1 Introduction and Background - GSA Development of St. Elizabeths ...

Introduction and Background 1121.A.2Prioritized Use of Government-Controlled Buildings/Sites versusLeased Buildings/Sites and Newly Acquired Buildings/Sites345678910111213141516171819202122232425262728When analyzing an agency’s needs and assigning space, GSA bases its recommendations on localmarket conditions, available vacant space, principles of professional space management, and thecustomer agency’s mission. GSA’s development decisions are guided by the principles laid outin Executive Order 13327: Federal Real Property Asset Management as established by the FederalReal Property Council (the Council). The Council’s ten guiding principles, applicable to Federalreal property asset management, include:1. Support agency missions and strategic goals2. Use public and commercial benchmarks and best practices3. Employ life-cycle cost-benefit analysis4. Promote full and appropriate utilization5. Dispose of unneeded assets6. Provide appropriate levels of investment7. Accurately inventory and describe all assets8. Employ balanced performance measures9. Advance customer satisfaction10. Provide for safe, secure, and healthy workplacesGSA satisfies customer agencies’ requests for space by first attempting to reassign availablespace in its inventory. In accordance with 41 CFR § 102-75.25, before it purchases non-Federalreal property, GSA fulfills real estate needs by utilizing real property determined excess by otheragencies. As well, 41 CFR § 102-73.255 directs GSA to consider the maximum utilization ofGovernment-owned land prior to the purchase of a privately owned site. Further, GSAconsiders the lease of privately-owned land and buildings only when needs cannot be metsatisfactorily in Government-controlled space, consistent with 41 CFR § 102-73.45.As a general matter, GSA uses Federally-owned sites or space whenever practicable to meetrequirements for computer and telecommunications operations, secured areas for nationalsecurity or defense, or permanent court space for the judiciary. GSA uses Federally-owned sitesFinal EIS Volume I – Campus Redevelopment 1-3

1 Introduction and Background123or space as much as possible whenever it is adequate, economically adaptable to agencies’requirements, and properly located.GSA utilizes lease alternatives where appropriate.451.A.3Certain Local Redevelopment and Historic PreservationConsiderations in Locating Federal Agencies6789101112131415161718In carrying out its duties to provide office space to Federal agencies, GSA is obligated to acquireand utilize space in suitable buildings of historical, architectural, or cultural significance unlessuse of the space would not prove feasible and prudent compared with available alternatives (40USC § 3306 ). Under 41 CFR § 102-73.255 “prior to acquiring, constructing, or leasing buildings(or sites for such buildings), [GSA] must use, to the maximum extent feasible, historic propertiesavailable to the agency.”This requirement has been further enunciated by various Executive Orders. Under ExecutiveOrder 11593, Protection and Enhancement of the Cultural Environment:“Agencies of the executive branch of the Government shall…initiate measuresnecessary to direct their policies, plans and programs in such a way that Federallyowned sites, structures, and objects of historical, architectural or archaeologicalsignificance are preserved, restored and maintained….”1.B The Department of Homeland Security191.B.1Mission and History of DHS2021222324252627Homeland Security is defined as: “A concerted national effort to prepare for, protect against, respond to, andrecover from all threats, hazards, and adverse incidents (natural or man-made) within the geographic UnitedStates or its territories. (DHS, 2008)”In the aftermath of the terrorist attacks on September 11, 2001, Congress passed the HomelandSecurity Act of 2002 which established the Department of Homeland Security (DHS) as anexecutive branch agency of the United States. The primary missions of DHS include preventingand deterring terrorist attacks, protecting against and responding to threats and hazards to theNation, ensuring safe and secure borders, welcoming lawful immigrants and visitors, and1-4 Final EIS Volume I – Campus Redevelopment

Introduction and Background 112345678910111213141516171819202122promoting the free-flow of commerce. DHS’ five near-term goals include: continue to protectour Nation from dangerous people; continue to protect our Nation from dangerous goods;protect critical infrastructure; build a nimble, effective emergency response system and a cultureof preparedness; and strengthen and unify DHS operations and management. These primarymissions and goals are not exhaustive, and DHS continues to carry out other functions of theagencies it has absorbed. DHS has also established strategic goals that provide the frameworkguiding actions that make up the daily operations of department. Those goals are as follows:Awareness -- Identify and understand threats, assess vulnerabilities, determine potentialimpacts and disseminate timely information to our homeland security partners and theAmerican public.Prevention -- Detect, deter, and mitigate threats to our homeland.Protection -- Safeguard our people and their freedoms, critical infrastructure, property and theeconomy of our Nation from acts of terrorism, natural disasters, or other emergencies.Response -- Lead, manage, and coordinate the national response to acts of terrorism, naturaldisasters, or other emergencies.Recovery -- Lead national, State, local, and private sector efforts to restore services and rebuildcommunities after acts of terrorism, natural disasters, or other emergencies.Service -- Serve the public effectively by facilitating lawful trade, travel, and immigration.Organizational Excellence -- Value our most important resource, our people. Create a culturethat promotes a common identity, innovation, mutual respect, accountability, and teamworkto achieve efficiencies, effectiveness, and operational synergies.The DHS organization includes the following headquarters elements and operating components:23Office of the Secretary28Chief Financial Officer24National Protection and Programs29Executive Secretariat25Directorate30Military Advisor’s Office26Science and Technology31Office of the General Counsel27Management32Office of Inspector GeneralFinal EIS Volume I – Campus Redevelopment 1-5

Introduction and Background 17778798081828384858687888990919293949596979899100101102103104105106and respond to threats and hazards to the Nation ensuring safe and secure borders; to welcomelawful immigrants and visitors; and to promote the free-flow of commerce. DHS’ missiondemands close coordination among its components, yet DHS’ legacy facilities and dispersedlocations throughout the NCR adversely impact critical communication, coordination, andcooperation across DHS Components. To effectively perform its mission, DHS needs toconsolidate executive program leadership at a single secure location, thereby allowing effectivecoordination of policy, management, and operational functions and facilitating incidentmanagement functions and command and control capabilities. This consolidation of policymanagement and operational functions at a single headquarters location will foster a “one-DHS”culture and optimize DHS’ prevention and response capabilities across the spectrum ofoperations.Given the strategic imperative to unify DHS operationally (see Appendix A, DHS NCR HousingMaster Plan) provides further information on this imperative), administratively and culturally,DHS is implementing comprehensive strategies to tear down stove pipes and remove physicalbarriers that impact mission performance. The goal of DHS headquarters consolidation is topromote effectiveness, efficiency, and readiness of DHS mission. In order to solve the spacemanagement issues underlying mission performance, DHS has worked closely with GSA todevelop planning level requirements for a consolidated campus, as well as a detailed Program ofRequirements for all DHS and Component functions throughout the NCR. DHS hasdetermined that a minimum collocation requirement of 4.5 million gross square feet of secureoffice space is required, and that it also must realign its real estate holdings as soon as possible toenhance mission performance.For further detail regarding DHS’ requirements, please see the DHS Consolidated HeadquartersCollocation Plan in Appendix A and the DHS National Capital Region Housing Master Plan inAppendix B.1.C St. ElizabethsSt. Elizabeths is located in Southeast Washington, D.C. It is situated in the Congress Heightscommunity and overlooks I-295, Bolling Air Force Base, the Anacostia Naval Annex, and theAnacostia River. The study area for the DHS Headquarters Consolidation includes the St.Elizabeths West Campus, the North Campus parcel of the St. Elizabeths East Campus. FiguresFinal EIS Volume I – Campus Redevelopment 1-7

1 Introduction and Background1071081-1 and 1-2 show the study area for the redevelopment of the DHS Headquarters at St.Elizabeths. 21091.C.1Ownership History of St. Elizabeths110111112113The U.S. Department of Health and Human Services and it predecessors controlled andoperated St. Elizabeths from its founding in 1852 until 2004. In 1987, the Federal Governmenttransferred the East Campus to the District of Columbia. The District has operated the hospitalon the East Campus since that time.1141.C.1.aGSA acquisition of the St. Elizabeths West Campus115116117118119120121122In January of 2001, the U.S. Department of Health and Human Services determined that theagency no longer had a need for the West Campus and declared the property “excess.” GSAtook custody and control of the campus in December of 2004, with the exception of fivebuildings still owned by the District: Hitchcock Hall, Hagan Hall, the Warehouse, theWarehouse Annex, and the Pump House. Under Public Law 109-396, these five buildings willbe conveyed from the District back to the United States Government. Currently the buildingson the West Campus are vacant. Since acquiring the site, GSA has spent $13.5M, to stabilize allthe buildings on the West Campus to prevent further deterioration and damage.1231.C.1.bGSA obligations for development of the St. Elizabeths West Campus124125126127128129130131GSA has identified a need to develop secure Federal office space in the WashingtonMetropolitan area. St. Elizabeths became available because the Department of Health andHuman Services (HHS) determined it excess to its needs. The Federal Management Regulation41 CFR § 102-75.25 requires landholding agencies such as GSA to fulfill their needs for realproperty, “by utilizing...real property determined excess by other agencies...before [they]purchase nonfederal property.” GSA considered St. Elizabeths and determined it is a viablelocation to house secure Federal office space so it requested the transfer of the property fromHHS to GSA in 2004.2 Volume II of this Final EIS analyzes transportation improvements which are part of the proposed action. Thestudy area for these transportation improvements includes the Malcolm X/I-295 interchange, the ShepherdParkway through which GSA proposes to build a new access road, Firth Sterling Avenue, and Martin LutherKing Jr. Avenue.1-8 Final EIS Volume I – Campus Redevelopment

Introduction and Background 1132133134135136137138139140141142143144145146147148149150151152153In addition, GSA has a process for formulating development projects including a review ofalternative strategies and locations for satisfying a programmatic requirement. This process isguided by the principles outlined in Executive Order 13327: Federal Real Property AssetManagement. GSA’s space acquisitions are driven by customer agency requirements. When arequirement is received, GSA looks to use existing Government-owned space first andsecondarily to vacant leased space already under contract from the private sector (41 CFR § 102-73.45).Utilization of the West Campus allows GSA and the taxpayer to avoid incurring unnecessary siteacquisition costs and potential lease costs. Also, the site becomes a long-term investment for theFederal Government.Most of the facilities on the St. Elizabeths West Campus have been vacant since the mid-1990s.The site is currently characterized by aging, unoccupied, and deteriorating largely historicbuildings and overgrown vegetation. However, the St. Elizabeths West Campus is the largestunused government property inside Washington, DC, and remains a valuable resource forFederal development. Redevelopment of St. Elizabeths would allow GSA to provide secureFederal office space to house Federal agencies in the city, while bringing Federal employees tothe Anacostia area. The St. Elizabeths West Campus is a secure property with potential for upto a 100-foot distance from the site perimeter to main buildings. The West Campus settingoffers the potential to bring the DHS Departmental functions together on one site increasingoperational efficiencies. The West Campus is easy to get to from I-295, and it is close to CapitolHill (a 15-minute drive or approximately 2.5 to 3 miles) and the White House (a 25-minute driveor approximately 4 miles) (see Figure 1-3).154Final EIS Volume I – Campus Redevelopment 1-9

1 Introduction and Background155156Figure 1-1. DHS Headquarters Consolidation – Campus Redevelopment Study Area1-10 Final EIS Volume I – Campus Redevelopment

Introduction and Background 1157158Figure 1-2. St. Elizabeths – Aerial Map159Final EIS Volume I – Campus Redevelopment 1-11

1 Introduction and Background160161Figure 1-3. St. Elizabeths in Relation to U.S. Capitol and the White House1621-12 Final EIS Volume I – Campus Redevelopment

Introduction and Background 11631641.C.21.C.2.aNational Historic Landmark StatusHistory of St. Elizabeths165166167168169170171172173174175176177178179180181182183184185186In the middle of the nineteenth century, Dorothea Dix began to campaign the FederalGovernment to build a model hospital for the mentally ill. She believed that the U.S.Government could provide humane care and enlightened curative treatment of the insane. In1852, Congress appropriated $100,000 for the construction of the “Government Hospital forthe Insane” in Washington, D.C. Dorothea Dix believed the St. Elizabeths site to be an ideallocation for the hospital and helped persuade the property’s owner, Thomas Blagden, to sell his185-acre tract to the Federal Government in1852.At that time, the St. Elizabeths tract haddirect access to the Anacostia River. Theflats on the river’s edge were filled aroundthe turn of the twentieth century. I-295, theNaval Annex, and Bolling Air Force Basenow occupy this reclaimed land.The architect of the U.S. Capitol, ThomasWest Campus CemeteryUstick Walter, worked with St. Elizabeths’first superintendent, Dr. Charles H. Nichols, to design the hospital’s first buildings. Mr. Walterwas the fourth architect of the U.S. Capitol (1851–1865). Additional development took place onthe West and East Campuses from the time of the hospital’s founding until 1937. During thistime, buildings were not only added to the campus, but also demolished. Figure 1-4 illustratessome of the important buildings which once stood on the site, but have been demolished overtime.187Final EIS Volume I – Campus Redevelopment 1-13

1 Introduction and Background188189190191During the Civil War, the hospital served soldiers wounded on nearby battlefields. A cemetery,previously established on the slope northwest of the Center Building, was also used to bury CivilWar veterans. 3 The cemetery was used to bury both black and white and Union andConfederate troops.1921.C.2.bNational Historic Landmark Designation193194195196197198199200201202203204205206207208209210211St. Elizabeths Hospital (both the East and WestCampuses) was listed in the National Register ofHistoric Places on April 26, 1979 (see Figures 1-4 and1-5). On March 7, 1991, the Secretary of the Interiordesignated the entire hospital a National HistoricLandmark (NHL). The NHL designation covers 82contributing resources including buildings,landscapes, vistas of the river and city, and the WestCampus Cemetery. Both campuses of the hospitalwere also listed in the District of Columbia’sInventory of Historic Sites on May 26, 2005.Designation of St. Elizabeths as an NHL recognizes Center Buildingits national significance and its exceptional value in illustrating the heritage of the United Statesin history, architecture, archeology, engineering, and culture. The designation also signifies thatthe site possesses a high degree of integrity of location, design, setting, materials, workmanship,feeling and association.St. Elizabeths satisfies NHL criteria 1, 2, and 4. Criterion 1 includes properties linked to eventsassociated with broad national patterns of United States history. St. Elizabeths representsimportant nineteenth and twentieth-century social and humanitarian movements associated with3 Although studies indicate that civilians, as well as military personnel, were buried in the West CampusCemetery, landmark documentation for the site, including the National Register and National HistoricLandmark nominations and the Historic Resources Management Plan, identify the site as the Civil WarCemetery. The Environmental Impact Statement will follow this convention to avoid confusion with thecemetery on the East Campus, which is known simply as the St. Elizabeths Cemetery, while acknowledging itsinaccuracy.1-14 Final EIS Volume I – Campus Redevelopment

Introduction and Background 1212213214215216217218219220221222223224225226227228229230231232233234235236237238239240241242243the advancements of mental health care. St. Elizabeths embodies the “moral treatment”philosophy of the mid-nineteenth century in its integration of physical activity andcontemplation of the natural and built environments as means to restore reason to its patients.The first Federal mental hospital in the United States, it represents an important variation of theKirkbride plan of mental health facilities, which maximized availability of light and fresh air forits patients. Throughout its history, St. Elizabeths was a leader in a pathological andpsychological research and pioneered a number of new therapeutic techniques, includingpsychoanalysis. Criterion 2 encompasses properties associated with nationally significantpersons. In the case of St. Elizabeths, these individuals include Dr. Charles H. Nichols andDorothea Lynde Dix, both of whom were national leaders in the treatment of mental illness, andexpatriate poet Ezra Pound who was committed to the hospital from 1946 to 1958. Criterion 4includes properties significant for their architecture or construction. St. Elizabeths is significantfor its Collegiate Gothic and Renaissance Revival architecture designed by the Architect of theCapitol, Thomas U. Walter, and the Boston architecture firm Shepley Rutan Coolidge. Nicholspresided over the first construction period for the hospital (1852 to 1877), which included theCenter Building and its additions. Thomas U. Walter was involved with the design of the CenterBuilding (Buildings #1, #2, #3, and #4) and the East Lodge (Building #30) during this period.During his administration (1877 to 1899), William W. Godding, the hospital’s secondsuperintendent, guided the construction of a number of smaller additions which are often called“cottage” buildings due to their residential scale. Superintendent Alonzo Richardson securedfunding for and initiated the expansion designed by Shepley Rutan Coolidge, which was begunin 1902 and completed by 1910 during the superintendency of William A. White. There are 10buildings remaining on the West Campus designed by Shepley Rutan Coolidge (Buildings #56,#60, #64, #66, #68, #69, #72, #73, #74, and #75). The period of significance for the NationalHistoric Landmark district was determined to be 1852 to 1940. For additional information onthe history of the West Campus, see Section 4.B.2, Historic Context.Prior to GSA’s jurisdiction of St. Elizabeths, the property was under the jurisdiction of the U.S.Department of Health and Human Services (HHS). In 1987, HHS transferred title of the EastCampus and five buildings on the West Campus to the District of Columbia. This transfer wasundertaken pursuant to Public Law 98-621, the Saint Elizabeths Hospital and District ofColumbia Mental Health Services Act. As a result of the Section 106 review of the transfer, aMemorandum of Agreement (MOA) on the preservation of St. Elizabeths was signed by theFinal EIS Volume I – Campus Redevelopment 1-15

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Introduction and Background 111.D Review Requirements21.D.1NEPA34567891011121314151617181920212223242526272829The National Environmental Policy Act of 1969, commonly referred to as NEPA, is theNation’s legislative charter for protection of the environment. NEPA requires Federal agenciesto consider environmental issues in Federal agency planning and decision-making. NEPArequires all Federal agencies to prepare an Environmental Impact Statement (EIS) for any majorFederal action significantly affecting the quality of the human environment. Under NEPAFederal agencies are required to 1) utilize a systematic, interdisciplinary approach in planning andin decision-making, and 2) include in every recommendation or report on proposals forlegislation and other major Federal actions significantly affecting the quality of the humanenvironment, a detailed statement, in this case an EIS, that assesses the impacts of that action.An EIS includes a detailed statement on environmental impacts of the proposed action;unavoidable adverse environmental effects, alternatives to the proposed action; the relationshipbetween local short-term uses of the human environment and maintenance and enhancement oflong-term productivity; and irreversible and irretrievable commitments of resources.Throughout the preparation of this EIS, GSA has sought input from the public and interestedparties on the proposed project and its potential impacts on the environment. GSA has heldpublic meetings from June 2005 through October 2008. For more information on public andagency coordination undertaken as part of the EIS process, please see Chapter 8, PublicInvolvement and Agency Coordination. As required, individuals and agencies were provided 45days to review the Draft EIS. During this review period, GSA held a public hearing to allow thepublic to learn more about the project and its potential impacts and to document comments andconcerns about the content of the Draft EIS. Responses to comments received during the DraftEIS comment period are included in Volume III of this Final EIS. There will be a 30-day publicreview period of this Final EIS, giving the public an additional opportunity to review the EIS,GSA’s responses to comments on the Draft EIS, and revisions to alternatives.Finally, GSA will publish a Record of Decision that will outline the selected alternative for theMaster Plan and describe measures the government will take to reduce adverse impacts from theredevelopment of the St. Elizabeths West Campus.Final EIS Volume I – Campus Redevelopment 1-21

1 Introduction and Background123456789101112131415161718192021222324252627282930Throughout preparation of the EIS, GSA consulted with numerous Federal and D.C. agencies,community groups, and members of the public. This consultation was intended to provideupdates on the project, solicit information on issues that could affect the outcome of the project,and seek input on alternatives and potential impacts. Chapter 10, Public Involvement andAgency Coordination, provides detail on this consultation.1.D.2 Section 106The National Historic Preservation Act (NHPA) of 1966, among other functions, governsFederal agencies in their handling of historic properties. Section 106 of the Act requires thatFederal agencies take into account the effects of their actions on historic resources. Under thisprovision, GSA must evaluate impacts to any district, site, building, structure, or object listed inor eligible for listing in the National Register of Historic Places (NRHP). If the historic propertysubject to an undertaking is a National Historic Landmark (NHL), Section 110(f) of NHPArequires the relevant agency “to the maximum extent possible, to undertake such planning andactions as may be necessary to minimize harmto such landmark” (see 1.D.3, Section 110).St. Elizabeths is listed in the National Registerand is a National Historic Landmark. Historicresources outside of the West Campus mayalso be affected by the redevelopment of theSt. Elizabeths West Campus. Chapter 6,Environmental Consequences, describes theimpacts the West Campus redevelopment willhave on St. Elizabeths and the other historicresources.Cultural resources are characterized asarcheological resources, historic structures,and cultural landscapes. “Historic properties”The National Register of Historic Places(NRHP) is the Nation's official list ofcultural resources worthy of preservation.Properties listed in the Register includedistricts, sites, buildings, structures, andobjects that are significant in Americanhistory, architecture, archeology,engineering, and culture.National Historic Landmarks (NHL) arenationally significant historic placesdesignated by the Secretary of theInterior because they possessexceptional value or quality in illustratingor interpreting the heritage of the UnitedStates.as defined by the implementing regulations of the NHPA (36 CFR 800), are any prehistoric orhistoric district, site, building, structure, or object included in, or eligible for inclusion in, theNRHP. This term includes artifacts, records, and the remains that are related to and located1-22 Final EIS Volume I – Campus Redevelopment

Introduction and Background 11234567891011121314151617181920212223242526272829within such properties, as well as traditional and culturally significant Native American sites andhistoric landscapes.The significance of historic properties is judged against a property’s ability to meet at least oneof the four criteria for inclusion in the NRHP:1) Association with events that have made a significant contribution to the broad patternsof our history; or2) Association with the lives of persons significant in our past; or3) That embody the distinctive characteristics of a type, period, or method of construction,or that represent the work of a master, or that possess high artistic values, or thatrepresent a significant and distinguishable entity whose components may lack individualdistinction; or4) That has yielded, or may be likely to yield, information important in prehistory orhistory.The historic properties may meet these criteria at the national, State, or local levels. Additionally,in order for a property to be listed in the National Register, it must possess historic integrity ofthose features necessary to convey its significance (location, design, setting, workmanship,materials, feeling, and association).GSA is working with the District of Columbia State Historic Preservation Office (DC SHPO),the Advisory Council on Historic Preservation (ACHP), the National Capital PlanningCommission (NCPC), the Department of Interior (DOI), the Federal Highway Administration(FHWA), DHS and other consulting parties to prepare a programmatic agreement that identifiessteps that will be taken to avoid, minimize, or mitigate adverse impacts on historic resourcesfrom the Master Plan development. The programmatic agreement will include design andlandscape guidelines, mitigation requirements, and will outline the process by which projects atSt. Elizabeths will be reviewed to ensure ongoing compliance with Section 106.Section 106 of the NHPA requires Federal agencies to afford the ACHP, the DC SHPO, andother consulting parties a reasonable opportunity to comment. If evaluation of an undertaking’simpact results in a finding of adverse effect on the historic property, the Federal agencycontinues consultation to resolve those effects.Final EIS Volume I – Campus Redevelopment 1-23

1 Introduction and Background1234567891011GSA formally notified the D.C. Historic Preservation Office (DCHPO) of the transfer ofmanagement of the St. Elizabeths West Campus from the Department of Health and HumanServices (HHS) on January 14, 2005. This notification also initiated Section 106 consultation forthe GSA Master Plan undertaking, for which GSA is the lead agency. GSA notified the ACHPand the National Park Service (NPS) of the undertaking and invited their participation in theSection 106 consultation by letter dated January 24, 2005. A list of consulting parties for Section106 review was determined, and consultation between GSA, the project team, review agencies,and consulting parties began in September 2005 and has continued through the Final EISpreparation period. In addition to consultation at these meetings, representatives of severalconsulting parties have relayed their ideas and concerns regarding St. Elizabeths through writtencommunication.12Agencies and Parties Invited to Participate in NHPA Consultation13Advisory Council for Historic28District of Columbia State Historic14Preservation29Preservation Office15American Society of Landscape30Friends of St. Elizabeths16Architects31Medical & Professional Society of St.17Anacostia Historical Society32Elizabeths Hospital18Area Neighborhood Commissions 8A,33National Association for Olmsted Parks198B, 8C, 8D, and 8E34National Capital Planning Commission20Brookings Institute35National Coalition to Save Our Mall21Committee of 100 on the Federal City36National Historic Landmarks Stewards22Cultural Landscape Foundation37Association23D.C. Preservation League38National Museum of Civil War24Department of Homeland Security39Medicine25District of Columbia Department of40National Park Service26Transportation41National Trust for Historic Preservation27District of Columbia Office of Planning42Office of Council member Marion Barry43Representative Eleanor Holmes Norton1-24 Final EIS Volume I – Campus Redevelopment

Introduction and Background 11St. Elizabeths Hospital3U.S. Commission of Fine Arts2United States Coast Guard4U.S. Federal Highway Administration567891011121314151617181920212223242526271.D.3 Section 110Section 110 of the NHPA defines Federal agencies’ responsibilities for historic preservationincluding the integration of historic preservation into Federal programs. Section 110 requiresthat:The agency head be responsible for preserving historic properties owned or controlledby the agency, and that agency gives priority to the use of historic properties to carry outagency missionsAgencies establish historic preservation programs, in consultation with the Secretary ofthe Interior, intended to locate, inventory and evaluate historic properties, in a timelymanner, under agency control or jurisdictionAgencies give full consideration when planning or considering approval of any actionthat might affect historic properties; consult with knowledgeable and concerned partiesoutside of the agency about its historic preservation-related activities; manage historicproperties in such a manner that considers the preservation of their historic,architectural, archaeological, or cultural values; and develop and use historic preservationplans that include historic contextsAgencies document historic properties and deposit resulting records in a repositorywhen historic properties are impacted by the agency or its licensed or permitted activitiesAgencies carry out their programs in accordance with NHPA and consider programsthat advance NHPA’s purposesThe Secretary of Interior review plans of transfer for surplus federal historic propertiesTo the maximum extent possible, agencies undertake planning and actions to minimizeadverse effects on National Historic LandmarksFinal EIS Volume I – Campus Redevelopment 1-25

1 Introduction and Background123456789101112131415161718192021222324252627281.D.4 Section 213Under Section 213 of the National Historic Preservation Act (16 USC § 470u), the Chairman ofthe Advisory Council on Historic Preservation (ACHP) may request input from the Secretary ofthe Interior on the effects of undertakings on historic properties. Specifically, the chairman mayrequest a report detailing the significance of any historic property, describing the effects of anyproposed undertaking on the affected property, and recommending measures to avoid,minimize, or mitigate adverse effects.In the fall of 2007, the ACHP requested that the Department of Interior prepare a report onGSA’s proposed redevelopment of the St. Elizabeths West Campus. The Interior Department’sreport (the “213 report”) was based on GSA’s Draft Environmental Impact Statement, and the4.5 million gross square foot alternatives contained therein for the consolidation of DHS’headquarters. The Interior report, dated November 6, 2007, concluded that the alternativespresented in the Draft EIS would potentially result in Interior’s consideration of de-designatingthe NHL, and that GSA should consider other options for redeveloping the site.As a result of the 213 report and through ongoing Section 106 consultation, GSA has eliminatedAlternatives 1 & 2 both from study in the Draft EIS and consideration in the 106 consultation;these alternatives were the most impactful alternatives to contributing resources. Further, GSAhas developed an additional alternative, Alternative 5, which reduces both office and parkingdensity on the West Campus and preserves the most intact areas of the NHL. Among otherplanning and actions, GSA has modified its Alternative 4 to respond to the Consulting Partyconsensus document (see Appendix D) by (i) reducing the parking ratio from 1:3 to 1:4 exceptfor 24/7 employees (24/7 employees represent approximately 1,300 of the 14,000), (ii)strategically locating new construction at the non-contributing warehouse site and the edge ofthe plateau west of the south lawn, and (iii) minimizing new construction within the historic coreof the upper plateau while promoting the preservation, rehabilitation and reuse of numeroushistoric buildings.The following table provides a more detailed summary of how Alternatives 4 and 5 take intoconsideration the preservation priorities identified in the Consensus Document.1-26 Final EIS Volume I – Campus Redevelopment

Introduction and Background 11Table 1-1. GSA Response to Section 213 ReportConsensus Document Preservation Priority Priority Detailed in Alternatives 4 and 51) appropriate siting, massing and height for newbuildings2) least objectionable demolition of and additions toexisting structures (both contributing and noncontributing).The core of the National Historic Landmark WestCampus contains three building periods, representingthe site’s development under Supervisor Nichols(1852-1877) Supervisor Godding (1877-1899), andSupervisor Richardson (1899-1903). This record ofdevelopment and its character-defining features –including the clusters of small, 19th century buildings,the 20th century “quadrangle” and associated settingsand landscapes –must be appropriately rehabilitatedand essentially preserved.The core of the National Historic Landmark WestCampus may, as specified in the parcel-by-parcelanalysis below, contain areas appropriate for thesensitive addition of carefully designed and sited newdevelopment.Major new development should be placed on theperiphery of the core, and should extend the clusteringor “quadrangle” design of the campus, characterizedby multiple buildings that relate to each other. Anymajor new development should appropriatelyincorporate significant landscape elements.New development should reference, enhance, and besubordinate to – not overwhelm – the setting, viewsand interrelationships of the existing campus. Theheight of any new buildings should not surpass theappropriate height limits specified below for eachparcel, and in no event should the height of any newbuilding exceed the height of the mass of the CenterBuilding (i.e., four floors) to ensure that building retainsits historic prominence.The height and massing of new buildings should beconsistent with adjacent buildings. Building footprintsshould be narrower than standard office buildings.The greater density is concentrated outside of the corehistoric area.Most of the new construction is located on the noncontributingwarehouse site and at the edge of theplateau west of the south lawn, where buildings wereremoved prior to the NHL designation. All buildingsare constrained below the height of the Center Buildingtower and where the mass of new buildings is higherthan four floors the buildings are located away fromexisting buildings and as distant from the CenterBuilding as possible.The response is to demolish all the non-contributingbuildings to clarify the history of the site while savingall the substantial contributing buildings with theexception of Greenhouses (eight buildings), theGeneral Store/Canteen (#39) and minor buildings suchas tool houses and fan sheds.The alternatives preserve each of these criticalsections of the campus by placing most newconstruction outside these core areas and by carefullyintroducing small new buildings and minor additions tohistoric buildings within these areas to enhance thereuse potential of the historic buildings. The AllisonQuad in parcel 1 is preserved and a new building isadded near Gate 2, configured to be compatible withthe existing buildings in footprint, height, overallmassing and siting to create an extended or new quadbetween the new and historic buildings. The 20thcentury quadrangle on the plateau is preserved.Historically there had been a building at the westernedge of the quadrangle; the new alternatives recreatethe western edge of the quad with new buildingssimilar in footprint and height to the existing buildingssurrounding the quad.The new development will adhere to design guidelinesthat encourage buildings with narrow footprints,appropriate height compatible with adjacent buildingsFinal EIS Volume I – Campus Redevelopment 1-27

1 Introduction and BackgroundConsensus Document Preservation Priority Priority Detailed in Alternatives 4 and 5Using the Center Building as a standard, a length ofunarticulated surface on a new building should notexceed 50 feet, and the width of any new buildingshould be limited to a maximum range of 75-90 feet.and articulated facades. In Alternative 4 typicalbuilding widths are 50 -75 feet and in Alternative 5buildings are 110’ wide.The view from the entrance of Gate 1 to the CenterBuilding and the “Point” should be preserved.Intrusion of development into the forested slopesshould be avoided, so as to protect to the maximumextent possible the character-defining view shed andsetting of the National Historic Landmark, as well asthe significant views into St. Elizabeths from themonuments, memorials, and other public areasthroughout the Washington, DC metropolitan area.Preservation, rehabilitation, restoration and newconstruction within the National Historic Landmarkshould adhere to the Secretary of Interior’s Standardsfor Treatment of Historic Properties.Construction and occupancy should be phased withthe rehabilitation and reuse of historic buildings as ahigh priority. No demolition of any contributing buildingshould occur until funding is immediately available fornew construction that requires the use of the specificsite, and until other contributing buildings have beenrehabilitated for adaptive reuse.All historic buildings should be put to appropriateproductive uses to enhance ongoing preservation andmaintenance of historic integrity.The new alternatives add no new construction abovegrade between Gate 1 and the Center Building or thePoint. In accordance with the design guidelines,security features in the vicinity of Gate 1 will besensitively sited and designed to be as unobtrusive aspossible.New development is built into the slope of the overlooksite (Parcel 4) onto the site of the current noncontributingwarehouse so as to minimize the amountof forested slope that is affected. By building into theslope the new development is intended to be lessvisible as part of the slope than the existingwarehouse.At the northwest corner of the site a new warehouseand delivery screening building is inserted into thetopography of the existing slope. Secondary growthforest cover in this area is removed and an openmeadow is reintroduced that will cover the newwarehouse building. The open meadow is a renewalof the historic character of the agricultural productionarea that existed on that portion of the site during theperiod of significance.The design guidelines will address preservation,rehabilitation, restoration and new construction for bothbuildings and landscape in accordance with theSecretary of Interior’s Standards for the Treatment ofHistoric Properties. The basis for appropriatepreservation or rehabilitation treatment for eachhistoric building will be based upon these guidelinesand either a Historic Structures Report (HSR) or aBuilding Preservation Plan (BPP).To the extent possible based on Congressionalfunding discretion, GSA places a high priority onrehabilitating and reusing historic buildings in concertwith new construction on the site. No demolition ofcontributing buildings will commence without havingfunding immediately available for new construction onthat particular site. See GSA’s phasing schedule forthe amounts of historic building rehabilitation and newconstruction to be included in each of the threeproposed phases of the project.Each historic building that will be preserved orrehabilitated will house either administrative office useor some shared general use. Wherever possibleexisting buildings will be reused to house original orsimilar functions. As examples, the dining hall (#33)will be proposed to house a cafeteria facility;gatehouses (#21 and #78) will be used as gatehouses,1-28 Final EIS Volume I – Campus Redevelopment

Introduction and Background 1Consensus Document Preservation Priority Priority Detailed in Alternatives 4 and 5Circulation PatternThe primary entrance should be at Gate 3 with asecondary entrance (if necessary) at Gate 2. Gate 1should be preserved as the ceremonial entrance.The historic roads and pathways should be maintainedand restored to the maximum extent practicable topreserve the historic circulation pattern of the campus.Any new roadways from Shepherd Parkway should bebuilt to National Park Service Standards for Parkways.the administration buildings (#73,# 74, #75) will houseadministrative uses. Other buildings will be looked atindividually to match the existing spaces to appropriatenew uses.The alternatives preserve Gate 1 as the principleentrance to the campus. The original configuration ofthe gatehouse and the historic gate will be preserved..Security apparatus will be housed in the gatehouse orsmall addition and vehicle barriers beyond the gate willbe designed to minimize visual appearance. Gate 2will be the primary visitor entrance. The existing gatewill be widened within the confines of the existing wallconfiguration. The gatehouse will be preserved.Security apparatus will be housed in the gatehouse orsmall addition and vehicle barriers beyond the gate willbe designed to minimize visual appearance. Gate 3will become an at-grade entrance exit point foremergency use only.To the greatest extent possible all the historicroadways and walkways will be maintained in theircurrent locations. Where possible new constructionwill occur within the existing roadway system. Thenew utility infrastructure on site will be placed withinthe area of existing sidewalks to minimize impacts tothe historic landscape.The new roadway through Shepherd’s Parkway will bebuilt to National Park Service Standards for Parkways.Large parking structures should be placed off-site.Security Perimeter and Public AccessAny required security barrier should be placed at theperimeter of the property line and designed tominimize impact to the National Historic Landmark.Perimeter fencing should intrude minimally into theviewshed from the Washington, DC area into the St.Elizabeths West Campus, perhaps by utilizingvegetation or trees as a screen.Regular public access should be provided to the Pointand the Civil War Cemetery.All parking is located on site, but now at a reducedratio of 1:4 except for emergency or operations centerpersonnel where the ratio is 1:3 (representing onlyapproximately 1,300 of the 14,000 employees). Asubstantial portion of the on site parking will be housedin below grade parking structures roofed withlandscaping.The double security fence is placed at the perimeter ofthe site for most of the north and west boundaries.The eastern wall along MLK Avenue will remain as theouter fence along that portion of the site. No physicalchanges to that wall are required. The perimeterdouble security fence along the southern portion of thesite will be placed to coincide with the southern edgeof parking structures on the west and along the edgeof the plateau skirting the wooded eagle protectionzone that occupies the southern portion of the site.Based on historic precedents, GSA and DHS areallowing regular, controlled public access to both theFinal EIS Volume I – Campus Redevelopment 1-29

1 Introduction and BackgroundLandscapeConsensus Document Preservation Priority Priority Detailed in Alternatives 4 and 5Point and Cemetery.Every effort should be made to preserve the maturetrees and landscape features of St. Elizabeths. In1892, Superintendent Godding described St.Elizabeths as grounds that are among the mostbeautiful in Washington. Rare trees imported byGodding’s son still exist and must be preserved. Thetherapeutic setting is a key characteristic of DorotheaDix’s treatment philosophy, and the landscape wascarefully planned to ensure that the mentally ill hadaccess to “pleasant surroundings” to aid in theirrecovery. This historic landscape is a highly significantfeature of the National Historic Landmark Campus.The significant landscape features, as described andcatalogued in the Cultural Landscape Report (CLR),have been carefully taken into account in theplacement and density of new development. The corearea landscape features are preserved and maintainedas are the historic woodlands. Also new developmentwill be constructed utilizing the existing topography tothe maximum extent possible to minimize visualimpacts to viewsheds. Where new landscape featuresare added they will be designed to extend, enhanceand rehabilitate the existing landscape treatments.Where possible degraded or missing historiclandscape features will be considered for preservation,rehabilitation or renewal .123456789101112131415As modified in the Final EIS, Alternative 4 will require demolition of 14 out of 62 contributingbuildings on the St. Elizabeths West Campus. Of these 13 buildings to be demolished, eight arethe extant greenhouses which are in extremely deteriorated condition with very low reusepotential. This modified Alternative 4 would remove only six contributing buildings on theWest Campus, in addition to the greenhouses. Alternative 5 would remove only threecontributing buildings on the West Campus in addition to the greenhouses. In any case, thenumbers of contributing buildings slated for demolition in the current alternatives ranges from25 to 11. If the greenhouses are excluded, the range of buildings that would be demolished onthe West Campus is reduced from 17 to 3 buildings.Impacts to landscape also vary across the alternatives, reflecting GSA’s efforts to undertakeplanning and actions to reduce impacts to the historic landscape features.By letter dated April 30, 2008, the Advisory Council on Historic Preservation has requested thatthe Interior Department prepare an updated 213 report to respond to GSA’s revised alternatives.The revised report is pending; to the extent possible, GSA will consider these comments in itsRecord of Decision.161.D.5Section 4(f)171819Section 4(f) of the U.S. Department of Transportation Act of 1966, as amended in 2005 (49U.S.C. 303(c) and 23 U.S.C. 138) applies only to the US Department of Transportation. Itpermits the use of publicly owned land from any public park or recreation area, wildlife or1-30 Final EIS Volume I – Campus Redevelopment

Introduction and Background 112345678910waterfowl refuge, or historic site (as determined by the officials having jurisdiction over the park,recreation area, refuge, or site) only if there is no prudent and feasible alternative to the use ofsuch land, and all possible planning has been undertaken to minimize harm resulting from thisuse.Section 4(f) compliance is required for the reconstruction of the Malcolm X/I-295 interchangeby the Federal Highway Administration (FHWA). Improvements to the interchange wouldrequire the use of land from the Shepherd Parkway, which is a Section 4(f) resource as a publicpark and as a historic site. A Draft Section 4(f) Evaluation was included in the Draft EIS. TheSection 4(f) Evaluation has been removed from this Final EIS and will be issued by FHWAseparately.111.D.6NCPC Review121314Under 40 U.S.C. § 8722, the National Capital Planning Commission (NCPC) has approvalauthority over site and building designs for Federal public buildings in the District of Columbiaand uses NCPC-approved Master Plans as the basis for subsequent reviews and approvals.151.D.7CFA Review161718192021The U.S. Commission of Fine Arts is an independent agency that advises the Federal andDistrict of Columbia governments on matters of design and aesthetics that affect the appearanceof the Nation’s capital. Under 45 C.F.R. § 2101.1(a), for public buildings to be erected in theDistrict of Columbia by the Federal Government, CFA comments and advises on the plans andon the merits of the designs before final approval or action.1.E Summary of Review Process221.E.1Original Notice of Intent2324252627Pursuant to the requirements of NEPA, the Council on Environmental Quality regulations (40CFR parts 1500-1508), GSA Order PBS P 1095.1F (Environmental considerations in decisionmaking,dated October 19, 1999), and the GSA Public Buildings Service NEPA Desk Guide,GSA published a Notice of Intent (NOI) to prepare an EIS for the proposed Master Plan forthe redevelopment of the St. Elizabeths West Campus in Southeast Washington, D.C. on June 7,Final EIS Volume I – Campus Redevelopment 1-31

1 Introduction and Background123456789101112131415161718192005. This notice defined the purpose of the proposed action as “develop[ing] secure officespace in the District of Columbia to accommodate substantial Federal operations.”GSA identified the need to redevelop the West Campus because (1) there is an immediate needfor secure Federal office space in the National Capital Region, (2) the site is within the Districtof Columbia boundary and proximate to the Central Employment Area (CEA), and (3) theexisting site is currently underutilized.At the time the NOI was published in June 2005, GSA had identified a need for approximately12 million gross square feet of secure Federal office space in the National Capital Region;however, the United States Coast Guard was the only potential tenant identified to be located atthe site. GSA undertook initial planning studies including preparation of a Land Use Feasibilitystudy to determine issues and constraints involved with redevelopment of the West Campus andto determine the reuse potential of historic buildings and the appropriate level and placement ofnew development on the campus. For additional information on the Land Use Feasibility Studysee Section 2.D.1.In addition, although neither specific tenants nor their requirements had been identified at thattime, it was important to GSA to get out to the community early to identify potential issues withredeveloping St. Elizabeths, irrespective of the particular tenants ultimately determined (see1A(1)(a), Scoping Meeting). The issues that were identified helped frame the early alternativesfor redevelopment.20211.E.2Initiation of Section 106 Consultation/Section 106 ConsultationMeetings222324252627282930At the start of the Section 106 consultation, the United States Coast Guard was the onlypotential tenant identified to be housed at St. Elizabeths; however, its tenancy was notconfirmed with the Consulting Parties until Congress appropriated design funds in October of2005. In a letter dated February 3, 2006, GSA notified the DCHPO, the ACHP, and theNational Park Service that it was redefining the St. Elizabeths West Campus undertaking as thepreparation of a master plan for up to 4.5 million gross square feet of tenant space (notincluding parking) to be provided through a combination of rehabilitation of existing buildingsand new construction. Further, the master plan would be developed to meet the programmaticneeds for two specific tenants.1-32 Final EIS Volume I – Campus Redevelopment

Introduction and Background 11234567891011121314151617181920212223242526272829303132In late 2005/early 2006, GSA identified Components of the Department of Homeland Security(DHS) as the potential future tenants of the site. Since that time, consulting party discussionshave focused on locating the DHS program at St. Elizabeths. As a follow up to the inclusion ofthe DHS program at St. Elizabeths in the Section 106 consultations, GSA provided a copy ofthe DHS National Capital Region Housing Master Plan (October 2006) to all consulting partiesin December of 2006. DHS, in coordination with GSA, prepared and submitted the Plan toCongress in October 2006 as required by P.L. 109-295 (FY 2007 Homeland SecurityAppropriations Act). The Plan outlines DHS’ required housing strategy for its Components anddesignated the need for 4.5 million gross square feet of office space to be collocated (seeDepartment of Homeland Security National Capital Region Housing Master Plan in AppendixA). It also identifies St. Elizabeths as the most viable location, based on GSA’s assessment ofpotential sites, for the DHS collocation requirement.On March 6, 2006, GSA met with representatives from the National Park Service’s NationalCapital Parks-East (NCP-E) region to discuss a proposal for an access road to the St. Elizabethsproperty that would be constructed on a portion of Shepherd Parkway. Shepherd Parkway andthe remains of two Civil War fortifications within its boundaries (Forts Carroll and Greble) areowned by the National Park Service. The forts were listed in the District of Columbia’sInventory of Historic Sites as part of the Civil War Fort Sites and Fort Circle Park Systemdocumentation on November 8, 1964. Shepherd Parkway was listed in the National Register onJuly 15, 1974, with revised documentation dated September 13, 1978.Section 106 review of the St. Elizabeths Master Plan undertaking was initiated based ondevelopment being limited to the West Campus. The role of the National Capital Region (NCR)of the National Park Service in the project was that of a consulting party due to the proximity ofits landholdings to St. Elizabeths. In a letter dated November 14, 2006, GSA notified theSHPO, ACHP and the NPS that the undertaking was being redefined to include potentialimpacts to Shepherd Parkway resulting from the construction of the access road and interchangeat Malcolm X Avenue, SE, on land within Shepherd Parkway under the control of the NPS.Lastly, in a letter dated October 10, 2008, GSA notified the SHPO, ACHP, and the NPS that theArea of Potential Effect for the undertaking was being expanded to include transportationimprovements needed to support the DHS Headquarters consolidation and to include potentialconstruction of up to 750,000 gsf of office space plus parking on the North Campus parcel ofthe St. Elizabeths East Campus.Final EIS Volume I – Campus Redevelopment 1-33

1 Introduction and Background12345678910111213141516When the government must impact historic resources, NHPA requires it to consult with localand Federal agencies responsible for historic preservation, local citizens, and groups with aninterest in historic preservation. In the case of St. Elizabeths, the District of Columbia HistoricPreservation Office is the local preservation planning agency that must be consulted. BecauseSt. Elizabeths is a National Historic Landmark, GSA must afford the Advisory Council onHistoric Preservation (ACHP) and the National Park Service (NPS) an opportunity to commenton the undertaking. The ACHP is an independent Federal agency with the duty to adviseFederal agencies on preservation issues. Impacts to historic resources can be in many formssuch as demolition of historic structures, alterations to landscapes, or changes in views.Throughout the project planning for the St. Elizabeths West Campus, GSA has sought inputfrom consulting parties on the impacts to the historic resources and ways to avoid and minimizeadverse impacts. GSA has been meeting with the Consulting Parties on St. Elizabeths sinceSeptember of 2005. As those meetings have progressed, GSA has been further refining itsdevelopment plans for the site including the tenant program.Complete minutes and presentation materials for these meetings are available atwww.stelizabethswestcampus.com.171.E.3Identification of DHS as Potential Tenant181920212223242526272829In late calendar year 2005, DHS approached GSA and requested assistance in meeting DHS’housing needs in the National Capital Region. GSA reviewed DHS’ space needs and hasdetermined that (1) within the NCR, DHS is operating in 40 locations and 70 buildings at thistime, which adversely impacts critical communication, coordination, and cooperation acrossComponents particularly in responding to significant natural disasters or terrorist threats; (2) theDHS Housing Master Plan requires certain core elements of its organization to be located on asingle campus, for reasons of both efficiency and organizational effectiveness (see Departmentof Homeland Security National Capital Region Housing Master Plan in Appendix A); (3) DHShas an immediate need for the consolidation of these core elements; (4) DHS requires thehighest level of secure Federal office space for its headquarters campus, including buffer zonesaround the perimeter of such facility; and (5) DHS headquarters is required by statute (4 USC §§71-72) to be located within the District of Columbia.1-34 Final EIS Volume I – Campus Redevelopment

Introduction and Background 112345678Based on these findings, there is a need to establish a secure campus within the District ofColumbia to house the consolidated headquarters and Components of DHS consistent withDHS’ housing plan. In addition, based on an analysis of alternative locations (see Chapter 3,DHS Alternative Locations Analysis), as well as consideration of applicable legislation regardingrelocation of the Coast Guard headquarters, GSA determined that the only reasonablealternatives for meeting the DHS space needs are alternatives involving the redevelopment ofthe St. Elizabeths West Campus or an alternative that includes development on both the Eastand West Campus.91.E.4Redefinition of Undertaking/Revised Notice of Intent1011121314151617On June 28, 2007, GSA reissued the Notice of Intent to prepare an Environmental ImpactStatement for the redevelopment of the St. Elizabeths West Campus in Southeast Washington,D.C., to house the headquarters of DHS and its Components in accordance with the DHSNational Capital Region Housing Master Plan. The revised Notice of Intent defined the primarypurpose of the proposed action as “developing secure office space in the District ofColumbia to house the consolidated headquarters of the Department of HomelandSecurity (DHS) and its Components in accordance with the DHS National CapitalRegion Housing Master Plan.”18Final EIS Volume I – Campus Redevelopment 1-35

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