the initial coin in a forthcoming series of non-circulating dollar coins; and the last submission is for a circulating quarter that will conclude the Commission’s multi-year reviews for the series of “America the Beautiful” coins. He provided samples of coins and medals comparable to the current submissions. He noted that the Mint’s Citizens Coinage Advisory Committee (CCAC) will meet next week and has not yet reviewed the current submissions. He asked April Stafford of the Mint to present the design alternatives.

1. CFA 20/SEP/18-4, 2018 American Innovation One Dollar Coin Program. Introductory one-dollar coin with a common obverse, unique reverse, and edge-incusing. Final. Ms. Stafford summarized the authorizing legislation for a new series of non-circulating coins that depict the theme of innovation for each of the U.S. states and territories. In advance of the series beginning in 2019, an introductory coin will be issued in 2018. All coins in the series will have the same obverse, prescribed in the legislation as a dramatic depiction of the Statue of Liberty extending to the coin’s edge; design alternatives for this obverse are part of the current submission for the introductory coin. The reverses for the series will feature an innovation or inventor from each jurisdiction; the reverse of the introductory coin will feature the signature of George Washington on the first U.S. patent. She noted that in July 2018, the CCAC considered an initial set of designs for the introductory coin; the CCAC comments have been considered in developing the new, expanded set of designs being presented today.

Ms. Stafford presented twelve alternative obverse designs, with varying depictions of the Statue of Liberty. She then presented fourteen alternatives for the reverse, all with President Washington’s signature along with varying combinations of motifs including a quill pen and inkwell, representations of the first patent involving the manufacture of potash, the patent date of 31 July 1790, machine gears symbolizing innovation, and later inventions such as the cowboy hat, the light bulb, and the space suit.

Vice Chairman Meyer suggested starting with a discussion of the obverse design, which will be used throughout the fifteen-year series of coins. Mr. Dunson suggested consideration of alternatives #6, 8, and 10. Ms. Gilbert observed that several alternatives depict the Statue of Liberty’s face in profile, which has not customarily been seen. Ms. Meyer suggested that a non-symmetrical design would better represent the overall theme of innovation; she observed that alternative #8 includes extensive areas of blank surface, an unusual design feature that would be appropriate for this theme. She asked about the coin’s size; Ms. Stafford responded that it will be the same size as the current series of circulating Presidential one-dollar coins, such as the sample provided to the Commission members.

Ms. Meyer suggested consideration of obverse alternative #12, due to its interesting cropping and upward perspective that suggests aspiration. Ms. Gilbert agreed that the upward angle of the perspective is interesting. Mr. Dunson cited the emphasis given to the torch, which Secretary Luebke suggested may symbolize illumination in support of the theme of innovation. Vice Chairman Meyer summarized the consensus to support obverse #12, subject to further consideration as the reverse designs are considered.

For the reverse, Ms. Meyer commented that the alternatives with multiple featured elements could be confusing; she noted that a wide range of subjects will be explored on the different reverse designs for the many coins in the series. Ms. Stafford said that the introductory coin is intended to set the tone for the program’s theme. Ms. Gilbert suggested that the inscription referring to the first U.S. patent should be accompanied by an image relating to that patent; if other inventions are depicted, then the inscription should be changed to avoid confusion. Ms. Meyer observed that this guidance eliminates many of the alternatives. Mr. Dunson suggested reverse alternative #13, which focuses on the first patent as a document although not depicting the invention. Ms. Meyer commented that only alternatives #11 and 14 have a depiction of the components of potash or its manufacture, and these depictions do not clearly convey the subject; Ms. Gilbert agreed. Ms. Meyer agreed with Mr. Dunson in supporting alternative #13; she also expressed interest in alternative #3 but said that the staggered lettering of the text “American Innovators” is problematic. Mr. Dunson said that the theme in alternative #3 is difficult to decipher, but it is readily legible in alternative #13 with a clear emphasis on President Washington’s signature.

Ms. Gilbert suggested consideration of reverse #2, perhaps with a simplified depiction of the historic light bulb and removal of the text “First U.S. Patent.” Ms. Meyer questioned the juxtaposition of President Washington’s signature with the light bulb from a later era; Ms. Gilbert agreed that this would be incongruous. Ms. Stafford noted that the New Jersey coin in this series will be minted in 2019, and its design concept will be Thomas Edison’s inventions; Ms. Gilbert agreed that the innovation of the light bulb will be sufficiently depicted in the near future. Ms. Meyer observed that several alternatives include depictions of machine gears, a specific reference that is unrelated to the first patent and therefore not meaningful for this coin. She also discouraged the alternatives with a cowboy hat, which appears odd; she reiterated the support for reverse #13. Ms. Gilbert agreed, citing the inscription of the first patent’s date as a desirable feature in this design, as well as the thirteen stars at the perimeter.

Noting the consensus to recommend reverse #13, Vice Chairman Meyer asked if obverse #12 remains the preference of the Commission members. Mr. Dunson said that obverse #8 is a clear design that would be just as successful when paired with reverse #13; he cited in particular the extensive blank space in this design. Ms. Meyer commented that obverse #8 does not have circumferential elements in the design, which may allow more flexibility in developing compatible reverse designs for the many coins in the series. Mr. Dunson suggested a dual recommendation for obverses #8 and 12; Ms. Stafford said that this would be helpful advice.

Vice Chairman Meyer, noting the large number of alternatives presented, agreed that that a dual recommendation would be reasonable. She summarized the consensus to recommended alternatives #8 and #12 for the obverse—both featuring unusual compositions with an emphasis on the Statue of Liberty’s torch, appropriate for the theme of innovation—and alternative #13 for the reverse. She added that the inscription “In God We Trust” on all obverse alternatives is somewhat incongruous with the theme of innovation, which emphasizes science and technology, but she acknowledged that the inclusion of this text is beyond the Commission’s purview. Mr. Dunson added that the translation of the artwork for reverse #13 into an executed coin will be interesting to see, particularly for the background text on the parchment of the patent document. Ms. Gilbert said that the lack of a defined rim at the edge of the recommended designs should be acceptable, particularly because reverse #13 places the stars and the “American Innovators” text along the edge. Vice Chairman Meyer said that the Commission looks forward to reviewing the future coins in this series.

2. CFA 20/SEP/18-5, 2019 American Liberty High Relief One Ounce 24-karat Gold Coin and Silver Medal. Designs for obverse and reverse. Final. (Previous: CFA 17/MAR/16-6, 2017 issue) Ms. Stafford summarized the previous high-relief gold coins and silver medals in this series, minted in 2015 and 2017; the current proposal for 2019 is intended to build on the success of these past issues. The coin and medal will share the same design but with different inscriptions; the theme for the obverse will be a modern allegorical interpretation of Liberty, and the reverse will be a modern depiction of a bald eagle. She said that the medal will be produced from 2.5 ounces of silver, more than was used for the previous medals, which will allow for greater relief in the design. Vice Chairman Meyer asked for clarification of the sizes in comparison to the samples provided to the Commission. Ron Harrigal, the manager of design and production for the Mint, responded that the gold coin will be slightly larger than the one-dollar Presidential coin—1.2 inches versus 1.043 inches—and more than twice as thick. The proposed silver medal will be two inches in diameters, 0.4 inches larger than the 1.6-inch sample silver medal provided to the Commission, and approximately twice the thickness. He noted that the Mint does not currently produce anything with a two-inch diameter; the new, larger format is the largest size that can be made on the Mint’s conventional press, allowing for a choice of manufacturing locations at Mint facilities and providing higher relief in conjunction with the desired finishes.

Ms. Stafford said that in accordance with past advice from the Mint’s Citizens Coinage Advisory Committee, the current design alternatives are taken from designs considered for the 2015 and 2017 programs in this series; inscriptions with the earlier dates are still shown, and these will be updated for the selected designs. She presented ten alternatives for the obverse design, indicating the paired images for the coin and medal that differ in their inscriptions. She also presented ten alternatives for the reverse design featuring an eagle.

For the obverse, Mr. Dunson expressed support for alternatives #1 and 10; Ms. Gilbert supported #1, and Ms. Meyer supported #10. Mr. Dunson added that obverse #2 is also interesting; Ms. Meyer commented that this design conveys the sense that the Liberty figure is holding a mirror to look at herself. Mr. Dunson said that in obverse #10, Liberty appears to have a doubtful expression due to the lowered chin; Ms. Meyer described it as pensive. Ms. Stafford suggested that Mr. Harrigal address the technical issues that the Mint has been considering for sculpting the complex headdress in obverse #10; Mr. Harrigal responded that the solution will likely involve a combination of relief and texture, taking advantage of the potential for high relief to produce a strong contrast between the headdress and the planar background. He noted that the high-relief process requires balancing the depth and placement of relief on the obverse and reverse, and the final technique for obverse #10 will therefore depend in part on the selection of a reverse design. Vice Chairman Meyer noted the support for obverses #1 and 10, suggesting that these be discussed further after consideration of the reverse design and the technical issues of the pairing.

For the reverse, Ms. Meyer suggested a simple design such as alternative #3, which would contrast with the more complex full-body depictions of eagles that have been used in the past. Ms. Stafford and Mr. Harrigal confirmed that they do not recollect prior coins or medals with a close-up view of an eagle’s head; Mr. Harrigal said that even with other animals such as falcons, such close-up compositions have not been used. Mr. Dunson and Ms. Meyer said that the concern is whether the bird would be legible as an eagle in such a close view. Mr. Dunson added that the view from beneath, as seen in several alternatives, does not convey the eagle’s majestic appearance; Ms. Meyer and Ms. Gilbert agreed, and Ms. Gilbert joined in supporting reverse #3. Mr. Dunson suggested reverse #6 as a very strong design that is between a close-up and full-body view of the eagle; Ms. Gilbert commented that the eagle’s spread wing would be interesting in combination with the headdress of Liberty on obverse #10.

Vice Chairman Meyer asked if the asymmetrical designs would be technically feasible to combine with reverse #6 and obverse #1 or 10. Mr. Harrigal responded that the manufacturing process would be a concern; a typical solution is for one side to be a relatively centered composition that allows for some flexibility in the minting process for the other side, but a pairing of asymmetrical compositions could be feasible. He noted that the two sides are both oriented toward the same top end on the medal, while on the coin the two sides are upside-down relative to each other, exacerbating the technical challenges of the production process. He said that this could be addressed by using different depths of relief on the coin versus the medal, and a solution should be possible despite the challenges.

Ms. Gilbert asked about the inspiration for the obverse’s allegorical depiction of Liberty, which does not appear to be derived from the Statue of Liberty; she said that the depiction on obverse #1 more closely resembles the statue, which may be why she prefers this design. Ms. Stafford responded that all of the depictions in the sets of alternatives for the 2015 and 2017 issues—from which the current alternatives are derived—were intended to be a more modern depiction of Liberty; for the 2017 issue, the guidance was more specifically to convey the diversity of the U.S. population, resulting in a very beautiful design for the allegorical Liberty. She said that the range of obverse alternatives reflects the different approaches by the artists in depicting a modern interpretation of Liberty; some designs are grounded in traditional representations, while others are more innovative. Ms. Meyer commented that the profile pose in obverse #10 conveys an ambiguous identity, which is advantageous; Ms. Gilbert and Mr. Dunson agreed. Ms. Meyer added that obverse #10 avoids the problems of the more classical depictions, such as obverse #5.

Vice Chairman Meyer summarized the consensus to recommend obverse #10 and reverse #6, commenting that #6 is preferable to #3 for the reverse because of the spectacular texture of the feathers and the partial depiction of the eagle’s body, compared to the simpler but very close-up view of the eagle’s head in reverse #3. Ms. Gilbert commented that this pairing would be especially beautiful and dynamic. Ms. Stafford expressed particular appreciation for the Commission’s comments relating the eagle’s wing to Liberty’s headdress.

3. CFA 20/SEP/18-6, 2020 America's Beautiful National Parks Quarter Dollar Program. Reverse designs for Connecticut. Final. (Previous: CFA 21/JUN/18-8) Ms. Stafford said that when the last set of reverses for six coins in the America the Beautiful series was presented, the designs for Weir Farm National Historic Site in Connecticut were noted as provisional until further revision based on the comments that had been provided by the Citizens Coinage Advisory Committee (CCAC). Today’s submission is a revised set of designs for this circulating quarter, based on the previous advice of the CCAC, the Commission of Fine Arts, and the Mint’s liaison from Weir Farm. She described the significance of Weir Farm as the finest remaining landscape of the American Impressionism period of painting; present-day artists continue to use the park for outdoor painting, in the tradition of the Impressionists. The farm was the home of Julian Alden Weir, a leading American artist of the late 19th to early 20th century [CFA member, 1916–1919].

Ms. Stafford said that all of the design alternatives now include the phrase “National Park for the Arts,” at the request of the site liaison. She presented seven alternatives for the reverse, with varied compositions that all include a painting on an easel within the landscape. She noted the preference of the site liaison for alternative #6A, depicting an artist working at a nearly blank canvas, with Weir’s studio building on a hill in the background.

Ms. Gilbert observed that the painting in some of the alternatives appears to be naturalistic, which is inconsistent with Weir’s Impressionist style; for example, alternative #13 would be problematic for this reason, although the overall composition is interesting. She supported a design with a blank or nearly blank canvas, as in alternatives #6 and 6A. She added that conveying the Impressionist style within the small scale of the coin would not be feasible, as noted by the Commission in the previous review.

Ms. Meyer concluded that alternatives #13, 14, and 14A, while conceptually interesting, could not be successful at the scale of the coin. She offered support for alternatives #6 and 6A as acceptable designs with a conventional composition. She also cited alternative #4 due to its more contemporary composition, appropriate for a site that continues to attract present-day artists. Mr. Dunson agreed that #4 is interesting, but the lack of a painter as part of the composition is disconcerting, and adding a painter within the scene would suggest confusing sightlines for the artist’s work. Ms. Gilbert suggested consideration of depicting multiple paintings in progress, conveying the park’s modern role as an attraction for many artists. She acknowledged that the result may be too complicated for the coin design, but she said that alternative #6 or 6A could include a child with a sketchbook.

Mr. Dunson expressed support for alternative #6A, commenting that the artist’s smock—not present in #6—is a desirable feature that helps to inform the coin’s theme. Vice Chairman Meyer summarized the consensus to recommend alternative #6A; Ms. Stafford noted that this choice is consistent with the site liaison’s preference.

There being no further business, the meeting was adjourned at 2:47 p.m.


Thomas E. Luebke, FAIA