Submitted to the National Capital Planning Commission — June 2, 2026
John Ayers, Washington, DC
The Comprehensive Plan for the National Capital: Federal Elements, January 2026 (the "Comprehensive Plan" or the "Plan") emphasizes, in its own words, "fundamental concepts of beauty and order," not as a judgment about whether individual structures are attractive, but as a standard for the composition of the city as a whole: its visual hierarchy, its protected sight lines, and the spatial relationships among its civic elements that make Washington legible as a national capital. The Lincoln Memorial, Arlington Memorial Bridge, Memorial Circle, Memorial Avenue, Arlington National Cemetery, and Arlington House are not isolated landmarks that happen to align. They form one ceremonial sequence, held together in a single sight line, conceived by the McMillan Commission as what the Comprehensive Plan calls "a complete work of civic art." The importance of that sequence derives not from any single structure but from the spatial relationships among its elements — relationships NCPC's own Comprehensive Plan is charged with protecting.
The planning question this proposal poses is whether inserting a 250-foot triumphal arch into the center of that sequence — at the western terminus of the Mall's primary ceremonial axis, where the Comprehensive Plan calls for particular vigilance against visual incursion — preserves the composition or destroys it. The applicants' own submission answers that question. Their "View from Lincoln Memorial — After" (Sheet 24) shows the arch rising to dominate the full axial terminus of Arlington Memorial Bridge, displacing the Lincoln Memorial from its position as the western anchor of the Mall axis and the gateway to the Arlington ceremonial sequence beyond. The Washington Monument views, the Arlington House views, and every approach across the Potomac tell the same story. The applicants have documented, in their own materials, that the proposed arch is a visual incursion into the Primary East-West Vista — a formally designated Preeminent Viewshed whose contributing elements are listed in the National Register of Historic Places.
The Comprehensive Plan contains at least twelve numbered policies that strongly support if not directly call for rejection of this proposal. They protect the visual hierarchy of national symbols, the openness of axial termini, the settings of National Historic Landmarks, the scale of memorial elements relative to their surroundings, and the integrity of designated view corridors. The proposal conflicts with every one of them. It also lacks the independent review that would normally give prior approval by the Commission of Fine Arts ("CFA") its evidentiary weight. The CFA that advanced this concept was reconstituted in its entirety by the project's sponsor before the vote.
Skip to Conclusion ↓The Comprehensive Plan does not exist to help decision-makers find places to put monuments. It exists to help determine when a monument does not belong. This one does not.
The members of the National Capital Planning Commission, stewards of our capital city, are not being asked whether the proposed triumphal arch is impressive, expensive, classical, or presidential. They are being asked whether the proposal is consistent with the Commission's own Comprehensive Plan for the National Capital — the document NCPC has itself described as "the decision-making framework for Commission actions on plans, proposals, and policies submitted for its review."
That distinction matters.
Reasonable people can disagree about whether a monumental arch is attractive. The question before the Commission is different: does the proposal advance or undermine the planning principles the Commission has adopted to guide development within the Monumental Core? Those principles are not ambiguous. They are codified, numbered, and applied by NCPC staff in every project review.
The Comprehensive Plan states that its Federal Elements — along with the District Elements, federal and District agencies' systems plans, individual installation master plans and subarea plans, development controls, and design guidelines — "constitute the road map for NCPC's land use planning and development decision-making processes in the [National Capital Region]." (Comprehensive Plan Introduction, p. 11).
The Federal Elements contain the directly applicable policies for evaluating this proposal. The Plan defines Washington's symbolic identity as expressed, in part, through "a visual order of importance (hierarchy) that emphasizes symbols and structures" visible "from both composite skyline views and linear views along particular streets." (Urban Design Element, p. 17) It further states that "from closer vantage points, the low scale of buildings and spacious settings around other landmarks, such as the White House, Lincoln Memorial, Jefferson Memorial, and Smithsonian museums, creates a fitting character for a capital city set in natural beauty" (Urban Design Element, p. 19) and that "the urban design principles that give preeminence to its most important national symbols, and particular viewsheds to them, has generally been retained." (Urban Design Element, p. 19). The General Principles for Viewshed Maintenance in the Technical Addendum state that NCPC supports the principle of creating "a wide visual frame and natural backdrop ('breathing room') around the U.S. Capitol, White House, Washington Monument, and other major symbolic elements within the monumental core." (Technical Addendum to Urban Design Element, p. 10.) The Lincoln Memorial is among those major symbolic elements. The proposed arch eliminates its breathing room on the western approach entirely and directly inverts the visual hierarchy the Plan is charged with protecting.
The Urban Design Element's "Significant Structures + Civic Art" section includes a Policy Guide box for proposals involving significant structures, civic art, and the symbolic skyline. It directs readers to policies B.1, B.3, B.4, and B.5 as the applicable framework, stating: "For policies relating to significant structures, civic art, and the symbolic skyline, please see:" B.1 Capital City Character: General Urban Design Policies; B.3 The L'Enfant City and the Public Realm; B.4 The Monumental Core; and B.5 Preeminent Viewsheds and View Corridors. (Urban Design Element, p. 11). The Lincoln Memorial and Arlington House are both specifically enumerated in that section as Gateway structures, and Memorial Circle sits on the preeminent view corridor connecting them shown on the accompanying map. The Plan has already identified this site, these structures, and these policies as the relevant analytical framework. The applicants' proposal falls squarely within it.
Policy UD.B.1.3 calls on the Commission to "[p]reserve Washington's picturesque, horizontal character, and reinforce the Height Act." (Urban Design Element, p. 22.) The proposed arch is 250 feet tall. Within the District of Columbia, the Height Act would prohibit it. The applicants have sited the structure in Arlington County, on the Virginia side of Memorial Circle, where the Height Act does not apply. The Comprehensive Plan directly addresses this jurisdictional gap. The Urban Design Element acknowledges that "[b]ecause the Height Act does not extend beyond the District, a conceptual understanding of building height in Arlington with respect to the primary vistas is defined through a resolution of the Arlington Board" — a resolution it characterizes as non-binding. (Urban Design Element, p. 13.) The Plan then states: "[i]t is critical to engage local jurisdictions to address mutual interests in the overall urban design quality of the nation's capital and region, and to prepare strategies that holistically consider the quality of the primary vistas." (Urban Design Element, p. 13.) The 2013 Height Master Plan, cited in the Comprehensive Plan, reaffirmed the Height Act's principles as continuing to serve national interests. (Technical Addendum to the Urban Design Element, p. 4.) NCPC is the one body whose jurisdiction and mandate bridge the DC-Virginia boundary. The Commission's review of this proposal is precisely the mechanism the Plan contemplates for protecting primary vistas from Virginia-side development the Height Act cannot reach. Approving a 250-foot structure that would be illegal on the DC side of the circle would render that mandate meaningless.
Policy UD.B.1.4 (Capital City Character) calls on the Commission to "[v]isually reinforce the preeminence of the U.S. Capitol, White House, Washington Monument, and other major nationally significant resources by protecting the visual frame around them" and to "[c]arefully examine the use of vertical elements within the setting of major national resources." (Urban Design Element, p. 22.) The Lincoln Memorial is among those major nationally significant resources. A 250-foot arch placed directly on its approach axis — interposing a new dominant vertical element between the Lincoln Memorial and every vantage point across the Potomac — is precisely the kind of intrusion this policy is designed to prevent.
Policy UD.B.3.1(2) (The L'Enfant City and the Public Realm) is the most directly applicable provision in the element. It calls on the federal government to "[p]rotect the visual openness and functional qualities of L'Enfant public spaces by preventing visual incursions into the rights-of-way wherever possible," and states explicitly that this protection "is particularly important at intersections and termini of radial and axial avenues." (Urban Design Element, p. 27.) Memorial Circle is precisely such a terminus. The proposed arch would introduce a 250-foot structure at the location the Comprehensive Plan identifies as requiring the greatest vigilance against visual incursion.
Policy UD.B.4.1 (The Monumental Core) calls for planning in and around the Monumental Core to "consider the relationship between the design of new development and significant adjacencies, such as major public spaces, urban and historic fabric, and along the preeminent viewsheds described within this element." It further calls for new development to "not infringe on the civic qualities and integrity of the National Mall and the surrounding monumental core" and to "respect existing lines of sight from the National Mall and existing relationships, including height and mass within that line of sight." (Urban Design Element, p. 29.) The 1902 McMillan Commission drew the Arlington Memorial Bridge axis directly between the then-proposed Lincoln Memorial and Arlington House as a deliberate act of civic design. The bridge itself is identified in the Urban Design Element as a "Capital Gateway" that "provides a formal processional entry into Washington, DC" — an entry point where "elements of the monumental core are visible." (Urban Design Element, p. 8.) Inserting a 250-foot arch at the midpoint of that processional does not respect the existing relationships. It displaces them.
Policy UD.B.5.1 (Preeminent Viewsheds and View Corridors) calls on the federal government to "[p]rotect and enhance panoramic and street-level linear views of the U.S. Capitol, White House, Washington Monument, and other major skyline elements" and to "[r]emove visual intrusions to increase visibility." (Urban Design Element, p. 33.) The Technical Addendum defines a visual incursion as a built element that, among other criteria, "detracts from the preeminence of a major national resource along a view corridor," "visually severs major landscape elements," or "detracts from the character of historic, cultural, or other open space areas." (Technical Addendum to Urban Design Element, p. 11.) The proposed arch satisfies all three criteria simultaneously — as confirmed by the before-and-after visualizations submitted by the applicants across eleven vantage points. The "View from Lincoln Memorial — After" (Sheet 24 of the applicants' submission) shows the arch rising to dominate the full axial terminus of Arlington Memorial Bridge, displacing the Lincoln Memorial from its position as the western anchor of the Mall axis and the gateway to the Arlington ceremonial sequence beyond.
The Technical Addendum's inventory of Preeminent Viewsheds makes this concrete. The "Primary East-West Vista" — the east-west axis running from the U.S. Capitol along the National Mall to the Lincoln Memorial and westward to the horizon — is a formally designated Preeminent Viewshed whose contributing elements are listed in the National Register of Historic Places as part of the L'Enfant Plan of the City of Washington nomination. The Addendum documents three specific observation points within this viewshed: View 1 from the west steps of the U.S. Capitol; View 2 from the west facade of the Washington Monument; and View 3 from the west portico of the Lincoln Memorial. (Technical Addendum to Urban Design Element, p. 19). The Addendum's own description of existing conditions states that the Arlington backdrop is currently perceived as "fairly uniform, without individual vertical elements interrupting the skyline and competing with the visual frame around the Lincoln Memorial and Washington Monument" — and identifies this condition as what must be maintained. The proposed arch is precisely such an individual vertical element at precisely these observation points. The applicants' own submission documents the interference: their Washington Monument before-and-after visualizations correspond to View 2, and Sheet 24 corresponds to View 3. Both show the arch as the dominant object in this formally designated, NRHP-listed Preeminent Viewshed. Arlington National Cemetery is separately identified in the Technical Addendum's inventory of publicly accessible federal lands with documented views as offering a "view to the monumental core; general panoramic view of the skyline." (Technical Addendum to Urban Design Element, p. 35.) The proposed arch would be sited directly within that documented view corridor, between Arlington National Cemetery and the monumental core it looks toward.
The Historic Preservation Element adds further authority. Policy HP.A.2 calls on the federal government to "[p]rotect the reciprocal views along the rights-of-way established by L'Enfant streets, as well as to and from squares, circles, and reservations." (Historic Preservation Element, p. 5.) The visual relationship between the Lincoln Memorial and Arlington House — the reciprocal view across the Potomac that the McMillan Commission built the bridge axis to formalize — is exactly what this policy protects. Policy HP.D.3 independently calls on the federal government to "[p]rotect the settings, including viewsheds, greenspaces, and tree canopies, of historic properties, as integral parts of the property's historic character." (Historic Preservation Element, p. 9.) Three National Historic Landmarks are independently affected. Arlington Memorial Bridge's setting — the open ceremonial approach across the Potomac — is inseparable from its historic character. Arlington House's setting includes its designed eastward prospect toward the Lincoln Memorial and the capital beyond — the view from which Robert E. Lee made his fateful decision in 1861, and which remains a formally documented feature of the property's historic significance. Arlington National Cemetery's setting includes the ceremonial approach along Memorial Avenue and Memorial Circle, integral to the solemn character the cemetery has carried since 1864. The proposed arch would permanently intrude into all three settings. No Section 106 consultation record appears in the applicants' submission.
The Parks and Open Space Element adds five further directly applicable policies.
Policy POS.A.1 calls on the federal government to "[r]ehabilitate, protect, and, where feasible, enhance historic designed landscapes and civic streets, including squares, circles, and triangles associated with The Plan of the City of Washington." (Parks & Open Space Element, p. 13.) Memorial Circle is a designed civic circle associated with the McMillan Plan's ceremonial approach to Arlington and falls within the category of historic designed landscapes this policy is charged with protecting.
Policy POS.A.2 calls on the federal government to "[p]rotect and maintain both the north-south and east-west cross-axes of the National Mall and its historic landscape as a complete work of civic art." (Parks & Open Space Element, p. 13.) The east-west axis extends to the Lincoln Memorial and westward toward Arlington. The proposed arch intrudes into that axis at its most sensitive transitional point.
Policy POS.A.7 calls on the federal government to "[p]rotect or restore viewsheds that contribute to cultural landscapes and the aesthetic quality, historic significance, and visitor experience of the parks and open space system." (Parks & Open Space Element, p. 13.) The viewshed from Arlington National Cemetery to the monumental core, the eastward prospect from Arlington House toward the Lincoln Memorial, and the reciprocal view from the Lincoln Memorial across the Potomac each contribute directly to the cultural landscape, historic significance, and visitor experience of the most significant commemorative parks in the national system.
Policy POS.C.5 calls on the federal government to "[a]void the introduction of visual incursions into the rights-of-way or placement of physical elements that would detract from the views of national memorials, civic institutions, or landmarks." (Parks & Open Space Element, p. 29.) The Lincoln Memorial is a national memorial. The proposed arch is a physical element placed on its approach axis that the applicants' own submitted visualizations confirm detracts from its view. POS.C.5 does not permit a balancing test. It says "avoid."
Policy POS.C.6 states that "[m]emorial elements should complement and not compete with the scale of the surrounding landscape and built environment." (Parks & Open Space Element, p. 29.) The surrounding landscape at Memorial Circle is Arlington Memorial Bridge, its pylons at approximately 40 feet, and an open ceremonial approach deliberately maintained at human scale for over a century. A 250-foot arch with a gilded sculpture group does not complement that landscape. It overwhelms it.
The Comprehensive Plan's own design guidance for commemorative works states the governing principle plainly: "Memorial or landscape elements may be used to frame or define an edge condition of a view corridor to maintain the openness of vistas … but new commemorative works should not detract from an existing prominent viewshed." (Parks & Open Space Element, p. 28.) The Lincoln-to-Arlington viewshed is among the most prominent in the nation's capital. The applicants' own before-and-after visualizations demonstrate that the proposed arch detracts from it. The Comprehensive Plan has already answered the question this proposal poses.
The Comprehensive Plan's Introduction Chapter describes the L'Enfant and McMillan Plans as "the foundation of modern Washington" (Comprehensive Plan Introduction, p. 6) and lists under Principle 1 the need to "preserve historic properties and important L'Enfant and McMillan Plan design features." (Comprehensive Plan Introduction, p. 8.) Policy POS.A.2 encodes this directly, calling on the Commission to "[p]rotect and maintain both the north-south and east-west cross-axes of the National Mall and its historic landscape as a complete work of civic art." (Parks & Open Space Element, p. 13.) That phrase — "complete work of civic art" — is the McMillan Commission's own conceptual framework, now codified as NCPC policy. It means the axis is not a collection of individual monuments that can be evaluated in isolation. It is a composition, and any intervention must be evaluated against what it does to the composition as a whole. An interesting precedent for how that principle applies to Memorial Circle is the McMillan Commission's own treatment of the Baltimore and Potomac Railroad on the Mall. The Commission did not remove the railroad because it was unattractive. It removed it because it interrupted the civic composition — because the Mall's designed openness was not emptiness but the medium through which the relationships among the Capitol, the Monument, and the Lincoln Memorial were made legible. That principle — that compositional openness is itself a planning value, not merely an aesthetic preference — is the foundation on which every subsequent protection of the Mall axis and its approaches has rested. Memorial Circle's openness serves exactly that function on the Arlington axis. The existing pylons, at approximately 40 feet, represent the considered answer to what scale of structure belongs at the circle: large enough to mark the threshold, small enough to preserve the view through it. Policy UD.B.3.1(2) encodes this principle directly, calling for protection of visual openness at axial termini. The McMillan Commission established why.
Memorial Circle is open not because no one thought to fill it. It is open because successive generations of planners understood its role as the visual fulcrum of the Lincoln-to-Arlington sequence. Stand at the Lincoln Memorial and look west: the bridge leads the eye across the river and through the circle, and if the circle is open, the eye continues up Memorial Avenue to Arlington House on the ridge. The sequence reads as a single continuous gesture — Lincoln, bridge, circle, avenue, Arlington House — each element handing off to the next. The circle is where the bridge ends and the avenue begins, and its openness is what makes that handoff legible. Arlington Memorial Bridge was designed in 1925 as an explicit symbol of national reconciliation: the Union president and the former Confederate general's home connected by a single axis. Memorial Circle is the point at which that reconciliation gesture makes contact with Virginia soil. Policy HP.A.2's protection of "reciprocal views … to and from squares, circles, and reservations" applies with particular force here: the reciprocal view between Lincoln and Arlington House is the designed meaning of the site, and the circle is where it pivots.
The form the applicants have chosen compounds the siting problem. A triumphal arch — the applicants' own title block uses that phrase — placing that specific form at the precise point where the Lincoln-Arlington reconciliation axis makes its Virginia landfall is not a neutral design decision. It is a direct typological contradiction of the commemorative purpose the site already carries. The Comprehensive Plan's commemorative design guidance calls for new works to "not detract from an existing prominent viewshed." (Parks & Open Space Element, p. 28.) The site has a commemorative identity. The proposed form conflicts with it. That is a planning finding, not an aesthetic judgment, and it falls squarely within the Commission's mandate to evaluate whether a proposed commemorative work is appropriately sited.
The Lincoln Memorial, Arlington Memorial Bridge, Memorial Circle, Memorial Avenue, Arlington National Cemetery, and Arlington House are not isolated landmarks. Together they form one of the most significant ceremonial and commemorative sequences in the United States. The importance of that sequence derives not from any single structure but from the spatial relationships among them — relationships the McMillan Commission conceived, the Congress funded over decades, and NCPC's own Comprehensive Plan is charged with protecting.
The Comprehensive Plan does not exist to help decision-makers find places to put monuments. It exists to help determine when a monument does not belong.
That determination is made easier here by a fact that the applicants' own submission makes plain: the Harrison Design package contains no written policy analysis, no commemorative purpose statement, and no explanation of how the proposal is consistent with the Comprehensive Plan. Significant interior program areas are labeled "PROGRAM SPACE TBD." The Commission is being asked to approve a permanent intervention in one of the nation's most protected civic landscapes on the basis of drawings alone, for a structure whose purpose has not been defined.
Viewed through that lens, the planning question is straightforward: does inserting a 250-foot triumphal arch into the center of this ceremonial sequence — at the western terminus of the Mall's primary ceremonial axis, where the Comprehensive Plan calls for particular vigilance against visual incursion — preserve the composition or interrupt it? Policies UD.B.1.3, UD.B.1.4, UD.B.3.1(2), UD.B.4.1, UD.B.5.1, HP.A.2, HP.D.3, POS.A.1, POS.A.2, POS.A.7, POS.C.5, and POS.C.6, read together with the Plan's General Principles for Viewshed Maintenance and its own commemorative design guidance, provide the answer.
The Historic Preservation Element states that "the Commission recognizes that sustained citizen engagement in the public process is fundamental to the broad acceptance of historic preservation decisions." (Historic Preservation Element, p. 3.) The public comment record before the Commission of Fine Arts on this proposal reflects near-unanimous opposition from the citizens of Washington and the surrounding region. That record is part of the administrative history of this proposal and the Commission should weigh it accordingly — not as a popularity contest, but as evidence that the broad acceptance the Plan identifies as fundamental to legitimate historic preservation decisions has not been achieved.
Principle 3 of the Comprehensive Plan calls on NCPC to coordinate federal plans with local jurisdictions and community groups, and to provide for public participation in the review of federal policies, plans, and programs. (Comprehensive Plan Introduction, p. 10.) The Harrison Design submission contains no evidence of coordination with the District of Columbia government, Arlington County, or the community organizations most directly affected by this proposal. A permanent 250-foot structure at the ceremonial gateway between the District and Virginia — a structure that would alter the character of the National Mall's primary western vista, the approach to Arlington National Cemetery, and the setting of three National Historic Landmarks — is precisely the kind of federal action the coordination obligation was designed to govern.
The Comprehensive Plan is explicit that this coordination must continue "in order to manage the capital's growth and development." It further recognizes that "factors such as the establishment of Home Rule in Washington … and greater citizen involvement have contributed to increased coordination among federal and local governments." (Historic Preservation Element, p. 3.) Advancing this proposal without that coordination — over the demonstrated opposition of the affected public — would reverse the direction the Plan calls for.
The Comprehensive Plan states that Washington "must reflect the highest standards of architecture, urban design, and planning" and that the Federal Elements "emphasize fundamental concepts of beauty and order." (Comprehensive Plan Introduction, p. 8.) The Historic Preservation Element states that "federal agencies working in concert with local officials and interested citizens must be careful stewards of the historic properties under their care or affected by their decisions" — and identifies NCPC as "one of several public forums where planning and historic preservation consultation can occur." (Historic Preservation Element, p. 6.) That stewardship obligation is not discharged by a prior review process that lacked institutional independence.
The Commission of Fine Arts, which voted unanimously to advance this concept, was reconstituted in its entirety by the project's sponsor between October 2025 and the date of that vote. All six sitting members were dismissed mid-term and replaced with new presidential appointees before the arch proposal came forward. The CFA's advancement of the concept therefore cannot be treated as independent design validation in the ordinary sense. The institutional independence that gives CFA advancement its evidentiary weight in NCPC's review process was absent.
This is not an argument about the aesthetic judgments of individual CFA members. It is an observation about process: NCPC's review is the first genuinely independent evaluation of whether this proposal reflects the beauty and order the Plan calls for and whether it meets the stewardship standard the Plan demands. The Commission should weigh it accordingly.
Washington's monumental core is not valuable because every available space contains a monument. It is valuable because generations of planners understood that open vistas, ceremonial approaches, and carefully composed civic relationships are themselves part of the monument.
The Comprehensive Plan emphasizes fundamental concepts of beauty and order — not as a judgment about any single structure, but as a standard for the composition of the city as a whole. The Commission should evaluate this proposal not as an isolated object but as an intervention in one of the nation's most important civic landscapes. Measured against the Commission's own adopted policies — twelve of which strongly support if not directly call for its rejection — the proposal is inconsistent with the principles of viewshed protection, historic continuity, ceremonial integrity, commemorative scale, and commemorative purpose that the Comprehensive Plan is designed to protect. It also lacks the coordination with local government and citizens the Plan calls for.
The question is not whether the arch is grand.
The question is whether it belongs where it is proposed.
It does not.