St. Elizabeths Hospital: A Q&A on Section 4(f)

Posted on: February 5th, 2009 by National Trust for Historic Preservation


The National Trust for Historic Preservation recently submitted comments to the Federal Highway Administration (FHWA) regarding its Section 4(f) evaluation of the proposed redevelopment of St. Elizabeths Hospital in Washington, D.C. Section 4(f) of the Department of Transportation Act is the strongest federal preservation law available because it prohibits federal approval of or funding for transportation projects that "use" any historic site, public park, recreation area or wildlife refuge unless there is "no feasible and prudent alternative" to the use of the site and the project includes "all possible planning to minimize harm."

The following Q&A is meant to shed light on both our ongoing work to protect St. Elizabeths Hospital, as well as some of the lingering questions and controversies surrounding its proposed redevelopment as the new headquarters for the U.S. Department of Homeland Security.

Question: What does the development of St. Elizabeths have to do with the FHWA?

Shepherd Parkway

Shepherd Parkway (Click Image for Full View)

The scale of the development at St. Elizabeths (and the decision to relocate 14,000 employees to the proposed Homeland Security headquarters there) would require expanded access to I-295 in order to avoid gridlock. Any interchange construction or expansion connecting to an interstate highway requires approval by FHWA, regardless of whether or not the road construction will be paid for with federal transportation dollars. That FHWA approval triggers the need for a Section 4(f) evaluation.

The current plans for St. Elizabeths include a major expansion of an existing interchange on I-295, the installation of massive retaining walls (up to 57 feet high) along steep slopes, and the construction and widening of additional access roads. This proposed access road has the potential to impose substantial adverse impacts on a large swath of land owned by the National Park Service (NPS) known as Shepherd Parkway.

Question: Why is this decision so crucial?

All federal agencies involved in the Homeland Security headquarters project – including the General Services Administration (GSA), the Department of Homeland Security and the National Capital Planning Commission – have adopted an explicit condition that the project will not go forward unless and until an access road through Shepherd Parkway is approved. Even construction of the Coast Guard Headquarters building, which is currently being designed as the first new building on the campus, cannot begin without approval of the new access road. Meanwhile, as the owner of Shepherd Parkway, NPS has refused to allow its land to be paved over to facilitate a project that would destroy public parkland and irreparably damage a National Historic Landmark. Thus, if NPS refuses to transfer its land and/or FHWA concludes that the stringent legal requirements of Section 4(f) have not been satisfied, GSA will be forced to develop a different and less harmful plan for St. Elizabeths Hospital.

Question: Why was the Section 4(f) evaluation completed after GSA's decision to develop the Homeland Security headquarters at St. Elizabeths?

Section 4(f) evaluations typically occur during the early development phase of a project, and are performed contemporaneously with a National Environmental Policy Act evaluation and a Section 106 evaluation. These evaluations are published in a draft Environmental Impact Statement (EIS), which is circulated for comment by the public. Federal agencies use this document to assess a wide range of possible alternatives before undertaking work on a particular project. By conducting Section 4(f) evaluations early in the process, federal agencies have a greater opportunity to evaluate all the possible ways a project can be designed to avoid or minimize harm.

This, however, was not the case for St. Elizabeths, since the Section 4(f) evaluation occurred after GSA’s final EIS was issued. By this point in the process, GSA had already determined the course of action it would take, which severely narrowed and foreclosed the range of alternatives to avoid and minimize harm that FHWA considered in its own evaluation.

Click here for the full text of the National Trust's comments on the Environmental Impact Statement.

Question: What points were made in the National Trust’s comments?

Our comments on the Section 4(f) evaluation of St. Elizabeths focus on numerous flaws in FHWA’s analysis. In particular, FHWA made several false assumptions and omissions in its limited evaluation, failing to fully examine the project’s entire transportation management plan. FHWA also neglected to consider the long-running objections by the Department of the Interior and NPS to the use of Shepherd Parkway. FHWA’s failure to consider these objections directly conflicts with its own Section 4(f) policy. All of these flaws led to a blatantly deficient analysis of the project, which the National Trust and NPS believe is not legally sufficient to satisfy Section 4(f)’s requirements (i.e. there is “no feasible and prudent alternative” to the use of a protected site and the project includes “all possible planning to minimize harm”).

The full text of the National Trust’s comments is available here. In addition to our comments, other comments objecting to the 4(f) evaluation were submitted by the Department of the Interior/National Park Service and the Maryland Native Plant Society, Inc.

Learn more about St. Elizabeths Hospital, which was listed in 2002 as one of America's 11 Most Endangered Places, and visit the project's online document center for more information.

 - Ross Bradford

Ross Bradford is an assistant general counsel for the National Trust for Historic Preservation.

The National Trust for Historic Preservation works to save America's historic places. Join us today to help protect the places that matter to you.

National Trust for Historic Preservation

National Trust for Historic Preservation

The National Trust for Historic Preservation, a privately funded non-profit organization, works to save America's historic places.

Why (Teaching) Preservation is Cool

Posted on: February 4th, 2009 by Guest Writer 1 Comment



Our roving reporter in action.

As preservationists, we all have our short list of what makes us tick. It’s the historic home we live in, or that old drug store around the corner, or those stunning petroglyphs in Utah, or the newly-conserved Star-Spangled Banner at the Smithsonian, or…

You get the point, but what about younger generations? What about “those kids today?” Is appreciating the past cool enough to cut through all the clutter and distractions hurled at them by MTV, MySpace and their Nintendo Wiis?

Well, according to the seniors in Paul LaRue’s Research History class, the answer is a resounding yes. To prove it, student Tyler K. set off as our roving reporter today, asking his classmates what they really think about their many preservation-focused class projects. Not only are they doing field work in Good Hope Cemetery (which we'll be documenting here all semester), they're also transcribing the stories of veterans who severed in all of our country's wars through the Library of Congress Veterans History Project.

(And for the record, “Lash” is their nickname for their esteemed teacher, Mr. LaRue. If you’re suddenly reminded of old western movies, you’re dead on.)

Dennis A. – "Through the Vietnam transcripts that I’ve worked on, I’ve become accustomed to preserving the stories of those people who risked their lives for our freedom. Listening to stories about the era during which my father risked his life has given me a new outlook on life. It has also introduced me to some wonderful people in the process."

Jeremy M. – "Preserving things today is cool because I’m not only benefiting my generation’s education and knowledge, I’m benefiting all the generations to come after me."

Alyssa D. – "Preservation is good because it saves the valuable history of our town. I have the opportunity to write an article about a Civil War veteran in Fayette County. I also enjoy typing up all the transcripts that my fellow classmates work on."

Shannon M. – "Through our class, my respect for veterans has grown. I have enjoyed listening to their honest, first-person accounts of what they experienced. Each day, I am surprised at how much more I learn through the projects we work on, whether it’s researching and writing articles – like how Thomas Edison might have worked in our own town – or listening to transcripts. I’m definitely going to miss this class and listening to the amusing discussions the freshman have with Lash over economics."

Jon A. – "Listening and writing down transcripts is a major part of my day. It has been very interesting hearing first-hand experiences from World War II veterans. It has been especially rewarding since I had the chance to transcribe my own grandfather’s tape."

Matt M. – "Preservation is important because you have a chance to not only save something forever, but to learn about the stories that you are making immortal. When you research, you obtain information from primary sources that will not only live with you forever, but with all of those who wish to see your preserved work."

Jackie P. – "Preservation gives you an opportunity to get your nose of out the textbooks and into the past. You gain knowledge from first-hand accounts of historic events that happened in the world, your country and even your hometown. Preservation gives you the ability to capture a moment in history instead of reading someone else’s efforts to describe those events."

... Read More →

The National Trust for Historic Preservation works to save America's historic places. Join us today to help protect the places that matter to you.

Guest Writer

Although we're always on the lookout for blog content, we encourage readers to submit story ideas or let us know if you've seen something that might be interesting and engaging for a national audience. Email us at

The Stimulus Plan Straight Up

Posted on: February 3rd, 2009 by Jason Clement 1 Comment



Want someone to tell it like it is? Check out our new webpage dedicated to tracking the stimulus plan.

If you turn on the TV right now, you're likely to hear about one of three things: 1) Former Senator Tom Daschle withdrawing his nomination to head the Department of Health and Human Services, 2) House Republicans and their laundry list of complaints over the Senate's stimulus package, or 3) President Barack Obama commenting on Jessica Simpson's weight during a Super Bowl Sunday interview with Matt Lauer.

Tomorrow, the graphics and the story lineups will change, but one thing will remain certain: the freight train of news generated by President Obama and the many people and ideas that he has brought to Washington won't be slowing down anytime soon.

If you're like me though, you really don't care about who snubbed whom on the Hill or who didn't pay their taxes. What matters are those sick-to-your-stomach headlines about who got laid off where today. Forget the he-said-she-said game; when are we going to see real relief?

If you feel the same way, you'll be happy to know that the National Trust has launched a new tracking and analysis webpage dedicated to the stimulus plan and the many hurdles it must clear before landing with thud on the Oval Office desk.

This is your resource for tracking the plan through the wiles of Washington, as well as monitoring how it will impact historic preservation in your neighborhood and across the country. You'll also find a special section for your feedback and ideas, which we hope you'll all use.

So join (and bookmark) us today as we continue to track what matters most. We promise it'll be Jessica Simpson-free.

Check it Out: The Stimulus Plan Straight Up

The National Trust for Historic Preservation works to save America's historic places. Join us today to help protect the places that matter to you.

Jason Clement

Jason Clement

Jason Lloyd Clement is the director of community outreach at the National Trust, which is really just a fancy way of saying he’s a professional place lover. For him, any day that involves a bike, a camera, and a gritty historic neighborhood is basically the best day ever.

Teaching Preservation: Digging Out & Catching Up

Posted on: February 2nd, 2009 by Guest Writer 3 Comments



Pink: The Official Color of Data Entry

On Tuesday, January 27, we received five inches of snow. On Wednesday, January 28, we received one inch of ice. And then later on Wednesday, we received another five inches of snow.

Sound fun? Welcome to winter in Ohio.

Unlike many across the country who were hammered by last week’s massive snow storm, we never lost power. What we did lose, however, was four consecutive days in the classroom. Oh darn.

Today, we’re back in school after digging out from our supersized weekend, which means that it’s time to pick up where we left off with our ongoing database project for the Good Hope Cemetery.

When we started, we were given 2,180 names, birth dates, and death dates for those buried at Good Hope. Between the two of us, it has taken about 13 hours to enter them into a spreadsheet document. To fight the boredom factor, we split the names up and turned the whole process into a contest. (One of us is winning by ten pages.)

Overall, it has been tedious, but the community will benefit from having a clearer picture of those who rests at the cemetery.

Oh, and if we disappear again for a few days at a time, check our weather forecast. Tuesday and Wednesday are already lookin’ a little iffy…

- Alyssa S. & Lynne M.

Alyssa S. and Lynne M. are seniors at Washington High School in Washington Court House, Ohio. This semester, they'll be working with their Research History classmates to document and preserve Good Hope Cemetery. Stay tuned as they share their experiences here on our blog and on their Flickr photostream.

The National Trust for Historic Preservation works to save America's historic places. Join us today to help protect the places that matter to you.

Guest Writer

Although we're always on the lookout for blog content, we encourage readers to submit story ideas or let us know if you've seen something that might be interesting and engaging for a national audience. Email us at


Cardiopulmonary Spatialization: Can architecture affect one's medical condition? "The sensorial experience of architecture could play a role in healing" or, as the project's owner explains, "spaces themselves should act as experiential platforms that provide a broader spectrum of environmental qualities, so that we may better understand their effects on our psychology – and ultimately, on our physiology." [BLDGBLOG]

DC and the Height of Power: "As other American fiefdoms fade, Washington looms larger than ever." [Washington Post]

Forney House Falls: A sad day for New Jerseyans who value the landmarks and neighborhoods that give our communities character:  the Forney House, the stately 19th century house and clinic on Milltown’s (Middlesex County) Main Street, was demolished over the weekend, to be replaced with a drive-through facility for Valley National Bank. [PreserveNJ]

We Built This City...: Architect Teddy Cruz tracks a new kind of urban ecology: Across the border from San Diego in Tijuana, a spontaneous urban space is taking shape off the radar of city planners, as an affluent city sheds its aging houses and its pieces are reassembled into creative dwellings for the poor. [The Nation]

Historic Equals Safe: "Transportation researchers Wesley Marshall and Norman Garrick fed the facts from more than 130,000 vehicular crashes into their computers in recent months, hoping for a systematic answer to a life-and-death question: How can America’s streets and roads be made safer?" This study shows that older streets are safer than those in newly developed areas. [New Urban News]

Azerbaijan’s Carbon Neutral Zira Island:
Zira Island is a 1,000,000 sq meter island In the Caspian Sea that will soon be developed into an incredible eco-community and sustainably built resort. [Inhabitat]

And It's Groundhog Day!

The National Trust for Historic Preservation works to save America's historic places. Join us today to help protect the places that matter to you.