Minutes for CFA Meeting — 16 May 2019

The meeting was convened in the Commission of Fine Arts offices in the National Building Museum, 401 F Street, NW, Washington, D.C. 20001, at 9:09 a.m.

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

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

I. Administration

A. Approval of the minutes of the 18 April meeting. Secretary Luebke reported that the minutes of the April meeting were circulated to the Commission members in advance. Upon a motion by Mr. Powell with second by Mr. Dunson, the Commission approved the minutes.

B. Dates of next meetings. Mr. Luebke presented the regularly scheduled dates for upcoming Commission meetings, as previously published: 20 June, 18 July, and 19 September 2019. He noted that no meeting is scheduled in August.

C. Anniversary of the establishment of the Commission of Fine Arts, 17 May 1910, and the Shipstead-Luce Act, 16 May 1930. Mr. Luebke acknowledged the Commission's two anniversaries falling in May: the 109th anniversary of the Commission's establishment and, on this day, the 89th anniversary of the Shipstead-Luce Act.

D. Report on the pre-meeting site inspections. Mr. Luebke reported the Commission's inspection the previous afternoon of the sites for several projects on the agenda. Chairman Powell suggested that comments from the Commission members could be provided in conjunction with the reviews on the agenda (see items II.A.1, II.A.2, and II.G.1).

II. Submissions and Reviews

A. Appendices

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

Appendix I – Government Submissions Consent Calendar: Mr. Lindstrom said that no changes have been made to the draft appendix. Upon a motion by Mr. Dunson, the Commission approved the Government Submissions Consent Calendar.

Appendix II – Shipstead-Luce Act Submissions: Ms. Batcheler said that the recommendation for one project (case number SL 19-136) has been changed to be favorable based on changes to the design, and the listing of the submission type for one project (SL 19-140) has been changed from concept to permit. Four projects listed on the draft appendix (SL 19-111, 19-133, 19-141, and 19-150) have been removed and will be held open for review in a future month. Other changes are limited to minor wording adjustments. The favorable recommendations for six projects are subject to further coordination with the applicants; she requested authorization to finalize these recommendations when the remaining issues are resolved. Upon a motion by Ms. Gilbert, the Commission approved the revised Shipstead-Luce Act appendix. Mr. Luebke noted the unusually large number of Shipstead-Luce Act submissions through much of the past year.

Appendix III – Old Georgetown Act Submissions: Ms. Stevenson reported that the appendix has 37 projects; the only change to the draft appendix is to note the receipt date for the revised drawings for five projects. Upon a motion by Mr. Krieger with second by Mr. Dunson, the Commission approved the revised Old Georgetown Act appendix.

At this point, the Commission departed from the order of the agenda to consider items II.D, II.F.2, and II.F.4. Mr. Luebke said that the Commission may wish to act on these concept submissions without a presentation.

D. U.S. Department of Agriculture

CFA 16/MAY/19-5, Jamie L. Whitten Federal Building (USDA headquarters). Staff parking lot #9, 12th Street and Independence Avenue, SW. Site improvements and perimeter security plan. Concept. (Previous: CFA 15/MAY/14-1.) Secretary Luebke noted that this project is part of a larger master plan for site improvements at the USDA headquarters complex; the proposal is for perimeter security around an existing parking lot that is also used for a weekly farmers market. Upon a motion by Mr. Powell with second by Mr. Krieger, the Commission approved the submission and delegated review of the final design to the staff.

F. District of Columbia Department of General Services

2. CFA 16/MAY/19-8, KIPP DC M.C. Terrell Campus/Somerset Prep DC Public Charter High School (formerly Mary Church Terrell Elementary School), 3301 Wheeler Road, SE. Building modernization and additions. Concept. Secretary Luebke noted that the staff is satisfied with the design, but this project is too large to be eligible for inclusion on the Government Submissions Consent Calendar. Upon a motion by Mr. Krieger, the Commission approved the submission and delegated review of the final design to the staff.

4. CFA 16/MAY/19-10, West Elementary School, 1338 Farragut Street, NW. Replacement building. Concept. Mr. Krieger asked if any members of the public have requested to address the Commission concerning this project. Secretary Luebke said that no requests have been received, and the project has not been controversial; he noted that another school project, with more substantial community interest, remains on the agenda for presentation later in the day. Upon a motion by Ms. Meyer with second by Mr. Krieger, the Commission approved the submission and delegated review of the final design to the staff.

The Commission returned to the order of the agenda with item II.B.1.

B. Smithsonian Institution

1. CFA 16/MAY/19-1, National Museum of the American Indian, Maryland Avenue at 3rd Street, SW. National Native American Veterans Memorial. Concept. (Previous: CFA 21/FEB/19-1.) Secretary Luebke introduced the proposed concept design for the National Native American Veterans Memorial, to be located on the grounds of the Smithsonian's National Museum of the American Indian at Maryland Avenue between 3rd and 4th Streets, SW. This memorial will honor people from native communities in the United States who have served in the country's military. He summarized the Commission's comments from the information presentation in February 2019: the Commission had expressed strong support for the proposed location and for the basic design scheme, while raising issues regarding the project scope and the complexity of the proposed elements. He said the project team has returned with a more developed concept submission that includes adjustments to the design, and he noted that several Commission members had visited the site the previous afternoon. He asked Ann Trowbridge, associate director for planning at the Smithsonian, to begin the presentation.

Ms. Trowbridge introduced several members of the design team: artist Harvey Pratt; architects Hans Butzer and Tori Butzer of Butzer Architects and Urbanism; landscape architect Elliot Rhodeside of Rhodeside & Harwell; and Alyson Steele of Quinn Evans Architects. She said they have been working to address comments provided by the Commission and from within the Smithsonian, and they have meet with representatives of the National Park Service to discuss the logistics of operating a memorial. She anticipated that the project will return to the Commission with a final design submission in the fall of 2019. She asked Mr. Butzer to present the design.

Mr. Butzer said that the project team has held meetings with Native American communities throughout the country, which made clear that the new memorial should be located on the north side of the museum grounds in order to be adjacent to the National Mall. He presented photographs of the selected site near Jefferson Drive and 3rd Street, including key views southwest from the intersection looking through the memorial site toward the museum building, and from the Welcome Plaza at the museum entrance looking northeast toward the memorial site. The view from the Welcome Plaza, looking across a wetland landscape, will suggest to visitors the presence of the memorial and encourage them to enter via its approach path, which begins among the "grandfather" rocks on the Welcome Plaza's north side, adjacent to the prayer circle dedicated to the late Sen. Daniel K. Inouye. The memorial site would be partly obscured by the existing landscape forms constructed to evoke the landscape typologies of the Chesapeake Bay region.

Mr. Pratt presented the memorial design. He emphasized that Native people are both the same as and different from each other; they hold similar conceptions concerning the significance of natural elements, directions, and cardinal points, and the memorial design is based on these shared beliefs. The central feature would be a large stainless steel circle, the Warriors' Circle of Honor, that would be set vertically on a granite drum representing the idea of calling people to gather at a ceremony. Water will flow from inside the drum, across its top surface and down its sides; on special occasions, a flame would be lit in the center of the drum, at the base of the Circle of Honor. A circular array of benches would define a precinct around the Circle of Honor. The memorial is organized as a series of concentric circles—the approach path leads to a Path of Life that runs outside the circle of benches, with four openings allowing access to an inner path, the Path of Harmony, circling around the Circle of Honor. The circular form of the Warriors' Circle of Honor is meant to symbolize, in Native American belief, the hole in the sky where the Creator lives and where prayers pass through. He said that when visitors reach the Path of Harmony, they will join in harmony with the four traditional elements of earth, air, fire, and water. The Native Path would circle the benches and exit to the west, representing a path followed by Native people.

Mr. Pratt said that mounted on the backs of the benches flanking the north and south openings would be pairs of large stainless steel lances, twelve to fourteen feet high, with eagle feathers hanging from battle pennants at their top points. The feathers, lance points, and battle streamers would all be molded bronze; the combination of feather designs would be different on each pole. At the bottom of each lance would be an area where visitors can attach tribal medicine bags or prayer cloths to honor war veterans and their mothers.

Mr. Butzer summarized the three main comments made by the Commission at the February 2019 information presentation: further study of the memorial's intended use to help determine the appropriate scale; ensuring that the memorial creates different types of spatial enclosure, closed and intimate versus open; and incorporating areas where people with disabilities can sit comfortably. He described how these issues have been addressed. To refine the spatial dimensions, the diameter of the memorial circle has been reduced from 50 feet to 46.9 feet. To enhance the sense of enclosure, the height of the bench seatbacks has been varied; this will help to create different levels of enclosure, to mitigate disturbance from nearby traffic, and to open up views of the wetland. Finally, the memorial design has been adapted to create different types of spaces that can be occupied by wheelchairs or people standing. The expanding circles of paving, benches, and other details would represent vibrations emanating from the central drum. He said that pedestrian circulation would trace a calm and sinuous movement through the memorial. Structurally, the memorial is intended to "lie lightly on the ground." Although the first segment of the approach path would be a slab on grade, this would change to a walkway set on piers, floating above the landscape and culminating at the Circle of Honor.

Mr. Krieger asked for clarification of the black line shown on the plan along the north side of the approach path. Mr. Butzer responded that this line delineates the path's continuous curve and varying edge conditions: first open; then defined by a granite wall, also serving as a retaining wall, that contains the memorial's name and military seals; then opening up again to the forested landscape. A railing on the south would define the edge of the path along the wetland.

Mr. Butzer provided additional details of the proposed dimensions. The average width of the approach path would be eight feet, intended to accommodate the varying numbers of people expected for different events; he noted the minimum passing width for wheelchairs of five feet. The overall width of the Path of Life would be at least six feet; part of it would be cantilevered over the wetland to give the memorial the appearance of floating on a thin structure. Seats would be cut back at four locations to accommodate pairs of wheelchairs. The bench backs would gradually rise toward the northeast corner of the site, creating a greater sense of privacy near the street traffic; the reduced height toward the southwest would open up views of the wetland. The design for the railing along the approach path was inspired by the shape of the museum building and the fluttering quality of leaves; the railing would incorporate lighting, and the approach path would also have a low guard edge.

Mr. Rhodeside said the goal for the new memorial design is that it be light in touch, as minimalist as possible, and respectful of existing landscape features—such as by protecting as many trees as possible, although five would have to be removed for construction. He said the area of disturbance would be limited to approximately 5,000 square feet, and this area would be restored afterward through the addition of shrubs and herbaceous plants. Two new landscape features would be added: larger aquatic plants that are sculptural in form and compatible with the railing design would be installed along the approach path, and lower aquatic plants would be added where they would not interrupt views toward the memorial from the museum's entrance plaza. He said that where the approach path and memorial appear to hover, the existing grade would remain and the roots of the birch trees would not be affected; the goal is to preserve the veil of trees and allow the memorial to sit within a mature landscape.

Ms. Meyer said that on the site visit, she was struck by the remarkable quality of the landscape, and also its fragility; she noted that erosion is already occurring. She emphasized that this environment will need great care during construction; she asked if the scope of work calls for its protection, and if an erosion and landscape and protection plan would be developed before construction begins. Mr. Rhodeside responded that a protection plan will be included, and he emphasized that the design team has been sensitive to the existing landscape. He acknowledged that since the initial construction of the museum landscape, the wetland has grown larger due to erosion, and further erosion during memorial construction will make it still larger. The proposal calls for adding erosion control around the perimeter of the wetland, in part through the installation of deeply rooted plants. He added that limiting the area of disturbance would also help protect the landscape. Ms. Meyer also questioned whether the change in the height of the bench backs should be a gradually sloped line or two distinct heights.

Mr. Krieger said he had not been present for the information presentation, but he finds the design beautiful, both physically and in its symbolism. He offered several minor comments. He questioned the need for the decorative railing along the approach walk; although it would provide protection and safety, he said the railing design is too dominant, dark, and substantial when it should be subordinate to the primary memorial elements of forest, ring, and lances. He questioned whether the experience of moving through the landscape would be improved by the presence of this railing, and he advised simplification. He also questioned the sloping bench backs, suggesting that this line may be so subtle that it would be difficult to perceive. He recommended slightly emphasizing the slope, either by raising one end or lowering the other, so that it clearly rises and falls while providing enough back support for visitors. Finally, he expressed appreciation for the veiled effect of the view from the museum's Welcome Plaza toward the wetland and the memorial, but he observed that the existing plantings are overgrown. He asked how clearly visible the memorial should be, commenting that a determination of how much to prune this opening is an important part of the design. Mr. Rhodeside agreed that the plantings will require careful management; he said that while the view of the wetland was originally intended to be open, the scrim of vegetation is beautiful.

Ms. Meyer said that the Commission members clearly are generally supportive of the design's progress; most of her comments concern how to make sure the proposal and the site work together. Referring to a section drawn through the site and building, she said that the scrim of vegetation between the Welcome Plaza and the wetland serves to define space, and it has two roles: enclosing the space and veiling the pond. She emphasized the need for a substantial planting mass there because the building is so large it is almost overwhelming, and a mass of vegetation on that arc will insert a scale between the museum building and the memorial. She cautioned that any pruning of this edge needs to be judicious, subtle, and not lowered to waist height. She stressed the importance of avoiding a large, clear view to the memorial; such a view would diminish the experience of visiting it, because visitors at the memorial cannot be in a contemplative mood if they are visible to people casually walking through the Welcome Plaza. She summarized that the veil of vegetation must be substantial, with just a little clearing to suggest the view of the memorial.

Ms. Meyer emphasized the landscape's richness and diversity as a habitat, which includes many species of birds and aquatic plants. She emphasized the importance of protecting this habitat during construction, including ensuring that every person involved in the construction is committed to the care of this special place of biodiversity that does not exist anywhere else on the National Mall.

Ms. Meyer said that her last recommendation is to modify the width of the approach path, which seems too big relative to the scale of the memorial circle. She recommended that the curving path should be delicate and varied, responding to the biomorphic curve of the habitat space instead of the formal geometry of the memorial. She suggested that the width could be as modest as 5.5 to 6 feet, with some wider areas where people could pass each other more easily; she said that such a treatment would make the proposal much stronger.

Ms. Gilbert commented on the inherent tension in the placement of this memorial at this rich, shady, and veiled spot, where the desire may be to open up views from the sidewalk to the memorial. However, given the busy Mall intersection to the northeast, she said the better solution would be to add denser vegetation along the sidewalk. She suggested defining the outer edge of the approach path as a ribbon of higher plants, with lower wetland plants lining the inner edge, to create the effect of walking through a green corridor before suddenly emerging into the memorial circle.

Mr. Shubow identified an additional tension in the design—between abstraction and representation in the treatment of the ring, drum, and lances. Expressing appreciation for the more literal appearance of the lances, whose meaning will be clear to visitors without interpretation, he observed that the ring and drum may be more difficult to understand. The drum in particular he found too abstract, and he suggested making it look more like a real drum, similar to the lances. He also questioned the proposal to use stainless steel for the Warriors' Circle of Honor, commenting that this industrial material may be appropriate for weapons such as the lances, but the central circle may require a more noble metal such as bronze or brass. Finally, he acknowledged the intended representation of the four elements, but he observed that the design does not appear to signify earth. He suggested considering whether the angular, artificial shape of the benches could include qualities evocative of earth, such as rough surfaces.

Mr. Dunson observed that the design has improved substantially since the information presentation. He commented that for memorial designs, he tends to respect the artist's intention. He expressed satisfaction with the design's accommodation of handicapped access requirements while retaining the strength of the concept. He agreed with Ms. Gilbert that the northeast corner of the site should be shrouded in denser vegetation to increase its sense of enclosure. Finally, he recommended that the wetland should have a wild and natural appearance to emphasize that it is a special place, distinct from the Mall.

Chairman Powell commented that the landscape components of this beautiful design will make it a success. He offered a motion to approve the concept design with the comments provided; upon a second by Mr. Dunson, the Commission adopted this action.

2. CFA 16/MAY/19-2, Hirshhorn Museum and Sculpture Garden, Independence Avenue and 7th Street, SW. Sculpture Garden renovation. Concept. Mr. Fox introduced the concept proposal for the renovation of the Hirshhorn Museum's Sculpture Garden on the National Mall. He said the museum and garden, designed by Gordon Bunshaft of SOM and opened in 1974, feature an important collection of modern art. Modifications to the Sculpture Garden design by landscape architect Lester Collins were completed in 1981. The Sculpture Garden is a sunken multi-level space defined by concrete retaining walls on the east, south, and west sides; a planted berm to the north opens onto the National Mall. Deterioration of the walls and other alterations have resulted in significant changes in character from Bunshaft's original design. The proposed design concept—developed by architect and artist Hiroshi Sugimoto—proposes a reworking of spaces throughout the garden to create a larger display area on the west, a sequence of semi-enclosed garden rooms for small sculptures on the east, and a programmable space for performance and display in the center. New stone landscape walls would be built within the garden as backdrops for sculpture. Mr. Fox asked Ann Trowbridge of the Smithsonian to begin the presentation.

Ms. Trowbridge noted the many members of the project's design team: Mr. Sugimoto's firm, the New Materials Research Lab, working in association with YUN Architecture; Quinn Evans Architects; Rhodeside & Harwell as landscape architects; and staff from several Smithsonian departments. She noted that the original design for the Hirshhorn had included plans for a reflecting pool extending across the Mall. Although approved by the Commission of Fine Arts, the pool was never built, and the Hirshhorn's extension into the Mall was limited to the Sculpture Garden on a single elm panel. The first design had introduced the idea of a pedestrian tunnel beneath Jefferson Drive to connect the museum building site and its garden. The revised, smaller garden design was asymmetrical and did not have access on the Mall side, and it featured a larger reflecting pool than was actually built. When the Sculpture Garden opened in 1974, it was paved with white gravel, which visually unified museum and garden but created an environment that was uncomfortable to inhabit, and Collins was hired after several years to design improvements. The tunnel between the garden and the museum plaza was implemented, but it was dark and difficult to secure, and it was closed in the 1980s; the tunnel space currently houses an art classroom. Ms. Trowbridge asked Hirshhorn director Melissa Chiu to continue the presentation.

Ms. Chiu said that the current Sculpture Garden does not allow the museum to display contemporary art in all its forms, and it lacks a direct connection to the adjacent museum across Jefferson Drive. She noted that the garden's genesis lies in Joseph Hirshhorn's collection of modern sculpture; she presented a photograph of Hirshhorn standing on the grounds of his Connecticut estate with sculptor Henry Moore. She also showed a 1960 photo of Bunshaft sitting with his occasional collaborator, sculptor Isamu Noguchi, at the Ryoanji rock garden in Kyoto, Japan, and she said that Bunshaft's familiarity with Japanese gardens inspired some elements of the Sculpture Garden, such as the sunken configuration and the use of gravel for the ground plane.

Ms. Chiu said that problems with the garden have been evident from the beginning: it is very hot and very bright, and visitors do not want to linger. The new concept is driven by the contemporary practice of artists creating site-specific works on a large scale, and by the growing importance of performance art; the redesigned garden would be able to accommodate larger sculptures in reconfigured spaces, as well as performance art in the central pool and on a lawn in the west garden. She added that another goal is to expand the museum's public outreach by scheduling additional programs on the museum's campus. She said that the Hirshhorn staff and board of directors are strongly of the opinion that the proposed redesign will provide a comfortable environment that will attract visitors and create effective display areas for the current collection as well as new art.

Ms. Chiu said that the chosen designer, artist Hiroshi Sugimoto, has long been associated with the museum. In 2006, the Hirshhorn mounted an exhibition of Mr. Sugimoto's photographs; since that time, he has expanded his practice to include architectural and interior design projects, including a recent redesign of the Hirshhorn's lobby. Mr. Sugimoto's proposal would reconfigure and adapt the Sculpture Garden. The east garden, intended for smaller works from the permanent collection, would feature more intimate spaces; the central area would still have a reflecting pool, rebuilt to include a stage for performance art and other events, with stadium seating on two sides; and the two-level west garden would be reconfigured as one level, with an open lawn for newly commissioned art and changing exhibitions. The tunnel would be reopened and redesigned, and a wider and more direct entrance to the central garden from the Mall would offer a vista through the garden into the tunnel. She said that the concept for the new tunnel was inspired by a sculpture of Mr. Sugimoto's, a milled stainless steel form derived from a mathematical equation expressing infinity; the steel-lined tunnel would narrow progressively in its passage toward the large fountain in the museum's courtyard.

Ms. Chiu said another idea guiding the design is the use of stacked stone walls to divide spaces within the garden and to create backdrops for sculpture. She noted that Mr. Sugimoto has worked with such walls in his architectural projects, and the walls would also refer to the stone walls of Joseph Hirshhorn's Connecticut garden and to other projects by Lester Collins. The stone walls would be similar in color and tone to the Sculpture Garden's existing concrete walls. Mr. Krieger asked if the physical model displayed for the Commission accurately depicts the color of the stone walls in relation to the concrete walls; Ms. Chiu responded that it shows more contrast than intended.

Ms. Chiu discussed current difficulties with barrier-free access to the garden. The accessible ramps are currently at the north side of the garden, adjacent to the center of the Mall; people with mobility issues who want to reach the garden from the museum building have to cross Jefferson Drive and walk around the garden to the Mall side to reach these ramps. The proposed design would provide ramped access that is easily reached from both Jefferson Drive and the Mall.

Ms. Chiu introduced Mr. Sugimoto to present the design analysis and current proposal. Mr. Sugimoto discussed how the doughnut-shaped Hirshhorn functions as a museum building, noting that the lack of straight walls causes difficulty for artists in hanging their work. In redesigning the Sculpture Garden, he is trying to create spaces that will be welcoming for artists and curators as well as for the public. His goal is that the garden will reflect the Bunshaft and Collins designs as well as their varied sources, such as Japanese temple gardens. The redesigned garden would have access from both the Mall on the north and the museum plaza on the south; it would provide more shaded areas; and it would continue to have one side designated for works from the collection and the other for contemporary art. For the performance area in the center, he said that he is exploring the idea of a stage set within a shallow pool. He illustrated sketches of his "infinity point" concept for the tunnel; its narrowing shape is intended to reflect and gather light, creating an intense pinpoint of light to draw people through the garden toward the museum plaza. The tunnel's rough stainless steel walls are intended to create a hazy mirrored effect, reminiscent of an Impressionist painting.

Mr. Sugimoto described his interest in exploring techniques of stacking stones. The new walls at the Sculpture Garden would feature American stones stacked in a Japanese manner; craftsmen would be brought from Japan to train American artisans in the construction technique. He said that because most Modern-era sculpture has a human scale, each work on display would be presented in its own space against the background of a stone wall. Moving through the garden, visitors would continually encounter new compositions of sculptures and stone walls.

Landscape architect Faye Harwell of Rhodeside & Harwell then presented the garden's existing conditions, identifying the elements from the Bunshaft and Collins designs; she said that the proposed concept seeks to balance both designs in a new configuration. She noted that the garden now frequently floods, and its perimeter concrete walls are heavily deteriorated, with extensive cracking and spalling; all of these will be rebuilt. She described the accessible ramp as very narrow, and it is reached from a Mall path on the north that has a soft, graveled surface, difficult to walk on and not truly accessible; she noted that the National Park Service is planning to pave the gravel paths throughout the Mall. The dense plantings along the Mall side restrict views into the garden and present an uninviting appearance. The redesign would provide overlooks into the central space from each of the cardinal directions, and a new, much shorter route would lead from the museum plaza across Jefferson Drive to a new ten-foot-wide ramp. Accessible paths and ramps would also be built throughout the garden.

Ms. Harwell described the proposed garden spaces in greater detail. The west garden, devoted to new large-scale sculpture and performance art, would feature an extensive lawn providing space for performances and seating up to 300 people; she noted that this would be the only area of lawn in the Sculpture Garden. The east garden would display works from the Hirshhorn's Modern sculpture collection; compared to the current use of this space, it would be a quieter area with fewer works on display. In the central area of the garden, a reflecting pool would remain the primary feature. The rebuilt reflecting pool would be as large as originally intended but shallower; it would not have railings. Within the pool would be a stage measuring approximately 25 by 23 feet, and additional permanent seating would be installed around the perimeter. When filled with water, the pool would provide a reflective surface for the garden; when it is empty in colder weather, its paving pattern would be a handsome artistic feature. She noted that the concrete perimeter walls would be replaced in kind, and some existing fabric would be retained. She summarized that the garden would become wider and more open, with spacing similar to Bunshaft's design and defined by the stone walls. She added that the proposal is consistent with Collins's concept that the east side of the garden would be composed of smaller spaces compared to the more open central area.

Ms. Harwell indicated existing architectural details that may be retained, which include the alignment of the perimeter walls. Originally, the paving of the central area was all gravel; when Collins added more plantings, he also created narrow paved ramps and narrowed the stairway from the Mall, decreasing the garden's visibility. The Collins design also included two retaining walls for the ramps, but these walls are so low that people often walk directly down the slope from the Mall to the garden; there is also a problem with water flowing down the slope. The ramp walls would be rebuilt on the same alignment but taller. The intent is to preserve a large sugar maple, if possible, and to replace a missing elm tree from the original design. She indicated a platform Bunshaft designed to save a tree, noting that the tree did not survive but the platform remains and now supports a large sculpture. Referring to the tunnel, she noted that Bunshaft's design blocks sunlight from reaching this passage; stainless steel cladding would be applied to the tunnel's original concrete walls, a reversible alteration that would bring more light into the tunnel.

Ms. Harwell said that the planting plan focuses on providing as much shade as possible and replacing certain missing trees. The shade canopy would be composed primarily of deciduous trees, with an edge of Japanese flowering cherries along the north to invite people to enter; these would also refer to the historic Japanese cherry trees at the Tidal Basin. She said the design team is working closely with the staff of Smithsonian Gardens to determine the right scale, proportion, texture, and seasonal diversity for the plants. At the time the plants are installed, the landscape should provide shade for the aprons and sitting areas; in about ten years, abundant shade would be provided throughout the garden. Ground plantings would be simple to complement the sculpture; they would be primarily evergreen with some semi-evergreen species, and would be selected for ease of maintenance, diversity, and to attract pollinators. Lighting would consist mostly of downlighting, with other lighting following the Mall standards to highlight monumental structures rather than ancillary features.

Chairman Powell invited public testimony. The first speaker was Nord Wennerstrom, representing the Cultural Landscape Foundation (TCLF), which has been recognized as a consulting party to the review process for this project under the National Historic Preservation Act. Mr. Wennerstrom said that the museum and garden are both contributing features to the National Mall Historic District and have been determined eligible for individual listing on the National Register of Historic Places. He said the proposed period of significance has been defined as 1974, the year that both the museum and garden were completed; this omits the period 1977–1981, the years of Lester Collins's work. In 2015, when TCLF was hired by the Smithsonian to review a draft of the Cultural Landscape Report for the South Mall Campus, TCLF noted this omission. He noted that the redesigned Sculpture Garden opened the same year as Paul Friedberg's Pershing Park, drawing a comparison between the proposed concept design for renovating this garden and the current plans to adapt Pershing Park as a World War I Memorial. He said that much of the existing garden is the design of Collins overlaid on Bunshaft's design; Collins transformed Bunshaft's several landscapes into a shaded and choreographed space. He said that Collins's plan represents an integrated and sympathetic solution to accessibility challenges in the years before the Americans with Disabilities Act. He summarized the TCLF asks for recognition of Collins's improvements in the historic preservation documentation, and for the help of the Commission in correcting this oversight before further review of the proposed concept design.

Next to speak was Nancy Slade, a landscape architect and the author of a biographical entry on Lester Collins in TCLF's Pioneers of American Landscape Design. Ms. Slade joined in commenting on the exclusion of the Collins design from the period of significance, and she said that if his work for the Sculpture Garden is lost, an important period of the Mall's landscape history will be lost. She said Collins's prominence and the range of his practice merits expansion of the period of significance from 1974 to 1981 because it is the work of a master landscape architect, a Modernist design that is a fitting complement to Bunshaft's architecture and to the Mall landscape. She also cited the Collins work on the garden as the catalyst for the 1991 redesign of the Hirshhorn Museum plaza by landscape architect James Urban.

Sharon Park, head of historic preservation for the Smithsonian, responded to the public comments. She emphasized that the Smithsonian has supported recognition of Collins's role as a collaborator on the Sculpture Garden; it has used his concepts to enhance the galleries in the garden, and much of his work will be incorporated into the new design. She said that National Register officials had recommended 1974 as the period of significance because the Sculpture Garden is part of a holistic Bunshaft design for the Hirshhorn complex, and the D.C. Historic Preservation Office has accepted 1974 as the period of significance for the site's Determination of Eligibility for the National Register.

Chairman Powell invited comments from the Commission members. Mr. Krieger said he believes Lester Collins improved on the Bunshaft design, and Hiroshi Sugimoto will improve on both; through such transformations the garden will continue to improve as a place to display art. He said that he finds no conceptual problem in this transformation, and he prefers not to address the disagreement concerning its period of significance; he anticipated that suitable ways will be found to recognize the contributions of both Bunshaft and Collins in shaping the garden. He emphasized that the proposed design would be a great improvement over the existing condition, and he expressed appreciation for many of the changes, from improved accessibility to more varied and flexible spaces for sculpture and performance; he also supported continuing to use the east side of the garden as an exhibit area for the older works in the Hirshhorn's collection.

Regarding the proposed stone walls, Mr. Krieger noted New England's long history of stone wall construction, adding that America generally has a historic legacy of such walls. He observed that the physical model is inaccurate in its strong contrast between concrete and stone walls, and said that although Mr. Sugimoto believes that the stone walls will visually recede, thereby making the sculpture more prominent, this can only happen if the walls are somewhat lower and softer in appearance than illustrated. Referring to the stone wall in the photo of the Hirshhorn estate, he observed that it is lower than stone walls in New England and Virginia. He questioned whether some of the proposed spaces would feel too confined, given the substantial height of the new stone walls. He expressed support for the continued development of the design.

Ms. Meyer emphasized that neither history nor historic preservation are issues separate from design, and landscape architects are skilled at reading sites as both biophysical places and cultural expressions. Noting that the Commission sees proposed redesigns for many Modernist landscapes in the Washington area, she emphasized that she is addressing this issue while supporting the proposed concept design. She commented that the Smithsonian's account of how the D.C. Historic Preservation Office had determined the period of significance for the Sculpture Garden only demonstrates the prevailing disregard of landscape architects when the significance of places is defined, indicating the gulf that lies between the regulatory framework that landscape architects are asked to work within and the larger design culture.

Ms. Meyer stressed the importance of understanding the Sculpture Garden as a palimpsest of three very talented designers: Gordon Bunshaft, along with the unknown people at SOM who worked with him; Lester Collins; and James Urban who, she noted, should be interviewed about how he approached changing the work of his two predecessors. She observed that many architects in the 1960s were enamored with public space, but the projects they built in the 1970s were often inhospitable—too hot and overscaled to be successful. She emphasized how indebted this garden is to the contribution of Lester Collins for his consideration of the human experience, comfort, and the scale of the artworks relative to people, and she agreed that his contribution should be carefully documented. She said that she nonetheless supports the proposal because she agrees with Mr. Krieger that the design of the garden has evolved over time in collaboration with the same client, the Hirshhorn Museum and its staff, which has continued to pursue the same mission of bringing contemporary art to the public. However, while the mission has stayed the same, the art has not—there has been a shift in scale and media that needs to be accommodated.

Ms. Meyer offered several suggestions for the design's refinement. Although commending some of the tree selections, she expressed concern that the small scale of some proposed trees, such as Halesia, would not provide the needed canopy for shade; she emphasized that the canopy still requires careful study. She commented that the design of the joint between the concrete walls and the stone walls has not been resolved, such as deciding whether they should touch or should have a gap between them. In addition, she said that the details of smaller pieces, such as steps and seats, appear generic and lack the sculptural elegance appropriate for this site. She advised ensuring that the garden's ground surface is designed beautifully, from the entrance to the center, to draw visitors in.

Ms. Meyer agreed about the need to provide spaces for performances and for larger artworks. However, she said that the proposed pool and stage look extremely generic within their new surroundings, and she noted that these types of spaces often do not work. She said that the proposed geometry of a structure coming in from the edge of a square has a different spatial quality from the rest of the garden, and this requires further study. She suggested that parts of the walkways to the stage could be moveable, so that the pool can appear more like a stage in a basin, with access that can be reconfigured depending on the event; she asked for more exploration of these elements.

Finally, Ms. Meyer acknowledged the inevitability of comparisons between the design for the Sculpture Garden and the design for a World War I Memorial in Pershing Park, but she emphasized that the situations have a fundamental difference: Pershing Park has a new client with a very different mission and a new program, while the Sculpture Garden has the same client, which wants a relationship between its core mission and this space. Mr. Krieger added that this is a mission that continues and evolves; Ms. Meyer agreed. She continued that the Sculpture Garden also comprises a history of change, and there is a point where the palimpsest—the layering of different forms—becomes so complex that it needs to be reconfigured.

Ms. Gilbert commented that one of the most important things the new design will provide is improved barrier-free access; she described the existing long route as unfortunate, and she commended the new design for making a more gracious entrance experience. She said that the proposed east and west overlooks would be delightful places to see into the garden from other angles. She commented that the Sculpture Garden now possesses a quality of sameness—a place where no artwork stands out. She expressed concern that the same generic effect might recur in the new design if it lacks a more extensive tree canopy; she suggested creating a grove of trees in the more intimate east area to contrast with the open, sunny garden in the center. She also expressed disappointment about the proposal to remove a mature weeping beech tree. Felix Ade of YUN Architecture clarified that the presented rendering misrepresents the trees, particularly in the east garden, where they are drawn as quite small in order to show the artworks more clearly. Ms. Gilbert recommended that the tree canopy be more consistent to provide a variety of experiences, from deep sun to lighter shade and full sun. She suggested exploring how the new walls could be built to reflect the changing seasons. She observed that the placement of walls appears diagrammatic, although the location of railings makes sense.

Mr. Shubow expressed support for the design, commenting that it would be an improvement over the existing Sculpture Garden and would better suit the Hirshhorn's needs. He commended in particular the proposed stone walls and the idea of providing a background for modern art that suggests ancient building techniques. He added that the stone walls would moderate the austerity of the concrete walls.

Referring to Ms. Gilbert's comment about creating a grove rather than just a few clumps of trees, Ms. Meyer observed that outdoor space is perceived very differently from space indoors, and generally feels much smaller. She said a tree canopy provides another plane of enclosure—a ceiling—resulting in spaces that feel intimate but not claustrophobic. She recommended that the design team build scale mockups to show different indoor and outdoor spaces, and that they consider vertical walls in relation to a consistent canopy ceiling; such models would be very helpful in making sure the scale is right, and in understanding the difference between architectural space and landscape space. Mr. Krieger supported this recommendation.

Mr. Dunson expressed support for his the comments of the other Commission members. He reiterated the importance of thinking of this garden as a landscape that has evolved from the work of Bunshaft, Collins, Urban, and now Hiroshi Sugimoto. Ms. Gilbert suggested representing the narrative of this evolution on the site; Mr. Powell supported this idea, noting that the National Gallery of Art presents such a history, and the story of the Sculpture Garden would be impressive. He commended the elegance of the proposed design and the careful attention to the needs of the client. He added that the most popular entrance to the National Gallery is the entrance from the Mall, and he anticipated that the Mall entrance to the redesigned Sculpture Garden would attract many more visitors.

Chairman Powell offered a motion to approve the concept design for the Sculpture Garden renovation with the comments provided. Upon a second by Mr. Krieger, the Commission adopted this action.

C. National Park Service

1. CFA 16/MAY/19-3, The White House Grounds, southwest yard. Maintenance facility renovation, Phase I—new tennis pavilion. Concept. Secretary Luebke introduced the concept proposal for a tennis pavilion on the grounds of the White House, submitted by the National Park Service on behalf of the Executive Residence. The pavilion would be the first phase of a larger project to renovate the adjacent maintenance facility, a U-shaped complex that dates from the 1960s. The proposed pavilion would be sited on the west side the existing tennis and basketball court located southwest of the White House, between the existing Children's Garden to the north and the Kitchen Garden to the southeast. The 1,000-square-foot pavilion would support the use of the court, and the project would also improve access and use of the adjacent gardens. He noted that the pavilion would be essentially invisible to the public from outside the fenced White House Grounds due to existing plantings. He introduced Peter May, the National Park Service's associate regional director for lands and planning, to present the proposal.

Mr. May noted that the National Park Service is responsible for the White House Grounds, including maintenance. He said that this project would address a somewhat neglected area of the grounds. He introduced Timothy Harleth, the Chief Usher of the Executive Residence at the White House, to continue the presentation.

Mr. Harleth said that the proposed pavilion would help to restore and connect the surrounding landscape, as well as a allowing for future improvement of the National Park Service's adjacent maintenance facility. He related the project to the broader history of the White House as the home of U.S. presidents and their families, reflecting the nation's dignity and character as well as its celebrations, tragedies, and continuing legacy. He said that the new pavilion would be a continuation of the White House story, intended to display the best of our nation.

Mr. Harleth introduced White House Curator Lydia Tederick to provide a more detailed history of the White House Grounds as context for this project. Ms. Tederick described the original planning for President's Park by L'Enfant, working with President Washington. This plan envisioned a presidential palace with a formal approach on the north, and terraced gardens on the south that would descend to pools of water. Some elements of this planning are seen in the current White House Grounds, the 18.7-acre precinct within the 88-acre President's Park; the grounds include gardens, groves of trees, fountains, and vistas. The form and use of the grounds have evolved over time, providing a setting for official ceremonies and events as well as outdoor space for the president's family. In the early 19th century, the grounds were converted from a construction site to a landscape with gardens and trees; President Jefferson worked with architect Benjamin Henry Latrobe to construct a stone enclosing wall on the south and a monumental entrance gate. An orangery was erected in the 1830s and expanded in the early 1850s, then demolished later in the 1850s for the construction of the Treasury Department. A greenhouse was constructed on the west at this time; it grew to a complex of buildings and outdoor space later in the 19th century, replaced in 1902 by construction of the White House's West Wing. Many trees were added to the grounds in the 1870s, and at this time the tradition began of planting commemorative trees and holding public events such as concerts, garden parties, and the annual Easter Egg Roll. More recently, the grounds have been used for arrival ceremonies, garden tours, and state dinners. Through the 19th century, the grounds north of the White House were generally open to the public, while the grounds south of the White House were considered more private, although with some public access. The privacy of the south grounds was formalized in the early 20th century by President Theodore Roosevelt, which allowed for the construction of private recreation facilities such as a tennis court; the north grounds were not permanently closed to the public until 1923. The tennis court itself was relocated several times, moving to its current location in the 1920s.

Ms. Tederick said that a landscape plan for the White House Grounds was partially developed by Andrew Jackson Downing in the early 1850s, but a complete landscape plan was not developed until 1935 by Frederick Law Olmsted, Jr.; Olmsted's plan remains the basis for current maintenance and development of the grounds. The primary features of Olmsted's plan for the south grounds are a park-like setting, carefully maintained groves of trees, and a broad vista open to the south; this vista also provided the public with a view north to the White House facade. Olmsted's plan limited the formal gardens to locations adjoining the West Wing and East Wing; vehicular traffic was limited, and driveways on the south grounds were sunken slightly so that vehicles would not intrude on views. The groves served to screen views of the grounds from the side streets, providing some privacy; this allowed for additional recreational facilities over the remainder of the 20th century such as playground equipment, a putting green, an outdoor swimming pool, a tree house, horseshoe pits, and a jogging track. The Kitchen Garden was installed in 2009, serving primarily as a demonstration garden for teaching about healthy eating and lifestyles, while also recalling the White House's series of functional kitchen gardens that dated back to the start of the 19th century, as well as the White House's victory garden during World War II. She noted each president's continuing support for the concepts of the Olmsted plan, which has proven flexible as the landscape evolves with each presidential family.

Mr. Harleth provided an overview of the current conditions at the site of the proposed pavilion. The adjacent National Park Service maintenance facility, initially built during the Truman administration, houses the grounds crew that cares for the White House landscape. The Children's Garden to the north was established in the late 1960s; it includes a flagstone terrace as well as bronze footprints and handprints of the grandchildren of the presidents. The existing modest outbuilding associated with the tennis court was built in the 1970s; it provides restrooms and storage. The Kitchen Garden to the southeast remains in use.

Mr. Harleth introduced architect Steven Spandle to present the proposed design for the pavilion. Mr. Spandle said that the White House, and particularly its East Wing and West Wing, are the primary design precedents that were studied. Elements most evident in the pavilion design include the colonnade, the parapet wall, and fanlight windows. The primary exterior material would be stucco, with limestone used for trim, the cornice, the water table, and the columns. The smaller windows would be mahogany, and the windows behind the columns would be steel; he noted the goal of creating continuity between the pavilion's central interior space and the outside. Mr. Krieger and Ms. Meyer asked about the roof; Mr. Spandle responded that the material would be lead-lined copper, intended to recede visually, and the cornice height would be approximately 12 feet, rising to a ridge line at nearly 18 feet. He noted that the pavilion's overall footprint would be 49 feet by about 24 feet, approximately a double-square in plan. He presented a comparison of the proposed classical detailing in the Ionic order with the existing colonnades of the White House and West Wing.

Mr. Spandle presented schematic design drawings for the planned second phase, the replacement of the maintenance facility. Similar to the pavilion, this facility would be stucco with stone trim and would be designed to recede into the landscape. It would have concrete roof tile that is widely used in Williamsburg, giving the appearance of a wood shingle roof; the tile has some texture and provides a habitat for moss and lichen, helping to blend the building with the surrounding landscape. The footprint of this maintenance building would be approximately 87 by 39 feet.

Mr. Spandle presented an existing site plan, indicating the existing maintenance facility that has grown with multiple additions over the years. The current proposal would slightly modify this building, with minor demolition to remove the existing restroom that supports the tennis court, and construct the new pavilion centered on the tennis court. The second phase would be to entirely demolish and replace the maintenance facility; the new facility would also be roughly centered on the tennis court, framing a service court between the maintenance facility and the new pavilion. He indicated the linear garden space that would be provided between the service court and the pavilion, providing a more direct pedestrian connection between the Children's Garden and the Kitchen Garden.

Mr. Spandle said that the proposed landscape is intended to enhance the existing landscape, and the important view from the Ellipse to the White House would not be interrupted. The existing trees that provide visual screening of the tennis court would remain, primarily hollies and magnolias; a few existing trees on the site of the proposed pavilion would be removed, while other trees would be added to improve the density of the screening. He emphasized that this area's privacy is what makes it special.

Chairman Powell invited comments from the Commission members. Ms. Gilbert observed that the interim condition of the new tennis pavilion alongside the existing maintenance facility would be somewhat odd; she asked about the anticipated time lag between the two phases. Mr. Spandle agreed that the interim condition would be less than ideal; he said that the pavilion is a near-term priority, while the replacement of the maintenance facility may be implemented in a few years. Ms. Meyer noted her own involvement in the establishment of the Kitchen Garden and confirmed the inadequacy of the current maintenance facility; she agreed that a significant time lag would be undesirable, resulting in a repeated disturbance of the site.

Ms. Meyer asked for clarification of the project's impact on the Children's Garden, which is not clear from the submitted drawings. Mr. Spandle responded that the location of the Children's Garden would be shifted slightly to improve its relationship to the pavilion's side entrance; existing features such as the cast handprints would be mapped and repositioned. Ms. Meyer commented that merely moving the terrace is insufficient; the project needs to consider not only the garden's floor but also its walls—the plantings that give it a sense of enclosure. She questioned whether the proposal would adequately retain the qualities of the Children's Garden that make it such an effective place of retreat. Mr. Spandle agreed and said that a landscape architect has joined the design team in the past week to address this issue as well as the connection to the Kitchen Garden; the goal will be to treat this area consistently as enclosures and paths. Mr. Harleth added that the photographs of the Children's Garden show the lack of attention given to it; the project is intended to celebrate this currently underused area and bring it back into prominence. Ms. Meyer observed that the presentation was largely about the history of the White House's landscape, but oddly the design portion of the presentation focused on the building as an object, leaving the landscape to be resolved in the future.

Mr. Dunson commented that the larger project involves a choice between establishing an aligned and symmetrical relationship among the components versus preserving the existing landscape features. He said that aligning the future maintenance building with the tennis pavilion seems to be a desirable relationship, but a different configuration for the maintenance building could allow the Children's Garden to remain in its current location. Mr. Spandle responded that other configurations have been studied, including an L-shape, but the presented configuration emerged as the best solution. Mr. Dunson suggested that the service yard itself does not need to be symmetrical around the axis of the building; adjusting the layout of the service yard may be sufficient to avoid disturbance to the Children's Garden, while retaining the broader axial relationship of the buildings. He said that the connecting path should be enhanced by a nicely designed fence between the path and the service yard, as well as by the design of the rear facade of the pavilion.

Chairman Powell supported further consideration of these issues; he suggested approval of the concept submission, with the outstanding issues to be explored as part of the next submission. Ms. Gilbert recommended working closely with the newly selected landscape architect, and Chairman Powell invited further consultation with the Commission. Ms. Meyer suggested that the design team also consult with the maintenance staff to address issues such as the turning radii of their trucks and carts. Mr. Spandle said that such discussions have already begun; Ms. Meyer said that the results are not apparent, and the Commission is just being presented with a proposed layout of spaces. Mr. Spandle acknowledged the concern, while noting that adequate access to the planned maintenance facility is one of the reasons for proposing to reposition the Children's Garden.

Chairman Powell offered a motion to approve the concept with the comments provided. Upon a second by Mr. Krieger, the Commission adopted this action.

2. CFA 16/MAY/19-4, National World War I Memorial. Pershing Park, Pennsylvania Avenue between 14th and 15th Streets, NW. Interpretation elements. Concept. (Previous: CFA 18/APR/19-1.) Secretary Luebke introduced the revised concept proposal for the interpretive components of the National World War I Memorial, submitted by the National Park Service on behalf of the U.S. World War I Centennial Commission. He noted that this submission is part of a sequence of several complex topics that the Commission had asked to review individually. He introduced Peter May of the National Park Service, who asked Libby O'Connell of the memorial commission to begin the presentation.

Thanking the Commission for its continuing guidance, Dr. O'Connell explained that both she and landscape architect David Rubin would present the interpretive program for the memorial park. Mr. Rubin noted that in April 2019, the Commission had reviewed the lighting plan and sculpture fountain details; some illustrations in the current presentation show older versions of certain details because changes based on the Commission's recent comments are still being worked out, and updated versions will be presented in July.

Dr. O'Connell described the proposed three-tiered conceptual framework for interpretation: physical commemoration, in the forms of the statue of Gen. John J. Pershing, the sculpture wall, and the Peace Fountain on the wall's west face; physical interpretation of those three elements, primarily through quotations; and in-depth interpretive material that would be accessible through digital technology. On a site plan for the park, she indicated the three primary elements along with the belvedere on the site of the former kiosk. She noted that the park will not have a predetermined chronological route; visitors will be free to explore the site in a non-sequential way.

Dr. O'Connell said that the belvedere would be the primary interpretive location, providing orientation through simple texts displayed on its parapet wall that identify the park's elements and their thematic connections. Visitors would look down to read about an object, and then when they raise their eyes will see that object ahead. The center of the paved ground plane inside the belvedere would feature a large circular bronze plaque cast with the image of the World War I Allied Victory medal, a design overseen by the Commission of Fine Arts in 1919. Around the top of the belvedere's curved exterior wall, the names of the major World War I battles in which the U.S. fought would be inscribed as a frieze. A porcelain enamel map of the park would show the locations of focal points or "information spots" where visitors would be able to receive through their own digital devices more detailed information on a particular theme; the information would be obtained using QR codes displayed on medallions in the shape of poppy flowers, a symbol of remembrance of World War I. The belvedere would also have a freestanding tactile model of the entire park. A display in the grove east of the belvedere would provide information on how to access digital material. The possibility of installing a donor panel here is also being discussed.

Dr. O'Connell described the second tier of interpretation: the judicious selection of quotations on America's participation in the war, exploring themes of patriotism, loss, and the war's impact on those left at home. She noted that although the U.S. was only involved in the fighting for about six months, more Americans died in World War I than in the Korean War and Vietnam Wars combined; World War I is second only to the Civil War in the total number of American deaths. She said that the quotation at the Peace Fountain, a unique commemorative area in Washington, would be an extract from a poem by Archibald MacLeish; it would appear in front of the cascade of water, with the lettering supported on rods projecting horizontally from the west face of the sculpture wall. Near the fountain, the retaining wall of the north berm would bear a quotation from President Woodrow Wilson. Along the north edge of the park, quotations would be inscribed on the two terraced planters facing the park's central plaza.

Dr. O'Connell illustrated how visitors would experience the park using a phone app. At the Pershing Memorial, for example, visitors would be able to hear a recording of Gen. Pershing speaking to his troops, or to watch augmented reality images of scenes from the war, such as biplanes engaging in a dogfight above the park.

Mr. Rubin presented design options for the poppy medallions that would incorporate the QR code. The proposal is to place them on "blades"—short, flat steel posts that would be bent at the top to provide a display surface for the medallions. The blades would be placed only within landscaped areas. The medallions themselves would consist of the image of a poppy, possibly surrounded by a circle or raised on a circular disc. He asked the Commission members to consider selecting from among six options for the medallions: a poppy in a circle engraved on either a raised bronze or stone disc; a poppy in a circle engraved directly on a blade or wall; an engraved or laser-cut poppy without a circular disc; and a three-dimensional sculpted bronze poppy without a disc or circle. He noted some of the issues that have to be considered, particularly the challenge of creating a medallion that can be changed as technologies change but not easily stolen.

Mr. Rubin concluded with further details of the proposed inscriptions on stone; he presented samples of carving on the Stony Creek granite that would be used for the peripheral walls and belvedere, in the honed and thermal finishes.

Chairman Powell invited comments from the Commission members. Ms. Gilbert asked whether placing quotations on the two planters along the plaza's north side would be effective, observing that visitors reading the quotations would also be looking directly at the dirt and mulch in the planters. She suggested that the letters could be attached to a separate surface that would project slightly from the face of the planters, noting that this option was illustrated in the presentation materials.

Mr. Rubin responded that the design team has carefully considered how to locate quotations so they would be subordinate to the architecture while remaining both noticeable and legible. The two inscriptions on the planters are intended to continue the narrative across the park's northern edge; the design team has studied whether they should be set at or below eye level, and whether they should be engraved on the planter wall or affixed to separate planes anchored to the wall. He said that these issues are under discussion with the foundry and with stone manufacturers. He noted the concern that bronze lettering attached to planters would be easy to steal, which is why engraved lettering is the design team's preference. Ms. Gilbert recommended that the text on these two planters should be as prominent as other inscriptions throughout the park. She suggested moving an inscription from the north to a planter on the south side of the plaza. Mr. Rubin said the challenge of inscribing text on the south planters is that these are built into the steps, and visitors would not be able to see the text easily. Ms. Meyer observed that inscriptions on the north planters would be more legible because they would get direct sunlight from the south. Ms. Gilbert commented that inscriptions on the north would face a larger area with more visitors passing by; Mr. Rubin added that the north also has more room for people to stand and read. Ms. Gilbert agreed that placing this text on the north planters would be better.

Ms. Meyer commended the design team for the interpretive program; she said the presentation had clarified the relation of quotations to existing objects, and how quotations in different scales would be organized within a larger framework. She acknowledged that the medallions might be vulnerable to being stolen as souvenirs. She commented that medallions placed on vertical wall surfaces could be flush to the wall and easily changed when the technology changes. Otherwise, if the proposed blades are used, she expressed support for medallions raised on bronze discs because they would catch the light and be easy to see.

Mr. Shubow asked for additional information about the proposed guided interpretation of the sculpture. Dr. O'Connell responded that information would be made available through several means: visitors could place a call on a smartphone for a guided tour, similar to headphone tours in museums; and visitors could obtain information through the smartphone using an app. Information would be provided on a variety of topics, such as the narrative and details of the sculpture wall. She noted the presentation in a previous review of the accurate period details that have been added to the sculpture to shift its narrative from a mythological story of a warrior's journey to the story of a particular soldier in World War I. For example, in the first version of the sculpture, women on the battlefield were shown wearing ordinary clothes, but now they are shown in uniforms with appropriate insignia. Also, African-American soldiers are now shown wearing French helmets, reflecting the fact that they had to serve under French officers because American officers refused to command them.

Mr. Shubow observed that the battle names on the exterior wall of the belvedere are proposed to be inscribed in letters only two inches high; he commented that this would be too small a scale to do justice to the importance of battles with a large number of casualties. He recommended that the lettering for the battle names be much larger than the proposed two-inch height, noting that an alternative design shown in an appendix to the presentation booklet depicts these names in larger letters. Ms. Meyer asked if the larger lettering in the booklet's appendix is for a shorter list of battles, such as only those in which the Allied forces were victorious, instead of the proposed list of all the war's major battles. Dr. O'Connell asked Edwin Fountain of the memorial commission to address this issue. Mr. Fountain said that the memorial commission has considered many different options for listing the battles, and every list had problems of omission. The decision is therefore to use the U.S. Army's official list of campaigns for which they awarded campaign streamers to participating units, the same list used for the Eternal Light Flagstaff in New York's Madison Square Park. He said that one solution considered was to stack the names of all the battles in a double tier; Mr. Rubin said that this arrangement made the individual names less powerful. Mr. Fountain said the lettering proposed for the belvedere may not be much smaller than the lettering used on the U.S. Marine Corps War Memorial, which is quite legible; Mr. Krieger agreed. Dr. O'Connell said the park will have a rich and complex commemorative program, and the proposed lettering size would keep the exterior of the belvedere quiet; its otherwise blank wall would serve to emphasize the battle names. Mr. Rubin added that the Commission would have the opportunity to review mockups during construction.

The Commission members inspected samples of the two granites with both two- and four-inch lettering. Ms. Meyer and Mr. Powell commented favorably on the two-inch lettering. Mr. Rubin said the Carnelian granite has enough contrast to make the lettering distinct; Mr. Shubow agreed it was more effective. Gabby Salvemini of the David Rubin Land Collective added that using the V-cut instead of the sandblasted cut in the Carnelian granite would give a higher contrast with a deeper cut, with more shadow to increase legibility. Mr. Powell expressed satisfaction with the proposal.

Mr. Shubow expressed his strong concern that the proposed interpretive program, particularly its digital component, would turn the World War I Memorial into an outdoor museum; he called this the wrong approach. He noted that Dr. O'Connell had used the term "museum" when discussing the amount of information that would be made available, which may even include augmented reality. Expressing the fear that the memorial park would resemble a video game, he emphasized that a memorial should be a site for commemoration rather than extensive information. He said he would not want to visit a memorial crowded with people walking around looking at their phones, pointing phones at artworks, or making calls; memorials should instead be presented without electronic media requiring use of phones. Noting that the present time is often called an age of distraction, he said this interpretive approach would only add to the discord and distract visitors from the solemnity of the World War I Memorial.

Dr. O'Connell thanked Mr. Shubow for his comments and acknowledged his concerns, but said she believes this design and its interpretive program will provide an appropriately solemn commemorative environment. She emphasized that the three primary elements—the Pershing Memorial, the sculpture wall, and the Peace Fountain—have been designed with commemoration as their primary purpose. She anticipated that most visitors will approach the park with respect, and the quotations—traditional components of a memorial—will provide an excellent introduction to fundamental concepts about the war. She said that World War I is the most overlooked major event in American history, and she emphasized the importance of educating the public so its importance can be understood. The distraction of electronic devices would be outweighed by the value of allowing visitors to hear, for example, the actual voices of people from that era. She agreed on the importance of people looking at the art in front of them instead of at their phones, but she reiterated that this technology will allow people to understand the role played by the war and its impact on our lives today, while eschewing this technology would create a barrier to learning. She endorsed the ability of new technology to break down such barriers, and she said that one of her goals as a public historian is welcoming people into public spaces to share in the knowledge that such sites convey. She emphasized that this park should be welcoming even for visitors who just want to sit by the fountain, as well as those who want to learn about World War I.

Mr. Shubow responded that if the use of electronic devices is of such public benefit, it should be enabled at other sites of outstanding national importance, such as the Lincoln Memorial and the Vietnam Veterans Memorial, but he questioned whether these memorials would be improved if visitors were looking at their phones. Dr. O'Connell and Mr. Fountain responded that visitors can in fact now access information about both memorials through their smartphones.

Ms. Meyer said she understands Mr. Shubow's concern; however, the generation that fought this war is no longer alive, and their experience has already faded from living memory. If such interpretive technology is not used at this memorial, she said that we will likely soon see a proposal to build a World War I Museum nearby. Observing that the physical pieces enabling this digital technology will be easy to remove, she offered a motion to approve the proposed interpretive program.

Secretary Luebke suggested clarifying certain items as part of the motion. He asked if the Commission members endorse the proposed selection of quotations; the location of quotations on two of the north planters; the proposed two-inch lettering on the belvedere; the proposal to interpret the site through electronic media; and the option for QR medallions with the poppy engraved or incised on a raised metal or stone disc. The consensus of the Commission members was in support of these items.

Noting that Ms. Meyer supported the audiovisual interpretation, Mr. Shubow asked for further opinions on this proposal. Mr. Krieger commented that in order to commemorate a particular event at a public site, visitors need to understand why the site had been built; the more they learn, the better the commemorative experience will be. He commended the interpretive program, adding that the opportunity to use devices will also reduce the need for more physical interpretive material. He noted that visitors will always have the option of not using their phones. Ms. Gilbert endorsed the idea of hearing historic audio recordings of people represented in the memorial.

Mr. Dunson expressed some hesitation about supporting the proposal, but he said that, in the end, he would rather give people the ability to learn more about historical events; he said that if people could be reached through the use of these digital technologies, then he accepts this solution. He noted that smartphones may be the best and most discreet way to provide information today, and he added that visitors will soon learn what behavior is appropriate at a memorial site.

Chairman Powell expressed his respect for Mr. Shubow's comments on this topic; however, noting his role in overseeing educational initiatives at the National Gallery of Art, he emphasized his support for the use of available technologies. He said that not every visitor will be looking at a phone, and the experience of the place itself will remain powerful. He seconded Ms. Meyer's motion to approve the interpretive program; the Commission adopted this action, with Mr. Shubow voting against the motion.

D. U.S. Department of Agriculture

CFA 16/MAY/19-5, Jamie L. Whitten Federal Building (USDA headquarters). Staff parking lot #9, 12th Street and Independence Avenue, SW. Site improvements and perimeter security plan. Concept. (Previous: CFA 15/MAY/14-1.) The Commission acted on the submission earlier in the meeting without a presentation, following agenda item II.A.

E. D.C. Department of Transportation

CFA 16/MAY/19-6, Small cell infrastructure in public space, throughout the city. Guidelines for the installation of low-power antennas for cellular and data communication. Final. (Previous: CFA 20/SEP/18-3.) Mr. Fox introduced the proposed final guidelines for the installation of small cell sites within public space throughout the District of Columbia. This infrastructure consists of antennas and supporting equipment for current 4G and future 5G technology; it is being deployed by private companies to improve and expand cellular service and facilitate new technologies such as autonomous cars and wireless home internet. He noted the previous information presentation to the Commission on the small cell initiative, given by the National Capital Planning Commission (NCPC) in July 2018, and the review of an initial version of the guidelines presented by the D.C. Department of Transportation (DDOT) in September 2018. The Old Georgetown Board also reviewed a draft of the guidelines in November 2018, with the intent of submitting its report to the Commission later that month. The second and third versions of the guidelines were not brought to the Commission for review before their formal adoption, and a later draft was adopted by D.C.'s Public Space Committee in March 2019.

Mr. Fox summarized the review in September 2018, in which the Commission provided recommendations for the development of the guidelines but did not take an action, identifying a fundamental inconsistency between the elegant design of contemporary smart phones and the obtrusive appearance of small cell infrastructure. The Commission did not support installing the infrastructure on Washington upright poles with globe or Twin-20 fixtures. The Commission encouraged a more expansive study of best practices and design approaches, and requested the initiation of a process to develop an elegant and holistic design typology for small cell installations. The Commission also requested several revisions to the guidelines, including the incorporation of a matrix of allowable small cell installations developed by the staff; the requirement of underground equipment vaults citywide; and the development of parametric drawings and onsite mock-ups to test the guidelines.

Mr. Fox said that some of the Commission's previous advice, such as prohibiting installations on the historic Washington poles, has been incorporated into the guidelines being presented today. Other revisions to the draft guidelines include a decrease in the number of allowed small cell facilities per blockface; a map detailing the specific locations allowed for small cell installations in a special federal core interest area; more comprehensive protections for trees; and various corrections regarding definitions of terms and the review process, which is still under discussion. Other Commission advice, such as requiring underground vaulting for all equipment or incorporating the staff's matrix of allowable installations, has not been accepted for inclusion. He noted that DDOT has initiated a consultation process for the design of the stand-alone pole, the freestanding equipment cabinet, and the equipment cabinet that would be attached to wood poles. The first of five consultation meetings was held at the end of last month, and the intent is for Commission review of concept and final designs that are developed through this process. He asked two DDOT representatives—public-private partnership manager Kathryn Roos and permitting manager Elliott Garrett—to present the final design guidelines.

Ms. Roos said that she and Mr. Garrett would provide an overview of the guidelines and describe the role of DDOT and D.C.'s Public Space Committee in the adoption and review process for the guidelines. She said that DDOT has had a positive working relationship with staff from the Commission of Fine Arts and other agencies; the guidelines to be presented are a compilation of hard work and compromise, representing a balanced solution to incorporating small cell infrastructure within the District of Columbia's public space.

Ms. Roos described DDOT's several roles in the small cell installation process. First, DDOT is considered the asset owner of the many streetlights and other poles onto which small cell infrastructure will be attached; therefore, DDOT has a responsibility to maintain and protect these assets. In addition, DDOT and the Public Space Committee are responsible for the permitting process in the public right-of-way, in which streetlights are located and potential stand-alone poles for small cell facilities would be installed.

Ms. Roos presented a summary of the guidelines, emphasizing that they are intended to facilitate the thoughtful incorporation of small cell technology into the urban realm and minimize the disturbance to the public right-of-way. She emphasized the historic nature of the District of Columbia as the nation's capital; the guidelines are therefore intended to ensure, to the greatest extent possible, uninterrupted vistas and viewpoints that are crucial to how residents and visitors experience the capital.

Ms. Roos said that the guidelines generally address the type of pole to which small cell installations can be attached; the maximum height of installations; where the antennas are allowed to be placed; and appearance, including the requirement that the color of the equipment match the color of the pole to which it is being attached. The location and spacing of the installations relative to other objects in the amenity zone, such as street trees and bike racks, is also addressed in the guidelines. She noted that installations would not be permitted on Washington upright poles with a globe or Twin-20 fixture. The frequency of installations, based on blockface length, is also addressed; this is intended to ensure that the multiple small cell providers do not overload a single block with installations. She said that additional restrictions are included for areas of special interest, which includes the Shipstead-Luce Act area, the Old Georgetown historic district, and an "area of special federal interest" delineated by NCPC. New stand-alone poles would likely be installed in areas where the predominant type of streetlight is the Washington upright pole with globe or Twin-20 fixtures, particularly downtown. She said that the CFA recommendation to further study the appearance of stand-alone poles is being pursued by DDOT; a working group to facilitate the design of these poles and other cabinetry has been convened.

Ms. Roos said that large equipment cabinets would not be allowed on any metal poles controlled by DDOT, due to both aesthetic and structural concerns; however, these large equipment cabinets would be allowed on wood utility poles, which are owned by utilities such as Pepco and Verizon; these poles typically have attached equipment such as power transformers. She said that the guidelines call for development of a uniform design for the small cell cabinetry on these poles; subsequently, any previously installed small cell cabinetry of a different design would have to be replaced with cabinets of the compliant design. She said the inclusion of these cabinets in the design process was a compromise to achieve balance and allow the installations to move forward. She noted that the currently presented guidelines would permit only the installation of 5G technology, since 4G equipment requires cabinetry that is not yet approved; therefore, DDOT will not be reviewing applications for 4G installations until the design process for stand-alone poles and cabinetry is completed. In addition, she said that the guidelines would permit only collar-type antennas installed below the fixture arm on upright poles with teardrop fixtures, responding to the Commission's advice not to alter this fixture's distinctive decorative finial.

Ms. Roos said that another area of revision to the guidelines in response to comments from the Commission, other agencies, and the public is the matrix for the permissible spacing and frequency of installations. This revision has resulted in a reduction from the previous version of more than fifty percent in the number of small cell facilities permitted per blockface; for certain blockface lengths, the revision also increases the minimum distance between facilities. She noted the more stringent restrictions for the areas of special interest, where no more than two installations would be allowed on any blockface, with the goal of reducing the long-term impact of these installations on the community. She said that the last column in the matrix, which stipulates the number of facilities owned by the same company allowed on a block, is intended to prevent monopolies. For example, an individual company would be allowed to have only one installation on certain blockface lengths; on atypical longer blockfaces, a company would be allowed to have two installations per blockface.

Ms. Roos presented a map that was developed by NCPC of potential small cell facility locations within the area of special federal interest. She said that this map addresses NCPC concerns regarding impacts of small cells on the federal core, including prominent federal buildings and viewsheds in this area; it is intended to ensure that the installations do not negatively impact some of the city's most well-known and aesthetically pleasing views. She indicated the colored symbols representing existing cobrahead streetlights, which are permitted for installations in the guidelines, and potential locations for stand-alone poles; she said the NCPC analysis indicates that these sites would not negatively impact the special area. Although many other streetlights exist in this area, only the sites indicated on this map would be allowed for installations; she said that this provision addresses some of the main areas of concern for NCPC and CFA. She asked Elliott Garrett to describe the adoption of the guidelines and the review process for permits and applications.

Mr. Garrett emphasized the importance of DDOT obtaining as much input as possible in developing the guidelines; this process included a working group of staff from several divisions within DDOT, such as those concerned with streetlights, policy, and sustainability, as well as staff from the D.C. Office of Planning (OP), NCPC, and CFA. He said that this group met several times over the spring and summer of 2018 to discuss the various groups' interests. Community input was also sought, including outreach to Advisory Neighborhood Commissions (ANCs), business improvement districts, and civic associations. In October 2018, a special meeting of the Public Space Committee was held regarding the draft guidelines, during which the public was able to provide comments; D.C. Councilmember Mary Cheh also convened a roundtable on the issue of small cells. He added that input was also sought from industry representatives regarding the technical requirements of small cell infrastructure. To reflect best practices, guidelines for this infrastructure adopted by other cities—such as Denver, CO; Boston, MA; Dublin, OH; and Lincoln, NE; as well international cities—were consulted and incorporated into the guidelines as appropriate. In addition, local and federal laws were consulted when drafting the guidelines.

Mr. Garrett described the permit review process for small cell infrastructure. He said that each application involving public space is entered into DDOT's Transportation Online Permit System, or "TOPS." Applications submitted through TOPS will go out for review to make sure they adhere to the small cell guidelines, D.C. regulations, federal regulations, and all of D.C.'s standards and design manuals. He said that DDOT staff would look at the applications and make sure that all the required standard material is included, such as drawings stamped by a professional engineer, notifications to the residents about where the infrastructure is proposed to be installed, and notifications to DDOT's standard stakeholders. He said that all applications through TOPS, including small cell applications, proceed through a standard review process: DDOT divisions included in the process include those related to engineering, traffic control, safety, planning, urban forestry, and inspections and enforcement; other agencies and groups include the D.C. Office of Planning and its Historic Preservation Office (HPO), the D.C. Office of the Chief Technology Officer (OCTO), NCPC, and the Commission of Fine Arts. He said that applications not in straightforward compliance with the guidelines would be forwarded to the Public Space Committee for a higher standard of review, and would also be referred to other agencies such as NCPC, HPO, and the Commission of Fine Arts.

Ms. Meyer acknowledged the effort to study the best practices of other cities, as previously requested by the Commission. She asked what was learned from this study and how this information affected the guidelines; more generally, she expressed concern that the Commission is being asked to trust DDOT without being presented with the information that was gathered from the year-long research and drafting process. Ms. Roos responded that small cell technology is relatively new, and the presented guidelines for Washington are more stringent than those of any other city that was researched; she said that stringent guidelines are appropriate given the historic nature of Washington. Some California cities, such as San Francisco and Los Angeles, do not have guidelines on how small cell infrastructure is to be installed. Other cities, such as Lincoln and Denver, are somewhat ahead of the District, but they have had to adopt a second version of their guidelines because the first version did not work for actual implementation of the infrastructure. She added that Europe is generally behind in this technology; for instance, London does not have guidelines and has only recently started to work with providers to implement this technology. She said she feels strongly that DDOT has completed the appropriate amount of work with the CFA staff, in addition to researching additional options and other cities, resulting in the most stringent guidelines that one would see in large cities across the United States.

Mr. Dunson asked for clarification of the terms "block" and "blockface" in the guidelines. Ms. Roos responded that a blockface is one side of the street from one cross-street to the next, while a block would consist of both sides of the street. In the guidelines, this means that if one small cell installation is allowed per blockface, then a total of two would be allowed on the block. She added that the limits on installations per provider are broken down by block; therefore, a block with a limit of one installation per carrier would allow a provider to have an installation on only one side of the street. She further clarified that this restriction is applicable regardless of installation type, and the restrictions on facilities permitted per blockface are absolute: one installation means only one installation, regardless of carrier. Mr. Dunson commented that he is concerned that the providers may discover a loophole in the spacing and frequency guidelines; Ms. Roos said that the limit per carrier would make the guidelines additionally restrictive, since in most cases it would prevent a carrier from taking a spot on both the north and south sides of a street. Mr. Krieger asked if a theoretical total of six carriers would result in 12 installations on a prototypical block. Ms. Roos reiterated that the limits on the number of small cell installations per blockface are absolute; if a block has already reached its maximum number of installations per blockface, no other installations would be allowed on that block, regardless of carrier. If another carrier wants to add an installation on such a block, above the limit set by the guidelines, then it could attempt to apply for an exception through the process described by Mr. Garrett, which includes the Public Space Committee; however, that would be an extreme exception. She confirmed for Ms. Meyer that the maximum number of installations on a block would be six, and this would only be on blocks greater than 600 feet in length.

Mr. Krieger commented that the restrictions in the guidelines have advanced since the last presentation. Secretary Luebke said the staff agrees that the guidelines are quite restrictive when compared to current practices. Mr. Dunson asked if any small cell infrastructure could be installed as a matter of right, and whether the Commission or the D.C. Department of Consumer and Regulatory Affairs would be involved in this process. Ms. Roos responded that the guidelines cover only installations proposed for public space controlled by the D.C. government; if providers wish to install their facilities on the National Mall, for example, they would have to consult with the National Park Service. She added that installations on private land are not addressed in the guidelines; for instance, Georgetown University and other private institutions could have separate agreements with carriers for installations on their properties. She confirmed that homeowners seeking an installation on their private property would not be subject to the guidelines. Mr. Krieger commented that carriers might therefore try to seek installations on private property, because DDOT's guidelines seem fairly restrictive; Ms. Roos said the guidelines are restrictive because of stakeholder feedback the feedback that has been received.

Mr. Luebke clarified that the guidelines effort is intended to create a programmatic approval process so that the D.C. government can perform its job, and so that the Commission does not have to review potentially thousands of street furniture applications within a short period of time. He said the Commission staff is seeking to identify the exceptions that may arise during the permitting process. The consultative process of drafting the guidelines attempted to formulate rules that would be equitably applied and provide a reasonable amount of restriction; however, questions will always arise for certain areas.

Ms. Meyer said that an understanding of these nuances is helpful before the Commission hears public comments. She asked how the principle in the guidelines regarding equitable distribution of small cells would be achieved, since lower-income neighborhoods have many wooden utility poles where haphazard, refrigerator-sized equipment would be permitted as close as ten feet from a building face. Ms. Roos responded that only one installation would be allowed per pole, even if the pole is a wooden utility pole. She reiterated that the equipment cabinetry is included as part of the design process now underway, and historic preservation areas would be treated the same in all areas of the city; similarly, a residential neighborhood would be treated equitably regardless of its location. She said that the locations of private installations cannot be dictated, but the providers have been strongly encouraged to distribute their installations so that everyone has the benefit of this new technology.

Mr. Luebke noted that some members of the public may want to address the Commission. Chairman Powell recognized Joe Gibbons, chairman of the local ANC-2E, which includes Georgetown. Mr. Gibbons expressed appreciation for the work that DDOT has done in preparing the guidelines. He said a resolution regarding this project was adopted by the ANC; Mr. Luebke confirmed that the resolution was distributed to the Commission members. Mr. Gibbons said he officially represents Georgetown, but loves the whole city and considers all of it to be historic. He said that the ANC believes in the primacy of the Commission of Fine Arts and its Old Georgetown Board, and is happy that Georgetown is within the Commission's jurisdiction. He said that Georgetown and the greater city should be treated with the same protections as those provided to the areas of special federal interest. Therefore, he urged that the guidelines be amended to require the receipt of a letter from the Commission of Fine Arts recommending approval of each specific site proposed for the installation of small cell facilities within the Old Georgetown historic district. He said that small cell infrastructure in Georgetown must be treated differently than in the rest of the city because it is a National Historic Landmark, a rare designation; he cited Georgetown's narrow walkways and historic viewsheds as being exceptional. Noting Ms. Meyer's concern about best practices, he said that he has contacted Washington's sister cities regarding this issue and has information that he can share with the Commission, but the DDOT presentation has covered many of the best practices of these cities. He said that Denver's guidelines are concerned with safety issues, such as ensuring that installation footings within the pavement are strong enough to protect against toppling in the wind. The ANC is particularly concerned about the treatment of the streetscape following the installation of small cells, citing the bricks that pave many of Georgetown's sidewalks as deserving of strong protection.

Mr. Gibbons noted that the guidelines permit installations as close as ten feet away from townhomes, which would be something new in the Georgetown streetscape; he said that his neighborhood has never had any type of continuously operating mechanical or electrical equipment within ten feet of a building face. He also expressed concern regarding maintenance, questioning how much care a maintenance worker would take when adjusting an installation, likely with regard only to achieving the desired cellular reception. He said that his ANC has been instructing residents to take photographs of the small cell infrastructure as it is installed, to allow for documentation of changes after the initial installation. He emphasized that members of the community would see the installations at all times. He said that his ANC is strongly in favor of implementing rooftop antennas, citing the recent approval of Sprint's application for a 5G installation on the roof of the Georgetown Park shopping mall, which would replace a 4G facility. He noted that Sprint is using a different technology that allows installing 5G infrastructure on rooftops, and this application was made through the normal process for permitting projects in Georgetown. He said that the use of private property, such as commercial and residential rooftops, is preferable, comparable to the installation of solar panels; the community wants small cells off of walkways and out of viewsheds. He said the community supports 5G technology and future technology, along with the benefits it would bring for safety, jobs, and national security.

Mr. Gibbons said that ANC commissioners throughout Washington have received notices regarding the locations of potential small cell sites, and 6,000 notices for multiple locations were distributed by the carrier AT&T within twenty-four hours. He said that the community is trying to ascertain the appearance of the infrastructure, and emphasized that this is a large undertaking with effects that will last forever; once carriers are given a permit, they will not relinquish it. He said that OCTO is planning to make high-speed WiFi available to everyone in the city—a great public cause supported by the mayor. He said that he also supports this goal, but the equipment for the WiFi network is four feet tall, has four antennas, and would be attached to poles. He said that these have not been included in the guidelines, and he questioned the appearance of this infrastructure and its effect on the community. He said that the Commission and its Old Georgetown Board should have the ability to comment on the appearance, and the Commission should treat Georgetown in the same fashion as NCPC has treated the monumental core area delineated on the map in the guidelines. He emphasized that Georgetown streets are narrow and that homes are sited close to the walkways, and the facades of houses would be obscured by small cell installations. He noted that Federal Communications Commission (FCC) regulations allow the installations to be 28 cubic feet in volume and as tall as 50 feet. He concluded by praising DDOT and its permit tracking system; he reiterated that the Commission has the ability to advise on how small cell infrastructure should appear and where it should be located, and the fitness of this infrastructure in Georgetown should be questioned.

Chairman Powell recognized Richard Hinds of the Citizens Association of Georgetown (CAG). Mr. Hinds said he would present the organization's views on the guidelines, with the recommendation that approving the guidelines now would be premature. He said that CAG has been at the forefront of citizens groups seeking to avert the rollout of 5G technology, which would irrevocably degrade the historic streetscapes of Georgetown. He added that CAG was founded on the notion that Georgetown's historic streetscapes and houses need to be maintained and preserved to the fullest extent possible, and this remains one of its primary objectives today. He said that the initial versions of the guidelines did not have any binding design guidelines for stand-alone poles. The current proposal is to defer the development of guidelines for the cabinetry and the pole itself, which is a part of the process of designing the cabinetry; revised guidelines addressing this issue would be presented to the Commission in the future for further review. He suggested instead that the Commission approve the guidelines only upon review of these designs and other revisions to the document.

Mr. Hinds said that the massive small cell equipment would be as large as refrigerators, and the antennas are significant as well—four feet tall and two feet wide. He said that placing the antennas in a cabinet would look better than leaving them exposed. He noted concerns about the OCTO WiFi antennas and how they are not included in this review. He said that specifications are also needed for wood poles and metal poles that are common throughout the city, particularly in Georgetown's alleys; the guidelines would allow carriers to attach what they like to them, aside from not exceeding the volumetric limits imposed by the FCC. He commended the spacing criteria in the guidelines, but said that the document does not account for what is attached to a pole or the appearance of the antenna cabinet. He emphasized the concern about attaching equipment to wood poles without guidance, and about noncompliant cabinets being attached before the designs are resolved and then not being removed. He said that the guidelines allow exposed wiring, and the replacement poles that will likely be required can be as high as fifty feet, which would overwhelm the typical thirty-five-foot-tall houses in Georgetown. He added that there no specifications are provided for the antennas. He summarized that the Commission is being asked to approve guidelines that provide no guidance beyond location, and he urged the Commission to request further guidance from DDOT on the specifications for small cell attachments to wood and metal poles throughout the city.

Chairman Powell recognized Elsa Santoyo, chair of CAG's committee on historic preservation and zoning. Ms. Santoyo said that her research has identified a number of municipalities that have very stringent guidelines, which dictate the appearance and location of small cell installations, and require that carriers provide evidence of their need for the particular sites that are requested. She said that detailed comments, including this research, were provided to DDOT but were not reflected in the draft guidelines that were newly presented one week later at a meeting of the Public Space Committee.

Ms. Santoyo presented the comments of the Committee of 100 on the Federal City, of which she is a member. She recalled that when DDOT presented the draft guidelines to the Commission of Fine Arts in September 2018, she heard the Commission's recommendation not to attach small cell infrastructure to streetlight poles, and to provide for a well-designed and uniform deployment of the infrastructure across the city. She said she believes the intention was to ensure that no neighborhood would have its environment marred with a plethora of haphazardly deployed small cell installations, such as those that have plagued communities elsewhere in the U.S., as seen in the many examples that can be readily found on the internet. She said that the third version of the guidelines, dated 21 March 2019, does not establish design specifications that would be uniform throughout the city; she acknowledged that the document does promise design parameters for stand-alone poles for small cells in limited areas of the city where Washington globe or Twin-20 streetlight poles exist, but it establishes only the most minimal design parameters for retrofitting small cells onto existing metal and wood utility poles. She said that wood poles are the predominant type around the city's streets and alleys, and the lack of design parameters for these poles is unfortunate because they are so common. She noted that many of these poles already have many pieces of equipment, such as cobrahead streetlights, electric utilities, telephone lines, fiber optic wiring, and other cabinets; adding concealed and unconcealed wires, radio equipment cabinets that are more than four feet in height, and a three-foot-tall antenna for small cells atop the poles would exacerbate the existing clutter. She said that the existing poles will likely not support the added weight of the small cell components, and the chaotic array will become even more prominent as the height of the wood poles would likely exceed fifty feet, which would tower over the typical two- and three-story D.C. houses. She said that in breadth and scope, these installations would have an immensely deleterious visual impact, and the current version of the small cell guidelines is not in accordance with either the direction or the intent of the Commission's previous recommendations. She said that at a minimum, small cell infrastructure should be well designed, no matter where in the city it is located. She said that small cells could be incorporated on roofs, initially augmenting and eventually replacing 4G infrastructure over time, or housed in specifically designed stand-alone poles across the entire city. She recommended that DDOT follow its existing practice with public space street furniture by developing strict specifications for the small cell infrastructure, rather than broad design guidelines. The specifications should address the appearance of cabinetry, wiring, and antennas, as well as establish uniform mounting and projection dimensions for each component, the maximum number of antenna and equipment allowed per pole, and color using recognized industry standards such as Pantone instead of subjective terms like "medium gray." She concluded by suggesting that in the Shipstead-Luce Act and Old Georgetown Act areas, the Commission's approval should be required for each installation of small cell infrastructure, as required by D.C. regulations for other above-grade installations by DDOT, such as bus shelters.

Chairman Powell recognized Jim Wilcox, a former ANC commissioner in Georgetown. Mr. Wilcox said he has provided comments at previous meetings of the Commission and the Old Georgetown Board regarding the small cell guidelines, during which many objections and concerns were expressed. He said that carriers are already installing small cell facilities on rooftops of commercial buildings in Georgetown, and he suggested that this may be a practical alternative to installations on poles within public space; he added that this alternative is not addressed in the guidelines. He said that allowing carriers to freely install small cell facilities on existing lampposts would have a serious adverse impact on the city's streetscapes, and would also deny religious institutions, historic properties, businesses, and residents from receiving the useful cash flow which many businesses currently receive from the placement of 4G antennas on their rooftops. He said that a helpful outcome would be a highly esteemed organization such as the Commission of Fine Arts declining to support the guidelines unless the document prioritizes rooftop installations of cellular technology; he suggested that this could serve as a model for the rest of the country. He recommended that the guidelines be revised to allow installations on lampposts only where an applicant can demonstrate that a rooftop installation is not feasible nearby. He noted that the guidelines state that NCPC has the authority to deny installations for sites that are not pre-approved in the guidelines; however, the Commission of Fine Arts can only provide comments. He said that the Commission should not approve the guidelines until the Public Space Committee agrees to accept the Commission's recommendations in the same way it is consenting to approvals by NCPC. He noted that Ms. Roos had described the guidelines as intended to minimize impacts on the public right-of-way; however, he believes that the impacts would not be minimized if poles are permitted to be installed in streetscapes without clear evidence that installing small cell infrastructure elsewhere, such as on rooftops, is impractical or infeasible. He concluded by asking the Commission members to visualize the impact of fifty-foot-tall wood poles, compared to the existing twenty- to twenty-five-foot-tall poles; he said that many would be located in low-income areas of the city and would be unattractive, and he referenced comments provided by the Commission regarding this topic at a previous review.

Mr. Luebke summarized written comments provided by Jo-Ann Neuhaus, executive director of the Penn Quarter Neighborhood Association. She wrote that the appearance of the Penn Quarter neighborhood has progressively improved over the last several decades; Washington has been a leader in valuing its past cultural and physical setting; and over time, much of the area that is considered Penn Quarter was saved through efforts of historic preservationists, with the result of enhancing streetscapes as well as saving and restoring important buildings. The installation of 5G cellular equipment should not be supported or allowed to destroy this invaluable heritage; fifty-foot-high poles spaced twenty-five feet apart are not wanted by the public nor by the National Park Service, which would not allow this on the National Mall or on Pennsylvania Avenue. She urged that with the Commission's help, this technology should not be allowed in the city's historic districts nor downtown between the U.S. Treasury building and the U.S. Capitol Grounds. Mr. Luebke concluded reading Ms. Neuhaus's comments by noting that some of what she anticipates would likely not be permitted under the proposed guidelines; however, the issue of height is salient.

Chairman Powell invited Ms. Roos to address these public comments. Ms. Roos said that DDOT is familiar with many of the members of the public who spoke, and much of their feedback has been incorporated into the guidelines. She said that the process has been about achieving balance, and each party will not receive all that it is seeking. She said that the D.C. government has strived to make decisions based upon the principles that were laid out at the beginning of the process, with the goal of incorporating the requests of each party. Some have been concerned that the process was too fast, while others thought the process was too slow, which she said suggests that the process has been moving at the right speed. She expressed appreciation for the comments provided by members of the public and their passion for their neighborhoods and the District of Columbia.

Ms. Roos noted some factual misunderstandings in the public comments. For the 6,000 notices sent to the community by AT&T, she said the implication was that this corresponds to the number of applications; however, this is not true. She cited section 4.1.5 of the guidelines: the applicant "shall provide notice to all immediately adjacent property owners, i.e., owners of all properties on both sides of the block where the small cell infrastructure is proposed to be installed." She said that the goal of this section is to be extremely transparent and thoroughly communicate to neighbors and neighborhoods about the proposed projects; therefore, all residents on a block are to receive notice of a proposed small cell installation, regardless of whether the installation would be directly adjacent to one's individual property. She then addressed concerns of the Georgetown residents regarding the allowed distance between a small cell installation and a building facade or projection. She said that FCC regulations mandate that small cell facilities cannot be placed within seven feet of a building facade; the guidelines increase this distance to a minimum of ten feet. She said Mr. Gibbons is correct that Georgetown has many sidewalks that are narrower than ten feet; small cell installations would therefore be prohibited in these areas, without exception. She said that the D.C. Office of Planning prepared an analysis of the streets in Georgetown that identifies which sidewalks are deep enough to allow for small cell installations. She emphasized the importance of considering the guidelines as a whole, and she noted that providers may find that they have to use rooftops for their installations in Georgetown. In addition, a street with many trees may also be excluded from small cell installations as a result of the guidelines, since an installation must be located at least fifteen feet away from a tree; she said that exceptions would not be given to these guidelines, and reiterated that the guidelines as a whole will restrict where installations go and how there are installed, beyond what is shown in the spacing and frequency matrix. She said that the public comments may also reflect a misunderstanding regarding the equipment cabinetry installed on wood poles; the design of the cabinets is included in the multiagency design process discussed earlier. She addressed the concern regarding the restoration of public space, citing a stipulation for all approved permits that mandates the restoration of public space to its prior condition after small cell infrastructure is installed. She said that DDOT has inspectors who will evaluate this work and enforce this stipulation; paving materials would be restored, as they would be for any other installation in public space throughout the city.

Ms. Gilbert asked for more information regarding the allowable height of poles. Ms. Roos responded that current utility poles are typically thirty feet tall, with some poles as high as forty feet; the height relates to the vertical separation zones between pieces of equipment on the poles. She said that federal regulations set standard spacing distances between these zones, which are intended to accommodate equipment for telecommunications or electrical power. She added that the maximum allowable height in the guidelines is slightly less than what is allowed under FCC regulations. Ms. Gilbert asked why poles would need to be fifty feet tall. Ms. Roos said that based on information from the small cell providers, fifty feet would allow for the required separations between the various zones; Pepco, which controls many of the wood utility poles, would also likely require the poles to be replaced to accommodate the new equipment. She said that representatives of provider companies are present to address the Commission regarding their installations. Mr. Luebke noted the substantial increase in the allowable height in the latest version of the guidelines, from just over thirty-four feet to fifty feet or greater; Ms. Roos commented that the separation between equipment zones was not accounted for in the previous guidelines, and the spacing requirements are different for DDOT-controlled poles and utility-controlled poles. She said that the technical spacing information was provided by the small cell companies, and she reiterated that the guidelines process is about compromise and balance.

Matthew Marcou, DDOT's associate director for the Public Space Regulation Division, provided additional information regarding the height of poles. He said that although the maximum height would be approximately fifty feet, this does not mean that every pole will be this tall; the carriers generally need their equipment to be as close to the ground as possible, particularly in denser areas. He said that the pole height is based on several factors. First, FCC regulations allow, and in some cases mandate, that municipalities allow poles to be up to fifty-one feet tall, or ten percent taller than the existing pole, in order to provide a new attachment zone for small cells. He said poles would likely have to be reengineered to accept the new equipment because it has a different weight and balance category relative to the existing pole. Second, pole heights in Washington vary depending on their location and the equipment they are carrying. Third, in areas where power transmission equipment is underground, the existing poles would be primarily carrying power lines that attach to houses; these lines are lower voltage than the higher-level transmission lines that carry power across a grid or a network. In addition, an offset zone is provided for safety purposes between telecommunications zones, which are typically lower than the power transmission and distribution zones. He said that taller poles are generally in areas that do not have underground power transmission, allowing the poles to accommodate both types of power lines; this is generally in outer areas of the city.

Jennifer Van Riper, area manager of construction and engineering for AT&T, provided additional comments. She said that AT&T is proposing to start laying the groundwork for a 5G network with over 500 individual small cell installations. She said that only 27 percent of AT&T's desired locations would meet the guidelines, which she described as the most restrictive she has seen anywhere in the country. She said the company understands why it is difficult to develop a network in Washington, and has participated in many conversations on how to proceed in a responsible way. She said that although FCC regulations allow for small cell installations to be as large as 28 cubic feet in volume, AT&T is not proposing such large installations in Washington. She said that her company's installations would be very small and streamlined—pole-top installations without large cabinets—and they are intended to be compatible with viewsheds. She said that most of the installations are planned for areas with the most foot traffic and network congestion, which is often downtown and in the federal core. The first iteration of technology would solve this existing problem of network congestion by augmenting the existing 4G network, which has no more capacity. She said that geographic disparities in the deployment of the cellular network are related to this usage model, which allocates resources to areas with a capacity issue; as this model changes and technology is developed, the system would have more geographic equity. Regarding installations on rooftops, she said that a type of technology is being installed that supports and augments 5G services. However, this technology is different from small cells themselves, which use a different frequency band and bring the cellular network closer to the user; she said that this technology operates best when it is less than thirty-five feet from the ground. She added that both rooftop and ground-based small cell installations are required for AT&T, and the company is committed to partnering to achieve an aesthetically acceptable design that is appropriate for Washington, to the extent technologically feasible. She acknowledged that people are passionate about potential obstructions in viewsheds; AT&T has therefore brought in designers and manufacturers, with the goal of working together to get it right. She said AT&T will return with photographs of the infrastructure once it is installed.

Carly Didden, government affairs manager for Crown Castle—a company seeking to install small cell infrastructure for Sprint and T-Mobile—said that her company's facilities would support multiple carriers, known as "hoteling." Regarding the issue of equity, she said that her company has filed applications to install small cell infrastructure in all eight of Washington's wards; the company has also partnered with OCTO to build out a network, particularly in Wards 7 and 8.

Chairman Powell thanked the speakers for their comments, and he expressed appreciation for the clarifications regarding rooftop- and pole-mounted installations. Mr. Krieger noted the carriers' intention to carefully design the infrastructure, and said that during the presentation and testimony he has tried to imagine how the small cell infrastructure will appear. He observed that groups on both sides of this issue—proponents who have said that the impacts of the installations will be minimal, with an installation every block, and opponents who predict fifty-foot-tall poles with refrigerator-sized equipment on top—do not fully understand the true impact of the installations because of a lack of visual studies; instead, they are substituting with their imaginations. He suggested that DDOT perform such visual studies, illustrating the maximum number of installations that would be seen on several prototypical blocks. He said that after such studies, some people may be more reassured about the impacts of the installations.

Ms. Meyer emphasized that the Commission's purview is the aesthetic impact of the project, rather than the more planning-based evaluations provided by NCPC. She said that the Commission is being asked to make a decision based on planning criteria, such as spacing and location, but not on the appearance of the infrastructure as installed on poles and its impact on the streetscape. She said that some time has passed since the last review, but drawings still have not been provided; she recommended preparing approximately a dozen axonometric drawings showing the maximum allowable installations on prototypical blocks of different widths and with different building heights. These diagrams should illustrate the application of the guidelines and other regulations affecting the installations, such as the FCC regulations regarding the spacing of equipment on a pole. She said the Commission should be able to visually evaluate the difference between a thirty-foot and fifty-foot pole height, and commented that the taller pole would have a big impact on the sidewalk because it would likely be of an increased diameter. She acknowledged that DDOT has been consulting with the staff, but DDOT has not presented successive versions of the guidelines to the Commission; the applicant is seeking a final approval, but the Commission never approved the guidelines in concept. She said that the work performed thus far is admirable and that she is impressed with the analysis shown in the guidelines, but the document falls short in demonstrating to the public that their concerns are being weighed as strongly as those of the small cell companies. She said that the role of the D.C. Government should not be to balance private and public interests, but to advocate for the citizens in the community and to ensure that ill-considered policy is not allowing private corporate benefits to supersede the benefits conferred to residents. She said the Commission would not be fulfilling its mission if it approves guidelines that include only location and spacing criteria without a demonstration of the physical impact of the proposed small cell infrastructure on the District of Columbia.

Ms. Roos said that DDOT offered in the late fall of 2018 to choose specific sites and allow providers to construct mockups for inspection, but the stakeholder group—including the Commission staff—declined this offer, citing concerns about the delays involved in constructing and revising these mock-ups. Mr. Luebke disagreed; he said the staff has not been presented with the offer of mockups that Ms. Roos is describing, nor with the study of Georgetown locations and impacts that she referenced earlier. He apologized for putting Ms. Roos on the spot, but said that she cannot demonstrate that the staff has been presented with the items she is mentioning. Ms. Roos responded that the D.C. Office of Planning studied some of the affected street sections, and the staff was present at these larger meetings; Mr. Luebke disputed this account.

Ms. Meyer expressed great appreciation for the work of the Commission staff, and reiterated that the Commission members themselves have not been presented with any documentation, such as axonometric drawings, that demonstrate the height, scale, and materials of the small cell installations and their impact. Ms. Roos said that previous versions of the guidelines contained these drawings, but when they were shared with the stakeholder group, the feedback was that the drawings were not completely illustrative and should therefore be removed from the guidelines. She said that she is not advocating for the carriers, and the responsibility of the D.C. government is to allow, in a sensitive manner, the installations as required by the FCC. She cited the comment by Ms. Van Riper that only 27 percent of AT&T's desired locations for small cell installations would comply with the guidelines, which means that they are very restrictive. Ms. Meyer responded that the Commission is not asking for weeks or months of study; drawings depicting the accurate spacing and locations of installations would take a design student a couple of days to complete. Ms. Roos responded that the Commission staff has been free to proactively provide these drawings to the working group; Ms. Meyer said drawings need to be presented by DDOT to the Commission members in an open meeting.

Mr. Krieger said that he believes the installations will not be as onerous as some residents think; Ms. Roos agreed. However, Mr. Krieger observed that no evidence has been provided showing how unobtrusive the installations may be in certain areas, and he said that he does not understand why DDOT is not choosing to demonstrate to residents that they should not fear the worst. He said that DDOT is sabotaging its own effort by not illustrating the implications of the installations along a block in several prototypical conditions. He added that he hopes that DDOT's assertion that the guidelines are very restrictive will be proven correct. He said that these illustrations might help reassure people, but until they are provided, there is no reason why both residents and the Commission should not be suspicious about the impacts of the small cell initiative. Chairman Powell emphasized that the Commission needs to review visual studies of the proposed small cell installations.

Mr. Luebke noted that the latest version of the guidelines changed the review process as described in Section; it states that if projects do not comply with the guidelines, then they are referred to the Commission of Fine Arts for comment within 30 days—not the 45-day review period required by federal law; he requested that this language be returned to the previous version that allows 45 days for the Commission to complete its own review process, which may include review by the Old Georgetown Board as well. He said that the staff would like the Commission to be able to endorse the guidelines, including the programmatic review; however, he acknowledged that the Commission is not yet ready to endorse the guidelines. He added that the staff would not have the capacity to review each individual installation, nor to prepare diagrams or test the results of applicants' proposals.

Mr. Luebke then summarized several issues before the Commission. He noted that both rooftop and street-level small cell installations have been discussed, although inconclusively on whether small cell infrastructure could be installed on rooftops. He noted that small cell providers generally do not want their installations higher than fifty feet off the ground, but he is unsure if the Commission is satisfied with the answers to the questions regarding the potential height of the poles. He said that a secondary set of issues concerns the details, attachments, color, and other appearance criteria that may be addressed during the design process for stand-alone poles, but it is unclear how these issues will be resolved for attachments to existing poles. A final issue concerns the infrastructure for the OCTO WiFi network. He summarized the need for further clarification of several outstanding issues. Chairman Powell said that the Commission would like to feel comfortable in approving the guidelines, but another step is required to get there.

Mr. Garrett responded to the concern regarding the review timeline. He said that the initial process in the guidelines calls for small cell infrastructure applications to go out to all reviewers, including the Commission staff, for an initial thirty-day review. Applications that do not meet the standard guidelines would have a sixty-day review process because they would have to be forwarded to the Public Space Committee and would have a higher-level review; these applications would also go to ANCs to aid in a deeper discussion of the proposed installations' implications for public space. He emphasized that additional time could be added to the initial thirty-day review process, depending on what other reviewers find in the applications. He said that DDOT's TOPS permit tracking system processes approximately 70,000 applications per year for unique installations in public space, using the same timeline as in the proposed guidelines. For small cell infrastructure applications, he said the approach is to extend the review period as much as needed for applications that do not meet the guidelines.

Mr. Krieger said that the guidelines have progressed a great deal since the previous presentations to the Commission, and they seem reasonably comprehensive and restrictive. But he reiterated that the Commission does not quite understand the visual implications of the guidelines. Therefore, to assist both the Commission and residents, who are understandably unsure about the guidelines, DDOT should provide visualizations that illustrate the implications of the guidelines. Ms. Meyer added that the visualizations should depict the physical design of the installations—for example, different installation sizes and the various conditions of wire installations—in addition to accurately illustrating the spacing and location. She said this is not too much to ask, considering that the residents are being asked to bear to burden of a multi-year infrastructure project. She noted that much attention has long been paid in specifying other objects in public space, such as seating, trashcans, and light standards, and the request for more documentation is reasonable given the Commission's mandate. Chairman Powell agreed that the request is appropriate; he commended DDOT for the progress on the guidelines and the effort to develop rules for small cell installations. He said that the Commission performs design review, and therefore designs depicted in visual studies are requested in an additional review; he agreed that these studies would help educate both the Commission and the community on the potential impact. He summarized the consensus that the Commission anticipates approving the guidelines, but would first like to review visual studies.

Mr. Marcou said that, as the chair of the Public Space Committee, he wants to ensure that the Commission of Fine Arts and his committee are aligned; if the guidelines are not satisfactory for the Commission, then they are not satisfactory for the Public Space Committee. He said that the guidelines could be amended to provide a 45-day review period, or whatever period of time is needed to fit the Commission's processes, for applications that do not meet the guidelines; these non-compliant applications would also have to be presented to the Public Space Committee. He said that he understands processes and wants to ensure that the D.C. processes fit with those of the Commission. He summarized the two other primary concerns that the Commission members would like to have addressed before they feel comfortable adopting the guidelines. The first is the visual impact of small cell infrastructure, with the Commission requesting to see a mockup or drawings that depict small cell installations that are scaled, accurate, and consistent, in a variety of locations across the city. Chairman Powell clarified that the Commission is seeking drawings, not physical mockups. Mr. Marcou agreed, noting that mockups of certain installations would be difficult to prepare because the designs have not been completed; however, mockups could be presented to the Commission after the design process. For instance, cabinetry designs would be included in the final guidelines, and would be submitted to the Commission when they are developed; any non-conforming cabinetry that is attached to poles before the completion of this design process would have to be replaced or retrofitted to be consistent with the adopted design. He said that he believes the Commission is seeking mockups showing the different types of antennas—Class A and Class B—as well as different types of cabinetry to be attached to wood poles or the DDOT streetlight types; stand-alone poles would be considered later, because they are going through a design process.

Mr. Marcou asked if this is an accurate summary of the most important issues for the Commission; Chairman Powell noted additional issues involving the locations of the installations. Mr. Krieger questioned whether Mr. Marcou would be able to accomplish what was just described; Mr. Marcou said that he would ensure that the studies he described would happen. Mr. Krieger expressed appreciation for this assurance, and he noted the Commission's additional request for visual studies depicting prototypical blocks showing how they would appear if filled out with small cells under the guidelines. Mr. Marcou clarified that the visual studies he was describing would include depictions of individual poles, as well as the installations on blockfaces. Ms. Gilbert recommended depicting actual blocks in the city. Ms. Meyer added that the Commission is seeking the depiction of small cells on street of varied widths, from the narrower blocks of Georgetown to wider streets; Mr. Marcou agreed to provide this. Chairman Powell expressed hope that this additional information would reassure the residents of Georgetown as well.

Mr. Luebke asked for clarification of a procedural concern. He noted DDOT's acknowledgement that a programmatic agreement is necessary because the Commission does not have the capacity, nor is it the Commission's role, to review every small cell infrastructure application. The goal is for the Commission to review only applications that do not comply with the guidelines, not to participate in the first-stage vetting of applications. He summarized that the Commission is seeking to endorse a program in which the D.C. government forwards only problematic applications for Commission review. Mr. Marcou said that all applications have to be forwarded, because the Commission staff is very familiar with the guidelines and has been an exceptional partner in developing them; the staff would therefore be able to assist in evaluating whether applications meet the guidelines. He said that this initial staff review would be especially beneficial during the early stages of the program to make sure that the submitted applications comply with the guidelines; once the Commission staff is comfortable that applications are meeting the standards of the guidelines, then the Commission can be entirely removed from the process of reviewing the hundreds of routine applications to the D.C. government. Mr. Luebke responded that this process could be considered as an informal consultation, not part of the referral process described in the guidelines; Mr. Marcou responded that if this is the Commission's preference, then he will proceed in this way.

Chairman Powell thanked the project team and said that the Commissions looks forward to evaluating visual studies at the next review. The discussion concluded without a formal action.

F. District of Columbia Department of General Services

1. CFA 16/MAY/19-7, Eastern Market Metro Park, 8th Street and Pennsylvania Avenue, SE. Modifications to and renovation of park. Concept. (Previous: CFA 21/MAR/19-7.) Ms. Batcheler introduced the concept proposal for renovation of the multiple park parcels at the intersection of Pennsylvania and South Carolina Avenues at 8th and D Streets, SE. She noted the Commission's previous review of this project in March 2019, with no action taken; she summarized the Commission's advice to develop and simplify the concept design. She said that this park occupies one of the open city squares that were articulated in the L'Enfant Plan, and it was later depicted as a rectangular park in the Senate Park Commission (McMillan) Plan. She asked project manager Cassidy Mullen of the D.C. Department of General Services to begin the presentation.

Mr. Mullen said that the project is intended to improve a key open space within the Capitol Hill neighborhood. The current proposal responds to the Commission's advice in the previous review while retaining many of the design features requested by the community during the extensive neighborhood consultation process over the past decade. He noted that the project has the support of the National Capital Planning Commission and the D.C. Office of Planning. He introduced landscape architect Susan England of Land Design to present the design.

Ms. England said that the Commission's comments have resulted in a better design. She briefly summarized the introductory slides of the presentation, noting that some Commission members were not present for the March 2019 presentation. She noted that the ownership and management of the park is complex, involving multiple agencies, which has had some impact on the design and the approval process. The site is rectangular in overall shape but is divided into several parcels by Pennsylvania Avenue and 8th Street; the two largest parcels are offset to the northeast and southwest, and an important design challenge—as identified by the Commission in the previous review—is how these two parcels relate to each other or have independent design characters. She acknowledged the Commission's previous observation that Pennsylvania Avenue is a wide divider between the two largest parcels, in contrast to the design process that had attempted to consider all the parcels as a single rectangular park. She said that an additional factor is the differing contexts of the two largest parcels: the development adjoining the northeast parcel is primarily residential, while the southwest parcel has a more commercial and urban character with adjacent retail frontage and, within the parcel, the Metro entrance to the Eastern Market station. Significant below-grade constraints include water pipes and the Metro station.

Ms. England described the goals and program elements of the design, emphasizing that these were developed through the lengthy process of community consultation. The design is intended to express the alignment of South Carolina Avenue with a viewshed that passes diagonally through the park's two largest parcels, connecting the segments of the avenue to the southwest and northeast of the park. Circulation patterns will be clarified, particularly for pedestrians, through improved spatial definition and wayfinding. The park would be updated to incorporate current standards and best practices. A playground would be added to the park, a new feature that is enthusiastically supported by the community. The park would also have a stronger relationship with the branch library located across 7th Street from the southern part of the park's southwestern parcel.

Ms. England said that the current design responds to the Commission's previous advice to simplify the programming and to design each of the parcels as a discrete park that does not rely on being perceived in relation to the entire project. She presented the current design for Parcel 1, the large parcel on the northeast side of the park. The proposed character of this parcel is now less rigidly geometric in comparison to the previous design that attempted to relate this parcel more closely to the southwest parcel; she said that this adjustment responds better to the residential context of Parcel 1. The layout now features more curves while still respecting the viewshed along the alignment of South Carolina Avenue. Major spaces within Parcel 1 include the playground and splash pad toward the north edge, located along the relatively quiet frontage of D Street instead of the busier traffic along Pennsylvania Avenue; a large lawn for recreation, approximately in the center of the parcel; and a "Nature Room" to the southeast, an oval gathering space focused on a large existing tree with bioretention areas nearby.

Ms. England said that Parcel 4, the large parcel on the southwest side of the park, continues to have a more rigid organizing geometry, in keeping with its more urban context of commercial buildings and the Metro station entrance. This geometry is intended to provide a stronger sense of wayfinding for the more intense pedestrian traffic on Parcel 4, particularly for people exiting the Metro station; the design is intended to accommodate people moving through this space while also encouraging them to linger and enjoy the park's amenities. The spaces within Parcel 4 include a circular area to the east, serving as a transition and gateway to the Barracks Row commercial district extending to the south along 8th Street; the "Town Center Plaza" near the Metro entrance, intended as a focal space for the Capitol Hill neighborhood; and a plaza to the west along 7th Street that would relate to the neighborhood library, which she described as small but heavily used. She said that some library activities could occur within this plaza, such as a children's story group, a poetry reading, or a small music event; fixed and moveable seating would be provided, and raised pedestrian crosswalk would help to connect this space with the library. A bosque with moveable furniture would be located along the southern edge of Parcel 4. A kiosk, previously proposed within the bosque, would now be located within the Town Center Plaza to activate the center of this space and assist in wayfinding for people exiting the Metro. The kiosk could be used for some type of retail sales; the management of this kiosk and its specific purpose have not been determined, but its inclusion has been encouraged by the D.C. Department of Parks and Recreation, and income from the kiosk could be used as a funding source for the park.

Ms. England addressed the concern that the previous design of Parcel 4 would have too much hardscape. She agreed that a barren plaza on Parcel 4 would not be a desirable solution; instead, the proposal now includes landscape features that are intended to be flexible, accommodating everyday use as well as special events. She indicated the tilted landscape panels at the edges of the major paved spaces. Some edges of the panels would be flush with the paving; other edges would be seating walls or low curbs. The seating could be used informally at any time, and during special events this seating would supplement chairs or standing space in the paved areas. She said that the tilted configuration would discourage pedestrian traffic that would damage the plantings; some panels would have lawns that people could occupy, such as for a concert in the park. A grove of trees near the Metro station's escalators would have grates to allow for both pedestrian circulation and healthy trees; the placement of this grove is intended to help with wayfinding, as people exiting the Metro decide whether to traverse the park or turn northwest toward the Eastern Market buildings. Another grouping of trees is intended to provide a buffer along the busy intersection of 8th Street and Pennsylvania Avenue, improving the comfort of people within the park. She said that a water feature previously shown near the library is now proposed at the northwest corner of Parcel 4, helping to attract people and draw them into the park; this corner was previously shown as just a paved area intended primarily for pedestrian traffic. She noted that the submission includes a conceptual site plan labeled "Option 2" that has a larger lawn area near the bosque, but this option is not preferred by the community nor the D.C. government.

Ms. England described several other modifications to the design. The number of proposed trees has increased, and more of the existing trees would be retained. The provision of shade has been studied carefully in relation to the placement of seating and other design features. The selection of tree species has been carefully considered within the context; for example, street trees within the park would relate to those on adjacent blocks. Crabapple trees would be planted within the two parcels that are wide medians within Pennsylvania Avenue, based on the historic precedent of species and layout identified by the National Park Service; she noted the Commission's previous concern with the continuity of the avenue's streetscape and the important view northwest toward the U.S. Capitol. She emphasized the refinement of tree placement to improve the edge definition of the park's open spaces and the South Carolina Avenue view corridor. She said that the proposed materials would be consistent with the Capitol Hill neighborhood, ranging from traditional to modern. She concluded with a series of perspective views illustrating the proposed design.

Chairman Powell invited comments from the Commission members, observing that the design appears to have improved substantially. Ms. Meyer commented that the proposal has some strong ideas but remains overly complex, despite the effort to simplify the previous version of the design. She noted that the park's two largest parcels are each slightly over an acre, a modest size compared to the dense design. She suggested further simplification, perhaps devoting more of the budget to planting additional trees. She also questioned the playground siting on Parcel 1, observing that its southern exposure would make it uncomfortable in the summer; she suggested reducing the large number of elliptical spaces in the playground area in order to free up more space for planting trees to provide shade. She observed that Parcel 4 would contain two water features; she suggested eliminating the water feature near 8th Street to allow for expansion of the bosque, which is a flexible and moderate-cost space that allows for pedestrian movement in the shade. She said that refinement of the bosque should also include locating trees to provide a stronger definition of the South Carolina Avenue view corridor, which appears to be merely a gap in the current landscape proposal. More generally, she suggested grouping the trees to provide a stronger sense of closed and open areas across the park's largest parcels. She discouraged the proposed placement of the kiosk, commenting that it would ruin the potential interest of the Town Center Plaza and clash with its geometry. She suggested moving the kiosk to the plaza's edge to help define this space, rather than occupying the middle where people should be; alternatively, the kiosk could be placed within the bosque or elsewhere.

Ms. England responded that she agrees with the need to provide shade for the playground; more trees may be added to the design for this area as the design is developed, after the selection of specific pieces of playground equipment. She added that trees have been added within the South Carolina Avenue alignment; the previous design had no trees within the width corresponding to the avenue's cartway, but some understory trees are now included in this area based on recent consultation with the Commission staff and the D.C. Historic Preservation Office concerning options for treating this corridor. Some existing trees within the cartway alignment, previously proposed for removal, are now shown as retained. She added that the additional trees will reduce solar heat gain as well as provide shade, and she offered to study the playground-area plantings further.

Mr. Krieger commented that the design has improved; he cited the better recognition of each of the large parcels as an individual park that responds to a distinct context. He described the overall effect of the multiple parcels as a treed opening within the city, and he agreed with Ms. Meyer's recommendation for additional trees. He said that her suggestion to strengthen the use of trees in defining the South Carolina Avenue alignment should not be construed as a recommendation to impose a strict geometry of trees to frame this corridor; the Commission is instead suggesting additional trees that would clarify the spatial legibility. He expressed support for the special paving treatment to connect Parcel 4 with the branch library; he offered general support for the design of this parcel, while agreeing that it should have more shade and fewer designated special areas. He suggested that the Commission approve the current concept and continue providing recommendations as the design is developed.

Ms. Gilbert commented that the design for Parcel 1 has improved substantially, but Parcel 4 would be improved if the design team were more willing to say no to some of the requested program elements. For example, she said that the fountain area near the busy intersection of 8th Street and Pennsylvania Avenue would be an uncomfortable space to occupy; a better treatment for this area would be an extension of the shady bosque. The functions of the plaza across from the library could extend into the Town Center Plaza, and an amphitheater could be included. She discouraged the proposal for small panels of landscape to direct the route of pedestrians exiting the Metro station, commenting that this design would result in frustration; she instead recommended a design for this area that provides shade while allowing pedestrians to move in all directions. She observed that people at this busy location who are seeking a quiet place to sit could easily see the opportunities toward the library or in Parcel 1 across Pennsylvania Avenue, adding that the nearby bosque could serve as a meeting point. She summarized that further editing of the design is needed, with an emphasis on the tree canopy and the larger gestures of the design, such as the bosque and the library garden for Parcel 4.

Chairman Powell reiterated that the design has improved, and he agreed that further simplification would be beneficial; he expressed appreciation for the revisions that have been made. He offered a motion to approve the concept with the comments provided; upon a second by Mr. Dunson, the Commission adopted this action.

2. CFA 16/MAY/19-8, KIPP DC M.C. Terrell Campus/Somerset Prep DC Public Charter High School (formerly Mary Church Terrell Elementary School), 3301 Wheeler Road, SE. Building modernization and additions. Concept. The Commission acted on the submission earlier in the meeting without a presentation, following agenda item II.A.

The Commission departed from the order of the agenda to consider item II.G.1.

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

1. SL 19-145, Folger Shakespeare Library, 201 East Capitol Street, SE. Building renovation and additions. Concept. Ms. Batcheler introduced the concept submission for alterations to the Folger Shakespeare Library, constructed in 1932 and designed by noted architect Paul Philippe Cret, who was a member of the Commission from 1940 to 1945. The building is listed on the National Register of Historic Places. She described the building's pair of main entrances, facing East Capitol Street from each end of the north facade; these entrances are reached via the terrace atop a plinth extending across the north facade, which requires using steps unless a temporary aluminum ramp is put in place. Inside the entrance; the main floor has multiple level changes that pose additional challenges for barrier-free access. The proposal would create barrier-free access through new lower-level lobbies and exhibition space located below the existing plinth; the approach to the two new entrances would be through new sunken gardens at the plinth's east and west ends. Barrier-free access to the plinth terrace would be provided through a site ramp; the existing entry doors facing the plinth would no longer be used except for emergency egress. She noted that the project involves significant modifications to this important historic building and its site, as well as substantial construction in public space; coordination is ongoing with the D.C. Historic Preservation Office and the D.C. Public Space Committee. She asked Michael Witmore, director of the Folger, to begin the presentation.

Mr. Witmore said that the building contains a precious collection of rare books and manuscripts related to European history from 1470 to 1700, as well as a major collection of materials related to Shakespeare. One of his goals as the Folger's director is to make the institution more open to the public. He noted that the building's site, at the transition between the federal and residential areas of Capitol Hill, was made available through an act of Congress in recognition of Henry Folger's intent to donate his important collection to the American people. Despite the public nature of Folger's gift and the universal relevance of the collection, the building does not currently accommodate universal access. He added that the building's Great Hall, currently used for exhibitions, was designed by Cret as a light-filled space, which poses problems for the display of fragile books and manuscripts. The Folger has therefore hired the firms Kieran Timberlake and OLIN to resolve the building's problems of access and exhibit space, with a solution that involves the design of the site's landscape. He said that the proposal honors Cret's design while allowing the Folger to share its resources more widely with the public. He introduced architect Stephen Kieran of Kieran Timberlake and landscape architect Hallie Boyce of OLIN to present the design.

Mr. Kieran summarized the goals of the project. The goal of accessibility includes the technical solution for barrier-free access, as well as conceptual access in making the building and its collection available to a much wider public. Visitors would come to the building for its theater as well as the two proposed exhibit halls, making the Folger's important collection more visible to the public; he contrasted this goal with the Folger's original emphasis on serving as a specialized research library. The civic presence of the East Capitol Street landscape is an important design consideration, with an effort to maintain the legibility of the ground plane and minimize obstructions rising from it. A final design goal is geometric simplicity, consistent with the simple orthogonal clarity of Cret's design.

Mr. Kieran described the context, indicating the buildings of the Library of Congress to the south and across 2nd Street to the east; the U.S. Supreme Court building is located diagonally to the northwest. The smaller-scale buildings of the Capitol Hill neighborhood are to the north and east. The Folger site includes a driveway that is no longer in use, serving instead as a parking area; it would be replaced with gardens. He indicated the existing access to the building: seven steps up from the sidewalk to the plinth terrace, then an additional seven steps up from the terrace to the building's entrance doors, and an additional three steps within the small entrance vestibule. He indicated the existing multi-run temporary exterior ramp, which would no longer be needed upon implementation of this project that would provide a single solution for public access. He noted that an additional barrier-free access route is available at the rear of the building, but this is not suitable for public use. He described the building's role as part of the transition between the government and neighborhood buildings; the transition can be seen in the detail of paving materials for sidewalks, which are concrete to the west and brick to the east. He indicated the range of site details in the context, including knee walls, rail fences, security bollards, and barriers of plantings along the sidewalk. He noted that the Folger site, like other properties in the neighborhood, has a significant distance between the property line and the sidewalk; this zone is part of the city's public space. He said that the public space along East Capitol Street is typically unobstructed for nearby buildings, resulting in a civic corridor.

Mr. Kieran presented some of the initial conceptual studies for the project. An early idea was to construct simple pedestrian ramps leading down from 2nd and 3rd Streets to newly constructed space beneath the plinth. However, the available length for the run of the ramp was too constrained; the descent of a ramp at a maximum slope would not allow for the interior space to have sufficient height for the desired exhibition galleries. The relationship between ramp and landscape in this early study was also problematic. The current proposal addresses these concerns by combining the ramping with new gardens, allowing for the more desirable experience of entering the building through a garden. He said that this solution would put less emphasis on the added space as an architectural facade, and the ramping within the gardens could be at a sufficiently shallow slope along most of its length to eliminate the need for handrails; the result would be gardens that have an open appearance that is inviting for the public. He described the proposed gardens as the first part of the suite of rooms that would be created in this proposal, corresponding to Shakespeare's many references to the natural world.

Mr. Kieran said that numerous refinements have been made in developing this concept, as a response to the review process. The ramps have been aligned orthogonally with the plinth, and a wall separating the plinth from the gardens has been lowered. The relationship of the ramps to the plinth edges has also been refined, involving the opportunity for providing a landscape buffer. He indicated several different iterations of the concept that have led to the current preferred design, which he said has the simplest geometry and the most generous plantings. He noted that the proposed east and west entrances would both provide access to the new galleries, while the west entrance would be used for access to the theater, consistent with the layout of the existing building; the design includes additional support amenities for the theater. Other program elements include an expanded gift shop, public restrooms, and an education lab that would serve the many local school groups that visit the Folger. He indicated the additional shallow ramp that would rise from the sidewalk level to the plinth terrace, which is important as a place for viewing a series of nine bas-relief sculptures placed low on the Folger's north facade. He emphasized the proposal's unity of landscape and architecture as a single composition, providing an experiential sequence from the city and neighborhood to Shakespeare's world.

Mr. Kieran provided additional perspective, elevation, and section drawings of the proposal, indicating the effort to avoid new vertical protrusions from the ground plane. He said that the site's property line along East Capitol Street runs through the plinth; the proposed new interior space would occupy the entire area beneath the plinth, and would therefore be partially in public space. He noted that the plinth would retain its existing configuration, and the interior ceiling height for the galleries could be a maximum of slightly less than twelve feet.

Ms. Boyce presented the landscape design, which she said is inspired by Shakespeare's love of nature. She noted that many of Shakespeare's plays are set outdoors, and his text contains many references to natural elements; she cited a passage about the transformative power of nature to bring people together. Another inspiration is the work of many designers to incorporate text into the landscape, serving to relate the gardens to the literary collection inside the building. She described the goal of a landscape that educates people and draws them into the Folger, with a particular emphasis on younger visitors; the landscape would also serve as a place of rest and relaxation for the Capitol Hill neighborhood with shade, seating, and seasonal variety.

Ms. Boyce said that the plantings would primarily include species native to Washington, supplemented by plants referenced in Shakespeare's writings. She presented a photograph of the site in the 1930s, indicating a hedge along the sidewalk; she said that the current landscape is much simpler, with an emphasis on open lawns. She indicated the seating that exists on the site, although access is not always easy due to fencing, and a large magnolia tree that would be moved south to allow for the proposed entrance sequence. She also indicated the large street trees and said that the location of their roots would be studied to adjust the design and allow for their continued growth. She said that two magnolia trees to the east would be removed, and eleven new trees would be planted; red maples are under consideration, which would add a great range of seasonal interest. Flowering trees would be planted in the new entrance gardens at the east and west. She said that the extent of lawn would be reduced, with more use of groundcover, seasonal bulbs, perennials, and evergreens. The entrance gardens would include seating, fountains, and sculpture. She also indicated a small "Juliet Balcony" adjacent to the theater lobby, serving as an additional reference to Shakespeare's plays.

Mr. Krieger commented that the designers have been given a seemingly impossible task, and he commended their success in being able to solve it. However, he observed that the solution appears strange and illogical; for example, as suggested by the perspective views, somebody approaching the building and looking for the entrance would not think to follow a convoluted downward path to find the new "mousehole" entrances. He acknowledged that the proposal may be the only feasible solution, despite its illogic. He noted the initial concept that was shown in the presentation, but was rejected, that had a simple ramp leading down from the sidewalk to a new front door; he commented that most buildings have this type of simple solution, and he asked whether the dimensional problems of this concept would be amenable to resolution through further study—perhaps by providing further downward ramping on the interior. He added that this concept would still allow for new gardens to the east and west of the plinth, if desired. He acknowledged that the design team's preferred concept would require people to traverse a garden, which he said is advantageous. Mr. Kieran responded that the dimensional constraint was too great; the initial concept already included a two-foot descent within the building, and the need remained for several feet of additional descent on the exterior.

Mr. Krieger asked why an additional ramp would be provided for access to the plinth terrace; Mr. Kieran said that it is required by regulation, as part of the public space that is used for viewing the building facade's public art of nine bas-reliefs. He described these bas-reliefs as part of the Folger's public experience, and he said it would not be permissible nor desirable to let the terrace remain without barrier-free access. Mr. Krieger observed that the presented drawings convey varying characters for this ramp, sometimes suggesting an odd appearance. A further oddity is that people who reach the terrace would have a very circuitous and confusing route to reach a building entrance—having to go back down the ramp from the terrace to the sidewalk level, and then down the lengthy sequence of ramps to a below-grade entrance; he questioned whether the intended universal access is really being provided. He also observed that people on the terrace would not be able to closely approach the bas-reliefs, perhaps making access to the terrace less necessary. He suggested that a better solution might somehow be available, such as by sloping a lawn panel. He acknowledged the emphasis on an orthogonal geometry, but he suggested that a different geometry could respond better to the prevailing direction of visitor arrival. He also expressed concern that the proposed design might encourage visitors to walk through the plantings to avoid the complicated entrance sequence that is intended.

Mr. Kieran acknowledged the concerns with the proposal. He said that the entrance steps to the current main entrances would need to remain as part of an egress route, even though these entrances would be closed for access; visitors would be discouraged from approaching these doors through signage. Unlike some other podium-configuration buildings in Washington, this podium is not a full story above the street level, and descent to the new entrance is therefore necessary. He said that an entrance oriented to one corner of the site was studied but rejected because it would intrude into the public space corridor along East Capitol Street. Mr. Krieger emphasized the need to make the new entrance sequence legible to visitors approaching from the corners of the site. He observed that the public space corridor is largely defined by building facades and trees, and depends less on the exact extent of hardscape and plantings on the ground plane. Mr. Kieran noted the additional concern that incursions into public space are subject to review by the D.C. government. Mr. Krieger summarized his general response of being impressed by the proposed gardens and the solution for access.

Noting his support for Mr. Krieger's remarks, Mr. Shubow raised the question of whether this major intervention for barrier-free access needs to occur at both ends of the plinth. He suggested that one of the existing entrances could remain in use for those who want to enjoy the traditional entry sequence, including close inspection of the bas-reliefs, while the alternative of a sunken garden could also be provided. Mr. Kieran clarified that barrier-free access is not the only reason for the proposal; Mr. Shubow agreed, while noting that the presentation has confusingly used the term "accessibility" in different ways. Mr. Kieran clarified that the interior of the Folger has a dual program: a library that is used primarily during the weekdays, and a theater that is used primarily at night and on weekends. He said that two points of access are preferable for handling this dual program with different times of use. He also noted that Cret's drawings show careful study of this issue. Mr. Shubow acknowledged that the lower-level entrance solution is ingenious, and he recognized that many buildings are entered through a low space before visitors ascend to a large, special room. He clarified that his concern is with the proposed configuration of ramps in relationship to the corners of the site. Mr. Kieran responded that the length of ramping results from the desire to have a shallow slope for most segments in order to avoid the need for handrails, which he said could give the visual effect of a "cattle chute."

Mr. Dunson agreed that the design challenge seems at first to be impossible, and the proposed solution has the initial appearance of being contorted; but based on the explanation provided, the proposal makes sense. He also agreed with the concern that inviting visitors to ascend to the plinth may not make sense in relation to the downward sequence to enter the building; he noted that this issue was apparent during the previous day's site inspection by several Commission members. Mr. Witmore responded that the building facade is designed with features that relate to the Folger's mission; he recalled a quotation from Mrs. Folger that the building itself serves as an illustration of Shakespeare's First Folio. He said that close visitor access to the building, as best achieved from the plinth, is therefore of comparable importance to providing visitors with close access to materials from the collection as displayed in the exhibition galleries.

Mr. Krieger observed that the design drawings give the misleading impression that visitors could descend directly from the plinth to a new building entrance; he said that this would be a desirable feature, instead of the frustration of ascending to the plinth and then having to return by the same ramp to start a new descent to the entrance. Mr. Kieran responded that an earlier version of the design had somewhat achieved this through a pairing of ascending and descending ramps; however, this design was rejected because it would protrude seven feet further into public space. He reiterated that this proposal requires approval from other review agencies, and Mr. Krieger acknowledged the unique challenges of designing in Washington. Mr. Kieran added that the proposal is not offered as a compromise, but it has instead gained strength in responding to the multiple parties that are involved in the process. Mr. Krieger questioned whether the proposal is stronger than some of the earlier sketches that have been shown, commenting that some exterior features could be perceived as part of the public space corridor rather than intrusions into it. He said that the review process in Washington can be overly bound to tradition and correctness while losing sight of what is essential. He expressed a willingness to support the concept proposal with the expectation that the design team would return with a more detailed presentation.

Secretary Luebke summarized the apparent consensus of the Commission to support the concept with some adjustments. Mr. Krieger suggested further exploration of a more direct connection between the terrace and the lower-level entrances, so that visiting the terrace would not be completely independent of the route to an entrance; Ms. Gilbert agreed. Ms. Meyer acknowledged the many constraints on the design, and the problematic legacy of the tradition of designing buildings for only able-bodied users. But she observed that the rejected design had a ramp with a clear relationship to the plinth, which is less satisfactorily resolved in the current proposal. She said that the design could be especially frustrating for disabled visitors who will follow the obvious ramped route to the plinth, only to eventually find that this route does not provide any access to the building, which requires returning to the corner of the site for a lengthier route. Notwithstanding the intended close viewing of the building facade, she said that the proposal will more likely result in annoyance and confusion; she described the design as potentially cruel and mean, particularly to the disabled. She suggested eliminating the ramp to the plinth terrace, and instead focusing on development of the descending sequence to the new entrances. She noted the numerous great Shakespeare gardens around the country and encouraged this feature as part of the landscape design. Ms. Gilbert asked about the existing Elizabethan garden on the east side of the site, a very special feature of the Folger; Ms. Boyce said that it would remain.

Mr. Shubow offered an alternative to Ms. Meyer's recommendation for removing the ramp to the plinth; he suggested instead that a ramp to the plinth could be supplemented by an additional ramp leading up from the plinth to one of the historic building entrances. This additional ramp could be designed more carefully than the existing temporary ramp. Ms. Boyce responded that the length of ramping would be significant due to the desire for a shallow slope that would eliminate the need for handrails; the design also avoids substantial drop-offs that would require guardrails. The intended result is an open and welcoming character for the garden spaces. She said that a steeper ramp to the existing entrance would likely need to be configured similar to the current temporary ramp; Mr. Kieran added that a permanent ramp would also require modification of the two planters flanking the doorway. Mr. Shubow acknowledged that some alteration could be acceptable; Mr. Kieran added that one of the principles for this project is to avoid creating impediments in front of Cret's building. Ms. Meyer added that the problem of additional stairs on the interior would also need to be resolved.

Mr. Witmore responded to the Commission's concern that the proposed access to the plinth would be perceived as a mixed signal or perhaps a trap. He said that this outcome is troubling because it is not consistent with the intent to create an open, welcoming character. He agreed with the Commission's concern about the lengthy, meandering route into the building; but he said that if the route is sufficiently clear, then the journey would have the quality of a Shakespearean sentence that meanders but reaches its conclusion. He said that seeing an entrance and garden from the corner of the site should provide visitors with sufficient motivation to make the journey.

Mr. Krieger offered a motion to approve the concept with the request for further consideration of eliminating the ramp to the terrace, or else providing a more direct connection from the terrace to a building entrance. Mr. Kieran agreed to work with this advice, adding that the recommendation may even result in a cost savings. The Commission adopted this action, with Mr. Shubow voting against the motion.

Ms. Meyer and Mr. Krieger departed the meeting at this point. The Commission returned to the order of the agenda with item II.F.3.

F. District of Columbia Department of General Services

3. CFA 16/MAY/19-9, John Eaton Elementary School, 3301 Lowell Street, NW. Building modernization and additions. Concept. Mr. Lindstrom introduced the proposed alterations to the John Eaton Elementary School, located within the Cleveland Park Historic District; the school itself is historic, with the oldest portion built in 1910 and successive additions through the 20th century. He introduced Bill Spack and Chris Ambridge of Cox Graae + Spack Architects to present the design.

Mr. Spack said that the proposal consists of modernization of two buildings of the existing school complex, as well as replacement of a third building with a new addition. He presented a diagram of the school's evolution. The first Eaton Elementary School building from 1909–11, designed by Appleton Clark, Jr., is three stories tall and approximately 80 by 80 feet, located at the southwest corner of the full-block site. He said that its Renaissance Revival architecture was described at the time as "exuberant." A separate, second building of approximately the same size and simplified style was added in 1921–23 at the southeast corner of the site, accommodating growth in the area; a hyphen structure connected the first two buildings, serving as the school's entrance. In 1929–30, a large Colonial Revival-style assembly room was added behind the hyphen. In 1979–81, the hyphen was replaced by a Brutalist-style addition containing the school library.

Mr. Spack said that the current project results from the general disrepair of the school complex, the need to update its systems, and changing educational needs. He described the school as inadequate for its population of 450 to 500 students, a problem that would only barely be addressed by the proposed six-percent expansion of the school's program area. He said the challenge is how to accommodate the expansion within the historic complex; the design process has included extensive consultation with neighborhood representatives, the D.C. Historic Preservation Office, and the Commission staff, with a variety of design options explored. The design strategy that emerged from historic preservation discussions is to retain the two oldest buildings at the southwest and southeast corners of the site, giving them precedence in the new design for the school, and retaining a sense of their original appearance as two separate buildings. In the proposed configuration of the school, each of these two buildings would be exposed on three sides; while their front facades are on the south along Lowell Street, the D.C. Historic Preservation Office has given equal importance to their rear facades on the north. The proposal is to replace the two later additions in the middle of the complex with a new infill building that contains additional program space while respecting the scale of the flanking historic buildings, minimizing the aesthetic impact on them.

Mr. Spack presented photographs of the existing conditions and the context, describing the site as being at the center of Cleveland Park's residential neighborhood. He noted the significant slope of the site, highest along Lowell Street and dropping ten feet toward 33rd Street on the east and an additional twenty feet toward Macomb Street on the north. He emphasized the original building's beautiful architecture, which has influenced the elevations and materials of the proposed construction; examples of the historic detailing include light-colored brick encircling the windows and an abandoned rooftop monitor that would be restored as part of this project. The second building, although similar in style, has less exuberant detailing. In addition to restoring the historic exteriors, the project will restore features of the interior, including the pinwheel layout of classroom spaces within each building's square plan.

Mr. Ambridge presented the proposal in more detail, beginning with a discussion of the site. He said that although the site is constrained, the outdoor space is very important to the school community. The buildings occupy a significant portion of the site, and the proposal is to minimize the built footprint and to use the outdoor space as efficiently as possible. One design strategy is to place some of the program below grade to the extent feasible; for example, the new gymnasium would be on the lower level, with an occupiable outdoor plaza located on its roof. A separate cafeteria would also be provided, a substantial improvement from the existing shared-use space for the cafeteria and gymnasium. The proposed contouring would progress downward through a series of flat terraces to accommodate the site's grade change. The playing field at the site's northeast corner would be skewed slightly from the orthogonal street grid to accommodate the adjacent slope. The school's loading dock would remain in its current location, using the existing curb cut near the middle of the 34th Street frontage. The school's main entrance would also remain in its current location at the center of the Lowell Street frontage, with a new design for the entrance plaza; the two-level library would be located above the main entrance. The classrooms would be organized in three clusters, each grouped around a central core with an elevator and open staircase. The new building would have a skylight and areas of green roof, and the historic buildings would each have a central skylight.

Mr. Ambridge presented the proposed elevations, which are derived from the traditional organization of the historic facades while not competing with them. Most of the new building would be clad in terracotta, likely more orange than is illustrated in the drawings; the intent is for the new material to be complementary to the historic exterior masonry. The base of the new construction would be a dark gray brick; the intended treatment of the top portion of the building is still evolving, possibly using a slate rainscreen and metal cladding at the eaves. The window detailing is designed as a contemporary reinterpretation of the window treatment on the historic buildings, possibly using windows of a similar size within a modern-looking projecting cast stone frame supplemented by solar shading; these details are still being developed to look less imposing than seen on the elevation drawings. An internal staircase on the north end of the new building would be expressed with glass on the north facade; this feature is currently being developed. A monitor on the north would bring daylight into the gymnasium.

Mr. Ambridge noted that the above-ground height of the new building would be three stories along Lowell Street on the south but four stories toward the northeast due to the descending grade. He provided additional details of the treatment of the Lowell Street facade: the new building would have recessed hyphens adjacent to the historic buildings, allowing their corners to remain exposed along the street; a large window would mark the double-height library, providing daylight and a view of the library's internal staircase. He noted that the original school building had an entrance canopy, which no longer exists; the proposal would replicate the original canopy design along the Lowell Street facade, reusing the two lion sculptures in the facade as part of the canopy support system. Restoration of the original wood doors and fan light is also being considered. He said that additional historic facade details would be restored, and the roofs would be replaced.

Mr. Ambridge concluded with several perspective renderings of the proposal; he indicated the complex grading around the site. Mr. Spack emphasized the many people and organizations involved in developing this proposal.

Ms. Gilbert asked if the site's outdoor space is accessible to the community when not being used by the school; Mr. Spack responded that the site would be fenced, with multiple entry points provided. Mr. Dunson commented that the proposed building would be an improvement from the early 1980s building that it would replace. However, he said that the north elevation of the new addition does not appear well resolved, due to the challenge of terminating the building within a complex setting of shifting grades and requirements for interior daylight. He suggested further effort to compose this side of the school complex in a clear manner, with less architectural "gymnastics." As an example, he recommended simplifying the complexity of the roof form, which he said is less well composed than on the south and east sides; the goal should be a new building that is respectful of the two historic buildings. He expressed support for the proposed materials and window detailing, as well as the scale and the contemporary design approach for the new building.

Mr. Spack acknowledged that the treatment of the ground plane has been challenging; he added that the strategy of placing large programmatic elements in the lower level appears to be successful in decreasing the above-grade massing, but it results in the challenge of bringing daylight to these spaces. He said that the goal for the massing on the north, based on consultation with the community and the D.C. Historic Preservation Office, was to minimize the intrusion of the new building into the site's open space; this has been achieved, along with barrier-free access to each site area, but the relationship of the massing to the site can be studied further. He cited the additional challenge of wanting to relate the new construction to the school's historic buildings, using a contemporary design approach that does not appear alien to the context; he said that this was apparently less of a concern for the early 1980s addition. He said that the relationship includes expression of a base, middle, and top, as well as remaining below the roofline of the historic buildings. Mr. Dunson reiterated his support for the intended design approach, and he cited the exposed corners of the historic building along Lowell Street as a desirable feature; however, he said that the exposed corners on the north are less successful, located in dark areas obscured by the new construction. Mr. Spack said that the design strategy is similar at these locations—using recessed hyphens of glass where the new construction abuts the historic buildings—but this configuration may need further study on the north side.

Ms. Gilbert asked for clarification of the intention to select a brick color that is complementary to the historic masonry. Mr. Spack said that the material selection in relation to the historic brick has been the subject of much discussion. One approach is to select a different material that approximately matches the color of the historic brick; this could be achieved with the terracotta rainscreen, which would be clearly modern with larger units. Another approach is to use a different color, perhaps more warm or neutral. Mr. Dunson suggested a color that is closer to the historic masonry instead of the bright color shown on the drawings; Ms. Gilbert agreed. Mr. Shubow added that the bright color calls too much attention to the new construction; instead, the historic buildings should appear most prominent. Mr. Powell agreed that the colors appear jarring; Secretary Luebke suggested that the solution may be to select brick from the darker end of the available color range.

Mr. Shubow commented more generally that the proposed additions appear very much out of character with the historic buildings and neighborhood. He observed that in the past, additions could be stylistically harmonious with an existing building, while this proposal obviously has a very different design vocabulary. He observed that the drawings show different materials as well as different colors in comparison to the historic buildings, and he said that he would prefer a more contextual design. Mr. Spack acknowledged the importance of this topic. He said that the intended design approach is to create something "of our time," and he suggested that this approach was actually followed for each of the earlier additions to the original school building. He said that the philosophical approach to the design is to follow the principles of the proportion, scale, and facade organization of the historic buildings, while deriving a modern language rather than replicating their detailing.

Ms. Gilbert commented that the large new windows would be a successful feature; she compared them to the large eyes of the students looking outward, and an opportunity for those inside the building to enjoy views of the landscape.

Chairman Powell expressed support for the proposal as well as the direction provided by the Commission. He agreed with the strategy of designing a building that is of our time, commenting that new construction could not be made to look exactly like the historic buildings. He offered a motion to approve the concept submission with the comments provided. Upon a second by Mr. Dunson, the Commission adopted this action; Mr. Shubow voted against the motion.

4. CFA 16/MAY/19-10, West Elementary School, 1338 Farragut Street, NW. Replacement building. Concept. The Commission acted on the submission earlier in the meeting without a presentation, following agenda item II.A.

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

The Folger Shakespeare Library, agenda item II.G.1, was heard earlier in the meeting preceding item II.F.3. The Commission returned to the final item on the agenda.

2. SL 19-152, The Mills Building, 1700 Pennsylvania Avenue, NW. Building renovation and additions. Concept. Ms. Batcheler introduced the concept proposal for renovation of the Mills Building, a commercial office building dating from 1966. The building is located at the southwest corner of 17th Street and Pennsylvania Avenue, NW, across from the Eisenhower Executive Office Building (EEOB), the Renwick Gallery, and the closed blocks of Pennsylvania Avenue in front of the White House and Blair House. She said the proposal includes a three-story addition on top of the building, the enclosure of the existing ground-level arcade, overcladding of the existing precast concrete facades, and a new entrance canopy. She said that the existing street facades project beyond the property line into public space, and the proposed overcladding would project further; the D.C. Public Space Committee will therefore review the project and will consider the Commission's advice on whether the overcladding provides a design benefit for the building. She noted that the Commission members have received copies of a letter of support from Advisory Neighborhood Commission 2A. She asked architect Greg Zielinski of Gensler to present the design.

Mr. Zielinski said that when it was built, the Mills Building was split-zoned into two different zoning designations. Excluding the penthouse, the height for the eastern portion of the building toward 17th Street was capped at 90 feet, while the western portion was capped at 110 feet. The zoning has subsequently changed, and the allowable height for the entire property is now 130 feet plus a twenty-foot-tall tall penthouse; the proposed renovation is intended to capture some of this allowable height.

Mr. Zielinski said that the existing precast facades would have an applied overcladding of glazed terracotta tiles in a two-story pattern; the proposed tile color is a warm gray that would be compatible with the landmark EEOB, directly to the east across 17th Street. Alternating spandrels and vertical fins of the existing facades would be overclad with dark metal panels. The first-floor arcade would be filled in to extend retail space to the primary facade plane, which he said will bring in more daylight. He noted that the existing building has a heavy spandrel above the first floor; the proposed design would treat the first floor as part of a two-story expression, using dark metal panels to obscure part of the existing spandrel. He provided samples of the proposed materials for the Commission's inspection.

Mr. Zielinski said that the three-story rooftop addition would be treated as a steel and glass pavilion set on top of the existing mass. Its light architectural character, along with stepbacks on the three exposed sides, would preserve the perception of the building's existing height and its urban role as a transition between the 70-foot-foot tall Consumer Financial Protection Bureau (CFPB) headquarters across G Street to the south and the 130-foot-tall buildings to the west and north. The stepback dimension along G Street and Pennsylvania Avenue would be four feet. He said this dimension is proposed because sightlines to these facades of the Mills Building are so limited that the four-foot stepback would be sufficient for the added stories to be perceived as a different mass; this dimension also matches the setback of the adjacent building to the west, which does not extend to its streetfront property lines. A more substantial stepback would be provided on the east, facing 17th Street; this responds to the availability of more distant views of the building along 17th Street. The southern part of this stepback would have a north-south orientation that aligns with the stepback of the CFPB building to the south—28 feet back from the primary facade plane on 17th Street; the northern part of the stepback would be at an angle that is perpendicular to the Pennsylvania Avenue facade. Above the three-story addition, the sixteen-foot-high upper penthouse level would step back substantially further—sixteen feet from the north and south facades of the three-story volume, and thirty feet from the two planes of its eastern face. He said that the moderate height and significant setbacks for the penthouse would result in it not being seen from close viewpoints; in longer views, such as from Lafayette Square to the east, the penthouse would appear to merge with the three added floors to avoid the wedding-cake effect of multiple stacked boxes. He said that the resulting perception would simply be the original building volume below and an additional volume on top. He added that the "butterfly" fold of the 17th Street stepback—the inward angle of the two stepback planes, which would be present on both the three-story addition and the upper penthouse—is related to the structural grid of the existing building below and would help to distinguish the upper floors from the main building mass.

Mr. Zielinski described several additional changes to the building. The entrance and lobby would be widened; a new interior egress stair would be added, and the loading area on the south along G Street would be enlarged to comply with current regulations. On the north frontage, the glazed lobby would be flanked by the vehicular ramp to the parking garage on the west and the new retail facade on the east, creating a more imposing expression along Pennsylvania Avenue.

Mr. Zielinski presented further details of the proposed overcladding. The existing rose-colored precast facades extend four inches beyond the property line around most of the building, with a consistent pattern of one-story high windows that appear squeezed within the structural bays. The proposal would overclad this precast with approximately six inches of terracotta or one inch of metal panels. The variation in depth, as well as the tonal difference between the terracotta and darker gray metal, would articulate a new double-story grid pattern of the facades. The new dark window frames would recede, while the brighter terracotta on alternating piers and spandrels would give the facades a grander, more monumental appearance that is appropriate for the context. The facades of the added three-story volume would be entirely dark metal and glass, with wider spandrels to reduce their perceived scale while being compatible with the floors below. He concluding by presenting several perspective views of the proposed design.

Ms. Gilbert asked why the design team chose not to use more stepping of the added upper floors; she noted an earlier drawing in which the penthouse had been treated like a terraced ziggurat form. Mr. Zielinski responded that this was explored but the addition began to appear like a multi-tiered wedding cake, and the single addition on top of the mass seemed like a simpler, tighter solution. Ms. Gilbert asked what would occupy the roof between the stepback of the addition and the edge of the existing building. Mr. Zielinski said the eastern roof area would be a private terrace for the ninth-floor tenant; an additional roof terrace for all tenants would be located at the upper penthouse level. A glass railing around the terrace space would be set back four feet from the perimeter; segments of this railing would align with the facade of the adjacent building to the west. Mr. Dunson asked about the current use of the roof; Mr. Zielinski confirmed that it is currently a very large private terrace.

Mr. Dunson observed that the proposed changes would add a sense of scale and improve the building's appearance; he cited the new proportioning of windows through verticals and spandrels. He said that the renovated building, although bigger, would be more compatible with its context, and he expressed support for the visual interest that would be provided by the new color palette. Ms. Gilbert agreed that the changes to the facades would be elegant.

Mr. Shubow also said that the proposed facade alterations would be a marked improvement, commenting favorably on the ribbed terracotta. However, he said that he has concerns about the added three-story "pavilion," which he said looks like part of a Modernist building by Mies van der Rohe stuck on top of a more contemporary building ornamented with ribbed terracotta panels. He suggested that this issue could be solved while avoiding the wedding-cake effect: the volume of the added floors should be aligned with the adjacent streets, and the addition's facades should be in the same style as the building beneath it. He indicated the perspective view of the proposal from the south along 17th Street, which emphasizes the difference in appearance between the two masses.

Mr. Powell said that he likes the proposal but thinks it would benefit if its two major masses were more closely related. Secretary Luebke noted the complex history of the context: the massing of the CFPB building was designed specifically in relation to the historic Winder Building to its south, and both the CFPB and the Mills Building were required to step back from 17th Street above a height of 75 feet. He said the guidance given by the staff emphasized this longstanding urban design principle in the area to keep building heights modest along 17th Street to frame the EEOB, while allowing a stepback to additional height further west. Mr. Shubow responded that he is not objecting to the stepback; his concern is the design of the stepback with a butterfly angle along 17th Street, and he recommended instead that the facade of the upper mass be parallel to 17th Street. Mr. Zielinski said the existing building has this butterfly shape in its internal column layout; the design team thought that extending this configuration into the addition, as well as continuing the material of metal panels for the addition's facades, would help to relate the building's lower and upper masses. Chairman Powell noted the consensus of the Commission that the design is generally good, but this particular issue needs more study. Mr. Dunson agreed; he said his main concern is that from some directions, the butterfly angle looks too pronounced and is just sitting on the lower building mass. Ms. Gilbert observed that the butterfly angle will not be noticed from other directions; Mr. Powell agreed.

Mr. Dunson offered a motion to approve the concept design with the comments provided, particularly those regarding the upper volume and details. Upon a second by Mr. Powell, the Commission adopted this action.

There being no further business, the meeting was adjourned at 5:47 p.m.


Thomas E. Luebke, FAIA