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Casey Mansion Committee
Foxhall Community Citizens Association
Response to Environmental Assessment
January 17, 2003




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Casey Mansion Committee
4645 Q Street, NW
Washington, DC 20007
(202) 338-9534

January 17, 2003

Mr. Joseph Cook
Chief, Land Resources
National Capital Region
National Park Service
1100 Ohio Drive, SW
Washington, DC 20242

Dear Mr. Cook:

This is the response of the Casey Mansion Committee to the Environmental Assessment (EA) for the proposed land exchange between the National Park Service (NPS) and the Casey Mansion Foundation. NPS would exchange the four-acre Whitehaven parkland for a small Georgetown riverfront parcel optioned by the foundation.

The committee was established on September 17, 2002 by the Foxhall Community Citizens Association to study and assess the possible impact of the proposed exchange. Over the past four months, the committee has consulted with experts on relevant ecological, legal, and land use aspects of the proposal; discussed the matter with public officials; participated in public meetings with NPS and foundation officials; examined available public documents; and carefully reviewed the EA.

We began our study free of preconceptions about the proposed land swap. Indeed, the Foxhall Community Citizens Association strongly endorsed the foundation’s offer to build a District mayoral mansion on its Foxhall Road property. The community welcomed the prospect of the 16.5-acre Casey tract remaining undeveloped except for the contemplated mansion. At the same time, the committee, composed of residents of he Foxhall and Palisades neighborhoods, is motivated by an unwavering commitment to keep the four-acre Whitehaven tract as public parkland.

After four months of investigation, the committee has found no credible justification for the proposal. The EA, financed by the Casey Mansion Foundation, which first proposed the exchange, is rife with errors and questionable assumptions and it ignores reasonable alternatives to the land grab it obviously favors. It attempts to create the appearance of being a thorough, professional examination of the consequences of various alternatives. But it turns out to be woefully shortsighted and unreliable as a way to fully inform the public. While seeming to comply with the letter of the National Environmental Policy Act, it violates the spirit of the law.


The EA makes errors that indicate haste or carelessness, or perhaps both.

It errs in stating Key Bridge “was named in honor of Revolutionary War figure Francis Scott Key.” Key figured in the War of 1812. The EA is wrong in stating the existence of “a sidewalk on the east side of Foxhall Road extending from Reservoir Road to the Mansion property.” There is no such sidewalk—an easily observable fact. The EA asserts that the trail through Glover-Archbold Park to the east of the four acres is inaccessible from the property due to distance and dense vegetation.” Had the EA prepares been even reasonably observant, they would have seen the path many hikers take between Glover-Archbold Park and Whitehaven Parkway.

John J. Fay, a Ph.D. botanist who walked the Whitehaven tract with the committee, wrote after his visit:

Unfortunately, the only time available to visit the property was December 30, 2002, when many herbaceous plants are difficult or impossible to detect or identify. I spent approximately an hour and a half on the property. During my visit, I had access to a species list based on a survey performed in October 2002, in the course of preparation of an Environmental Assessment on the land exchange.

Given the unfavorable timing of my visit, my observations are necessarily fragmentary, but I was able to verify the presence of several species that had evidently been overlooked in the earlier survey. Two of these (Verbesina alternifolia and a Veronia that was not identifiable to species) are notable because they are rather conspicuous herbs standing approximately 2 meters high; both are autumn-blooming and showed evidence of having flowered in 2002. The Verbesina was quite abundant on the eastern portion of the parcel; I saw only one large clump of the Veronia.

My brief observation raises questions regarding the adequacy of the botanical survey performed for the Environmental Assessment. Neither October nor December is an ideal time for a survey in the Mid-Atlantic region, and I am at a loss to understand how a survey even in October could have overlooked the conspicuous Verbesina, which may still have been in the late stages of flowering at that time.

Without probing further, the EA concludes the NPS land has “very little probability of any remaining intact archaeological resource eligible for listing on the National Register (Potter, 2002).” Yet the EA notes there is “documented evidence of prehistoric sites” in adjacent Glover-Archbold Park and artifacts indicating prehistoric activities have been observed on the foundation property. An archaeologist with the D.C. Office of Historic Preservation says there is a prehistoric site on the Whitehaven parkland identified as site 51 Northwest 7, a reduction site with evidence of scattering of debris and store in the making of tools. We recommend a Phase I archaeological investigation be conducted, certainly before any construction takes place on this land.


We are saddened and dismayed that the National Park Service—mandated to be good stewards of the national parklands—advocate this deal that would unnecessarily privatize the Whitehaven tract the public has enjoyed for more than half a century. If this proposal is consummated, an eight-foot steel fence and guardhouse–up to 1,000-square-feet, larger than many families occupy in the District–will bar the public from walking four acres of woods, wetlands, and wildlife habitat.

Some of the major steps taken by the parties to the proposal have raised concerns about their commitment to an effective public review. Few people in the area directly affected by the proposal attended the session the NPS scheduled for late August 2002. That low attendance could have been predicted, as it is a time when many residents are away from the city. Public comments on the EA, which was published just after Thanksgiving, were required to be at the NPS by January 3 —again a period when many who would likely respond to the EA are engaged in the holidays or traveling. An appeal for an extension was granted close to the deadline. Also, the EA does not provide any information on how public comments will be weighed or how long this process will take.


It is essential for the public to understand the genesis for the swap, though the EA omits mentioning it. NPS did not initiate this proposal in order to aid the development of the Georgetown waterfront park. “Rather, we agreed to pursue an extraordinary (emphasis added) exchange at the request of the foundation, in order to assist the District of Columbia with providing a suitable and secure setting for a mayoral residence,” according to NPS Regional Director Terry Carlstrom in a letter toANC3-D Chair John Finney.

This reasoning flies in the face of the findings of the Mayor’s Official Residence Commission, headed by former Mayor Walter Washington, which stated in 2001: “The proposed site (16.5-acre tract) and buildings are large enough to accommodate all reasonable security concerns.” The commission also concluded the 16.5-acre tract was large enough for a “suitable” mayoral mansion. Despite this unmistakable conclusion, the foundation seeks to expand its property by almost 25 percent. Why?


The apparent answer that surfaces in the EA is the foundation plans a “preferred location” for the promised mansion that sits far closer to the NPS parkland than the site originally assumed to be the logical location of the mayoral residence. This site was the location of an earlier large residence and has a driveway linking it to Foxhall Road, and utility lines. As important as this piece of the puzzle is, the EA fails to present the reasons for the change in siting the mansion. And the foundation has provided no credible public justification for it.

In adopting a resolution accepting the foundation’s offer to build and own the mayoral mansion, the DC City Council also adopted a provision “to ensure that the future rights and obligations of all parties are clearly understood, and that the District government, the general public, and the surrounding neighborhood are fully consulted in the planning, design, and construction, and ongoing future operations of the Mayor’s official residence.” The Council included a specific request for information about the foundation’s plans and activities, and finance “in an effort to enhance due diligence, as well as public disclosure and involvement.” The Council’s concerns and intentions are quite clear, but the foundation’s selection of the “preferred location” was taken with no public consultation we are aware of. This seems to be contrary to the intent and possibly the letter of the District legislation.

Donald Velsey, a member of the American Institute of Architects and a resident of the Foxhall community, says, “the EA does not contain any information relating to the origin of the proposed site plan for the preferred option.” Mr. Velsey asks, “What other options, beside the original mansion site, were studied? Who studied them? What were the criteria used to select this as the ‘preferred’ option? What compelling design or planning reasons led to this conclusion?” He questioned the EA assertion that if the foundation does not obtain the parkland, “development of the ‘preferred’ configuration for the mayoral mansion would not be possible.” “That statement,” Mr. Velsey states, “does not reflect a thoughtful analysis of the site, proposing as it does, only one possible solution. This is a tired, old strategy for presenting and distorting facts in a way that can only lead to the conclusion the presenter wants.”

The absence of any supporting documentation is mystifying in the light of the assertions by Mayor Anthony Williams and by Richard Carr, president of the Casey Mansion Foundation, that an international design competition would precede the development of the mayoral mansion. But as Mr. Velsey notes in his individual comments on the EA, “As an architect, I cannot understand how a definitive, fixed site on this property for the mansion could have been selected so early in the game, and before receiving input from the competition architects, who would surely want to look carefully at other alternatives.”


The EA fails to examine reasonable alternatives to the so-called “secure access” road the NPS-Foundation agreement imposes on the Whitehaven parkland.

Such an alternative, which some area residents have suggested to NPS and foundation officials, would locate a second access road on the foundation property south of the Whitehaven parkland and across from the German embassy. Foxhall Road is four lanes wide at this point; Foxhall is only two lanes wide at the point the foundation proposes to construct a “secure access” road and large, obvious guardhouse if it obtains title to the parkland. (See Attachment A)

Another reasonable alternative missed by the EA is an easement that would leave the parkland in the public domain and enable construction of a mansion access route. We note, however, this option is unwarranted because the foundation’s 16.5-acre tract is adequate to meet “all reasonable security concerns.”


The EA asserts, “The proposed development of the mayoral mansion and grounds would utilize the entire Mansion Property, and would prevent such intense subdivision development.” But this is a questionable assumption without substantiation. Since it will continue to hold title to this land, it is entirely possible the foundation will build the mansion, and still develop a substantial portion of the land for many dwellings. The access road, on what not NPS parkland, would facilitate such development. The EA does not seriously examine this possibility.

Nor does it assess the environmental consequences from the prospective development of the Hariri property, which borders the Whitehaven parkland on the north. (See map Attachment B.) Carving out parkland for an access road for the mayor’s mansion opens the door to residential construction of the 15-acre Hariri tract. A plan dating from the mid-1980’s shows a planned access road across the parkland to the Hariri land at the same point the foundation proposes a road.

The committee and many residents of the neighborhood near this area believe that an access road in the foundation’s hands would encourage efforts to obtain another entry to the Hariri acreage.


The EA recognizes the “heavy congestion” of traffic at Whitehaven Parkway and Foxhall Road. The District plans to install a traffic signal at this intersection to ease congestion. But traffic on Foxhall Road, which is only two lanes at this junction and northward toward Nebraska Avenue, continues to swell unrelentingly.

Located at this intersection is the recently expanded Mount Vernon Campus of George Washington University and the recently opened Field School. Just beyond the intersection lie other schools, which generate considerable traffic. Also within a block or so are three major embassies. Social events at these institutions and embassies are likely to compound traffic congestion—even with a signal light—when the mansion serves one of its prime purposes as a center for official entertainment and other occasions that will attract large numbers of participants.


“Localized CO2 admissions could be elevated tentatively during times of high volume ingress or egress at the facilities,” according to the EA. During construction at the NPS and foundation properties, “short-term effects on air quality” may occur from emissions from heavy equipment and workers’ own vehicles. The EA notes elsewhere in the text: “The air in the Washington, DC, metropolitan area has exceeded the Federal health standard for 19 of the last 20 years and the region has been designated by the EPA as a ‘obvious non-attainment area’.” The NPS and foundation intentions would contribute to further air quality deterioration.

We believe the proposed access road would concentrate the predicted air contamination at and near the Whitehaven-Foxhall intersection and close to several schools. This pollution could be mitigated, we believe, by locating the access road at the alternative site proposed above.


The NPS-Foundation agreement indicates a concern about the wetlands on the parkland. This area is described as a “No Development Zone.” But some observers describe most of the four acres as wetlands. This is because the adjacent topography causes storm water runoff over most of the NPS land. The parkland is a “bioretention zone” that serves as a natural filter for water flowing through Glover-Archbold Park to the Potomac River and Chesapeake Bay, according to Bob Morris, conservation chair of the DC Sierra Club. Despite this essential role of these wetlands, they are likely to be impacted by the topographical alteration and soil compaction resulting from the proposed construction on the NPS site. Mitigation processes employed during the construction of the nearby Field School failed to prevent soil erosion that negatively affected Glover-Archbold Park. The EA needs more specifics on the protection of a fragile ecosystem.

The committee is concerned about the cumulative environmental effects of the proposed future use of the parkland on the area’s humans, wildlife, and plant habitats. These impacts—dismissed by the EA as of no or short-term consequence—are like the death of a thousand cuts.

The EA states: “The Mansion and NPS properties would become more manicured open space. This change would be generally compatible with the settings of the surrounding residential and institutional uses.” This so-called manicuring would take place, according to the EA, “to improve appearances from the mansion grounds.” But the EA completely misses the point: It is the rough-hewn nature of the NPS parkland that makes it so appealing to so many people.


The NPS has agreed to swap its four acres of parkland for a parcel near Key Bridge that the foundation has option to buy. That parcel covers only one-tenth-acre. It is assessed at less than $900,000; the parkland is assessed at more than $2,300,000.

The Government Accounting Office has criticized some Federal land exchanges for undervaluing Federal land, and overvaluing land the government has obtained in trade from private interests, according to Taxpayers for Common Sense. On December 13, 2002, Regional Director Carlstrom stated in a letter to ANC Chair Finney, “we are currently completing our review of the NPS commissioned appraisals of the properties to be exchanged. Should the appraisals demonstrate that the value of the Georgetown properties does not equal the value of the Whitehaven Parkway property, the foundation is obliged to provide additional interests in land or a cash payment in order to achieve an equal value exchange.” The details of this critical financial part of the swap await public exposure. They are not illuminated by the EA.

But a realistic and comprehensive EA would have examined the major values to the public that do not factor in the NPS-commissioned appraisal of the Whitehaven land. In a letter to The Washington Post, Bob Morris of the DC Sierra Club, wrote:

The environmental concerns regarding this swap are similar to those concerns in many other such transactions by NPS around the country. Current economic analysis by NPS does not take into consideration important services provided by wild areas. Lot 804, the public land NPS wants to trade, is a natural bioretention area, absorbing the runoff from a broad extent of Foxhall Road. Rainwater is held, recycled into the air through transpiration, filtered, and slowly released in a manner that is beneficial to both the onsite and downstream habitat. Trees have three times their harvested value when left onsite: by recycling water to the air, cleansing carbon and other pollutants from the air, providing summer cooling, preventing erosion, fixing nutrients in the soil, and eventually becoming part of the soil and replacing themselves. Provision of habitat to a tremendous diversity of wild species, including such rarities as the piebald deer, is of significant value. All of these services escape typical economic analysis, but all factor into the valuation of this site to the public, who own this land. All these values will be drastically and adversely affected by the planned use of the land if the swap is consummated.

Concerned environmentalists continue to work with all the parties to the transaction to assist them in insuring that the public trust is served well in the use of the land. That public includes the two young naturalists, ages 6 and 10, who had their mother call me because they were concerned that their beloved piebald deer were being threatened by development. They and their classmates at Georgetown Day School have become fascinated by this natural phenomenon and regularly report sightings to each other. That is another value that is not represented in a standard economic analysis: the inspiration of a class of children who are expose to a small slice of wild land in the city.

Under the NPS-Foundation agreement, the wetlands on the eastern portion of the parkland would be a “no development zone.” The prohibition on development, as a Park Service official has said, would reduce the value of the parkland in the appraisal now under Park Service review. Actually, this prohibition arguably could enhance the value of the land if residential development, a real prospect, takes place on the adjacent land owned by the foundation and the Hariri tract. It would enhance the scenic elements, much as a mountain or seashore aspect would.


The NPS, according to the EA, wants the Georgetown parcel as the site of a future “scholastic boathouse.” The committee applauds high school crews and appreciates they may need adequate waterfront facilities to pursue their sport. But in the case of this trade, the public must be cautious—and realistic.

The phrases the EA uses to describe this boathouse emphasize, perhaps unintentionally, the great uncertainty handing over this concept: “eventual…”, “the possible construction…”, “potentially accommodate the development of a boathouse…”. The EA does not allude to the severe financial problems of the DC public schools, which would likely impair the system’s capacity to help finance a boathouse. Perhaps private benefactors or the National Parks Foundation could underwrite a boathouse if that ultimately proves to be the wisest use of the site.

Our point here is that the proposed swap would take away real parkland from the public now and justify it on the basis of a very problematic public benefit that may never materialize in years to come.


Another important financial element in the NPS-Foundation agreement, the text of which is referenced in the EA, is left unexamined. NPS states it will establish an escrow account with “appropriated” funds to buy back the Whitehaven parkland from the foundation if Casey does not “initiate” construction of the mayoral mansion within five years of the actual land exchange. This escrow device appears to be crafted to assuage public concerns over the impending loss of parkland. Without more public details, the escrow provision needs to be questioned. What is the source of the escrow funds? We understand the National Parks Foundation, a non-governmental agency designated to administer the escrow account, cannot accept Congressionally appropriated funds. Five years is an insufficient period for the escrow provision, particularly in view of the mansion project already two years behind the schedule indicated by the foundation.

The NPS-Foundation agreement also provides that the NPS will have a 30-day right of first refusal to repurchase the parkland. There is no guarantee the buyback would occur, especially when NPS seems so ready to trade away the Whitehaven acreage, which it originally acquired in 1948.

Covenants such as the escrow provision appear well-intended. But covenants are subject to court challenge and can be reversed; they are not guarantees intentions will be fulfilled. Deed restrictions might be a stronger instrument. The committee recommends that before the agreement is consummated, the covenants be amended to delegate authority to an independent environmental organization to enforce the covenant. The choice of the organization would be subject to community approval.

The history of the Whitehaven land acquisition as described by the EA is “incorrect,” according to District Councilman Phil Mendelson, an authority on DC parks. “The land was not acquired as a ‘corrector road’, nor does it lie to the east of the former Arizona Avenue, nor was this land ever shown with a road on the District’s highway plan. Instead, this land was acquired by the United States at a time when the Park Service and the National Capital Planning Commission envisioned an extensive system of interconnecting parkways (parkland) throughout the District.”

The interconnectedness, of which the Whitehaven land is a vital link in this green necklace is readily apparent from even a quick look at a map of the District or an on-the-ground exploration—neither of which are to be found in the EA. Hikers can now walk from Rock Creek Park westward to Montrose Park, Dumbarton Park, Glover-Archbold Park, across the hilly Whitehaven parkland and on to the C&O Canal, the Capital Crescent Trail, and to the Potomac shore.

A proposed NPS trail on the Whitehaven tract outlined by the Park Service last August was subsequently removed in the amended NPS-Foundation agreement. This trail was eliminated reportedly because a neighbor objected to its site. But this person has encouraged location of a trail through the center of the Parkland—a reasonable alternative that would benefit the public but interfere with the foundation’s land grab.


The EA quotes an immensely relevant National Capital Planning Commission policy set forth two years ago in the Comprehensive Plan for Parks, Open Spaces, and National Features Element:

The narrow threads of natural green areas throughout the District, like Whitehaven Parkway … Glover-Archbold Park … should be protected and maintained to provide green background and open space amenity for the residential areas of the city. These natural areas should be protected form border development that would adversely impact their natural resources and visual quality…

A large guardhouse and fence will obscure the view from Foxhall Road. Those who cherish the serenity of these acres will have to trespass on private land to view this pristine habitat through black steel bar. This alternative, favored by the NPS and the foundation, defies NCPC’s sound social policy.

William J. Snape, III, vice president and chief counsel of Defenders of Wildlife national organization of some one million members and supporters, has written the Whitehaven tract is “… a popular hiking and feeding spot for federally protected migratory birds, including the potential of bald eagles; a biodiversity connector to Glover-Archbold National park and the Rock Creek National Park system; important land to Native Americans; valuable open and quiet space in a growing urban area, and, possibly the site of unique historic or cultural resources.” The committee recommends that the Casey Mansion Foundation Act to protect the buffer zone between Glover-Archbold Park and the Whitehaven tract, and its present property.

Mayor Williams is instituting policies to increase the District’s population by 100,000 people in the next ten years. Green space in our neighborhood and across the city will become even more valuable and under development pressures as population grows. Whitehaven should not be sacrificed so callously and unnecessarily.


The committee and the many other opponents of the parkland swap are not a flock of naysayers, opposed instinctively to any development. We believe this response to the EA clearly sets forth the carefully reasoned grounds for our opposition.

We urge the NPS in collaboration with the Casey Mansion Foundation and representatives of the larger community to explore ways to encourage schools to use the site creatively for environmental studies. NPS and the foundation will find many talented and experienced volunteers to assist in such a concerted effort.

In summary, this land deal should be vacated by NPS. The EA does not make a credible case for it. The foundation should move to fulfill its February 26, 2001 commitment to build a mayoral mansion, and the NPS should continue development of the Georgetown Waterfront Park. That’s a win-win situation for all parties, and for the people of Washington and the nation.

Casey Mansion Committee
Foxhall Community Citizens Association

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