The Park Service establishes that the arch will interrupt designed views, spatial relationships and illumination with effects extending to National Mall resources and more distant sites, including the Washington Monument, Pentagon, U.S. Capitol and National Cathedral.

Despite these concerns, the agency says it will focus on minimizing and mitigating effects while retaining the arch’s proposed location and design.

The proposed monument “is not interchangeable with another site,” the report says. The Park Service ties the location to a 1924 Arlington Memorial Bridge Commission plan that called for monumental vertical elements at Columbia Island and Memorial Circle.

On scale, the agency rejected shorter arch designs, saying those alternatives would more completely obstruct the view between the Lincoln Memorial and Arlington National Cemetery, while the 250-ft design would frame part of that sightline through its central opening.

The report acknowledges that Memorial Circle’s historic significance makes the site particularly sensitive to the project. But the agency asserts that “the same characteristics” that create preservation concerns also make the location historically appropriate.

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Mitigation and remediation measures include lighting controls, vibration and noise limits, archaeological investigations and landscape restoration and coordination of disruptive construction during funerals and other ceremonies at the cemetery.

Charles Birnbaum, founding president and CEO of The Cultural Landscape Foundation and a consulting party in the Section 106 review, disputed that mitigation offers a meaningful resolution once relocation and scale reduction are off the table. “This is a Hobson’s Choice—which is take it or leave it,” he said. “The idea of mitigation or minimization is a hollow performative gesture.”

Of 31 National Historic Landmarks within the area, the Park Service found six would experience adverse effects and 25 would not. Federal law requires agencies to minimize harm to affected landmarks to the maximum extent possible.

The Park Service proposes using LiDAR scanning, photogrammetry and 3D modeling to create a permanent record of the corridor’s spatial relationships and key sightlines before construction alters existing conditions.

The agency also plans a subsurface archaeological investigation. Memorial Circle was built atop about 10 to 14 ft of 20th-century fill covering a buried landscape that may contain intact precolonial or historic resources.

Excavation would remove about 1,400 truckloads of soil and require roughly 400 truckloads of engineered fill. The south side of Memorial Circle would remain closed for most of construction, and westbound traffic from Arlington Memorial Bridge would be reduced to two lanes.

The report calls for vibration monitoring near the bridge and other historic structures, along with noise and traffic controls and coordination of disruptive work around cemetery ceremonies. Those measures could constrain a baseline construction schedule currently calling for 20 hours of work per day, year-round.

The initial June 5-15 review drew 100,936 comments, followed by another 6,254 after the public comment period reopened July 10-30. Consulting parties subsequently pressed the Park Service to broaden its viewshed analysis, examine additional historic resources and consider alternative locations.

The consultation is unfolding as the Advisory Council on Historic Preservation considers a major rewrite of regulations governing Section 106, which ENR reported earlier in August. A draft revision would narrow the Area of Potential Effects to direct material alterations, potentially excluding visual and spatial changes underlying many of the arch’s adverse-effect findings.

Questions also remain over congressional authorization. Rep. Don Beyer of Virginia, whose district includes the cemetary, said in August that the federal analysis reinforced his concerns about effects on major historic sites. He has introduced legislation that would prohibit a triumphal arch in Lady Bird Johnson Park, designated a federally protected area under the Park Service in 1968 in honor of the former First Lady, and require express congressional authorization for any such agency monument taller than 50 ft in the National Capital Region.

For now, the Park Service says the arch review will focus on measures that can “reduce, manage, document, or compensate for harm” while retaining the proposed location and design.