There is broad opposition to the 250-foot Trump arch proposed near the National Mall, a structure that would loom over a historic corridor already lined with monuments.
This week, the administration’s own park agency raised objections. The National Park Service issued findings identifying 37 historic properties it says would suffer adverse effects from building the arch at Memorial Circle, a traffic roundabout just below Arlington National Cemetery.
“The significance of these properties derives not only from their individual architectural or commemorative importance, but also from their spatial, visual, symbolic, and ceremonial interrelationships,” the report states.
The National Park Service findings were released under Section 106 of the National Historic Preservation Act, a process that requires federal agencies to assess potential harm to historic properties and pursue ways to avoid or reduce it.
The review concludes that an arch at Memorial Circle would disrupt dozens of historic sites, notably the axial relationship between the Lincoln Memorial and Arlington House, the former home of Confederate Gen. Robert E. Lee.
“The bridge alignment and associated ceremonial landscape were intended to physically and symbolically unite North and South through a coordinated monumental composition extending across the Potomac River,” the document says.
The proposed site sits between those landmarks. Opponents argue it would intrude on that vista and the solemn setting adjacent to the cemetery.
A group of Vietnam War veterans has already filed suit to block construction, calling the project a visual affront that also requires congressional approval, which the president disputes and has not sought.
The White House maintains Memorial Circle is the right location. In an email, it called the arch a “fitting addition to the monumental axis between the Lincoln Memorial and Arlington House” and has repeatedly said it would “enhance the visitor experience at Arlington National Cemetery.”
That stance frustrates Greg Werkheiser of Cultural Heritage Partners, whose firm is pursuing several lawsuits related to other federal construction projects in Washington.
“It’s as if the president is saying: ‘Only if I jam my arch between Arlington Cemetery and the Lincoln Memorial and make it tower over everything else in the city will it be noticed,'” Werkheiser said.
Preservation advocates say Washington has locations where a monument of this size would affect far fewer historic assets.
“I think people are opposed to the absurdity of locating an arch this size and of this design in the middle of what is almost a civil sacred landscape,” Werkheiser said, adding that a different site might even draw support from current critics.
The National Park Service and the Department of the Interior did not respond to questions about whether alternate sites were considered. The Interior Department, however, played down concerns about adverse effects.
“The Arch will offer stunning views of Washington, D.C. from its observation deck, and the Arch itself will be visible from other historic properties, adding a monumental structure to the viewshed in a location that is currently a barren piece of grass,” a department spokesperson said in an email.
Critics counter that discussion of other locations has been scant, calling the review both rushed and poorly sequenced.
The Section 106 review began in June, after the project received final design approval from the first of two federal arts commissions evaluating it. That timing is unusual, said Ed Stierli, vice president of government affairs at the National Parks Conservation Association.
“We’re talking … not a whole lot of transparency, not even a meeting of the consulting parties has genuinely taken place,” Stierli said. “And unfortunately, as this continues, it feels like more of a box-checking than an actual, legitimate process.”
Trump arch controversy over location
Location, location, location
Typically, planning for new memorials starts with siting.
“Even looking at some of the more recent memorials — like the Women’s Suffrage National Monument that’s still in the planning process — they weigh the pros and cons,” Stierli said. “And they have to evaluate the alternatives, as well as what the impact is for visitors, before any of these are sited.”
He said any proposal for Memorial Circle warrants heightened scrutiny because of the area’s symbolism.
“Anything that would be built there would be controversial,” Stierli said. “But I think what makes this so controversial is the pure scale … We’re talking about one of the largest monuments to ever be built in Washington, D.C.”
At 250 feet, the arch would stand at more than twice the height of the nearby Lincoln Memorial. The National Park Service says its adverse effects would extend across a wide swath of the capital, including the National Mall, the U.S. Capitol, and the Washington Monument and its grounds.
“They skipped over real consideration of alternatives and just went to what arguably is the most concentrated collection of important historic sites and landscapes and settings in the country,” Werkheiser said.
One official who proposed an alternate site is David Maloney, Washington’s state historic preservation officer.
In a June letter to the National Park Service, Maloney suggested placing the arch in a newly created traffic oval near the Frederick Douglass Bridge over the Anacostia River in Southeast.
The neighborhoods east of the river are predominantly Black, with rich cultural history but higher poverty rates than the rest of the city.
Maloney wrote that an arch there, between Nationals Park and Audi Field, could “create an energizing focal point for a still-emerging neighborhood, suitable for a celebratory crowd.” He added that the site aligns with the Capitol and would be “more in scale” with the 288-foot Capitol dome.
“And importantly, it would enhance … the city’s monumental landscape rather than detracting from it,” he wrote. He did not grant an interview, noting his intent was to highlight avoidance of adverse effects as part of Section 106, not to endorse a specific alternative.
Maloney’s idea was briefly noted at the July meeting of the National Capital Planning Commission, the second federal panel reviewing the proposal.
“I’ve been intrigued and interested in this idea about bringing something that might strengthen Anacostia River East by bringing it to an area that would [have] an impact on our community that could be positive, maybe,” said Arrington Dixon, a planning commissioner who grew up nearby.
But commissioners did not delve into siting in depth. After two hours of public criticism and many unanswered questions, they advanced the proposal to the next review stage.
The commission meets again in early September. Its Trump-appointed chair has said final approval could come then, though the body’s rules require the Section 106 process to be complete first.
The National Park Service gave consulting parties until Thursday to respond to its latest findings.
In letters shared publicly, two organizations registered strong opposition to the project’s location and to what they described as a deficient review.
Charles Birnbaum, founding president and CEO of The Cultural Landscape Foundation, called the process “horrifically flawed from the outset,” saying the project’s specifics and site were set by the administration without a design competition or early consultations.
Rebecca Miller, executive director of the D.C. Preservation League, was blunter: “Let’s stop calling this a proper Section 106 process.”
“There is nothing normal about how this consultation is taking place – no avoidance, no minimization, no mitigation – just adverse impacts on the whole of our federal city,” she wrote.
Weakening the review process
For now, Section 106 remains one of the few remaining procedural hurdles for the Trump arch. The administration is moving to narrow it.
In late July, the Advisory Council on Historic Preservation, whose membership is largely aligned with the president, voted to revise Section 106 regulations to ease federal construction on or near historic properties nationwide.
The council says current rules create confusion and delays. Its proposed changes would limit what qualifies as historic, narrow definitions of adverse effects, and reduce public input. Those revisions would affect the arch among other projects.
“Even if they did consult [the public], they wouldn’t have to consider the obvious harm to the setting of putting an arch that’s this tall literally jammed in the middle of the sight lines between Arlington Cemetery and the Lincoln Memorial,” Werkheiser said.
The draft rule is moving through federal rulemaking, including a 30-day public comment period. Werkheiser said court challenges are likely later.
Congress could theoretically halt the monument. A group of House Democrats introduced a bill to do so, but with Republicans in the majority, passage appears unlikely.
Debates around public monuments and contested cultural landscapes have also surfaced in other recent cases, including calls to reinstate SAIC professor Savneet Talwar, highlighting how cultural institutions navigate conflict over public memory and space.