As the country fixates on the sad saga of the ruined Lincoln Memorial Reflecting Pool in Washington, D.C., the Trump administration’s plans to build a 250-foot arch at the western terminus of Memorial Bridge have marched forward.

The project received final design approval in late May from the Trump-appointed U.S. Commission of Fine Arts. The problem with that, critics quickly pointed out, was that this approval occurred before a key part of the National Historic Preservation Act — Section 106 — was initiated.

For background: President Lyndon B. Johnson signed NHPA into law in 1966 during an era of rampant unregulated building in order to protect the country’s shared cultural heritage. Section 106, which the Trump administration has been trying to gut, allows for a period of public comment about proposed projects in advance of their approval. This gives time for reasonable concerns to be raised and for pivots in design and siting to take place accordingly.

In a letter submitted to the National Park Service on Thursday by the nonprofit Cultural Landscape Foundation (TCLF) as part of the federal-level reviews of the Triumphal Arch under Section 106, the group’s founding president and chief executive, Charles Birnbaum, called the chain of events leading to the arch’s approval a “radical departure from a well-established series of processes that have made the Monumental Core a global paragon of civic art, landscape architecture, architecture, and planning.”

Birnbaum, who served as coordinator of the Historic Landscape Initiative at the NPS from 1992 to 2007, also noted, “The process for the selection and siting of the Triumphal Arch has been horrifically flawed from the outset. Remarkably, there was no design competition, which is a dangerous and radical decision for what would be the second largest monument in the Monumental Core after the Washington Monument.”

The letter was sent several days after the NPS released a preliminary assessment that found the arch could have significant adverse effects on the historic structures around it. Birnbaum and TCLF, however, worry — based on linguistic hedging in NPS correspondence — that a final “adverse effect determination” will not be made, thus depriving concerned parties of the ability to continue to advocate against the project.

“Given the extensive documentation of adverse effects in the preliminary finding, the suggestion that any uncertainty exists about the final determination is both confounding and alarming,” Birnbaum wrote.

During his tenure at NPS, Birnbaum was the lead author of “The Guidelines for the Treatment of Cultural Landscapes,” which includes a section on “Spatial Organization and Land Patterns,” which, he writes in the letter, “is clear about what is and is not recommended.”

“Identifying, retaining and preserving the existing spatial organization and land patterns of the landscape as they have over time,” is recommended, for example, while, “Allowing spatial organization and land patterns to be altered through incompatible development or neglect,” is not.

“A 250-foot-tall arch in Memorial Circle sited between the Lincoln Memorial and Arlington National Cemetery and Arlington House and in the Monumental Core is undeniably incompatible development,” Birnbaum wrote, noting that any new development is stipulated to be in agreement with the cultural landscape guidelines. “The Arch as proposed will not be consistent with the Guidelines and any certification otherwise would not only be factually baseless (in short, a lie), but declaring so would be unprofessional, fraudulent, and, perhaps, illegal.”

Strong words that may very well fall on closed ears, if recent history is any guide. Nonetheless, the resistance forges ahead.

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