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Zoo Allowing Collapse of 200-Year Mansion, Desecration of Old Burial Ground and Rock Creek Pollution; Laws May Be Broken

By W. Matthew Lynn & Paul K Williams*


[This article originally appeared in the May 1997 issue]

Neighborhood discontent with the Smithsonian’s National Zoological Park’s plans for a mulching facility has shed light on an array of possible federal law violations, The InTowner recently learned.

The Zoo may not have given enough consideration to various historical and ecological regulations when developing a scope of work for construction of the new mulching facility for the park. This neglect has drawn attention to a host of other possible violations.

The Zoo’s troubles began when a local activist, Eddie Becker, informed citizens living around Walter Pierce Park of the Zoo’s construction plans for the mulching facility. Becker and many other citizens were already concerned about the Zoo’s neglect of the dumpsters it has placed near Walter Pierce Park.

As concern mounted, Becker organized a meeting with Zoo officials. As the meeting progressed, it became clear to The InTowner that the Zoo may be violating various laws. The Zoo officials at the meeting admitted that they were not sure of exactly which laws they needed to comply with in dealing with their usage of this property. Later Dr. Cynthia Fields, Chair of the Historic Preservation and Architectural History Division of the Smithsonian, told The InTowner that “we attempt to observe every rule, but it is not clear if federal legislation applies to the Zoo”.

The property in question, accessible to the public via the rear gate to the Zoo off Adams Mill Road and Walter Pierce Park, or along the bicycle path next to Rock Creek, has intense historical significance. Apart from being a Quaker and African American cemetery, the grounds host the circa 1805 Holt House, which once may have been frequented by John Quincy Adams, Dolly Madison, and aviation pioneer Samuel P. Langley. The house also represents one of only two examples of its architectural style remaining in the District. The area is also home to a rare species of a shrimp-like amphipod, and a section of Rock Creek on Zoo property is the only known habitat for the species. Ironically, it was Smithsonian researchers who first discovered the species in the late 1920’s.

When The InTowner asked Fields if she knew of any plans to provide an archaeological survey of the Quaker and African American burial grounds before the construction of the $35,000 mulching facility, she replied “we are not convinced there are two cemeteries, and are not even sure of the boundaries of the cemetery”. She also indicated that there were no plans to restore or even stabilize the historic (and vacant) Holt House, although it appeared as a prominent justification each and every year the Zoo has appealed for federal funds to put toward general maintenance costs in the more public areas of the Zoo.

A federal agency that knowingly allows a historic resource to be demolished by neglect is in clear violation of the National Historic Preservation Act (NHPA) of 1966. The Zoo is required by law to consult with both the DC Historic Preservation Division and the President’s Advisory Council on Historic Preservation before any actions are taken that may affect historic resources. The InTowner has learned that neither agency has been contacted by the Zoo for consultation regarding the Zoo’s current plans, nor have the agencies been contacted for past changes in use.

This would include previous Zoo actions such as placing dumpsters and driving dump trucks on top of a National Register listed cemetery, allowing a listed house to deteriorate and remain unsecured, and excavation work on the flagstone walls of the historic Adams Mill Road, which the Zoo prefers to call the Blue Road. In fact, because the entire zoo property has been listed in the National Register since April 11, 1973, the Zoo must consult with the aforementioned agencies before any kind of action is taken, unless a memorandum of agreement is negotiated.

A federal agency is allowed to demolish a listed property, but it first must document that it has gone through a lengthy and proper procedure, as laid out in NHPA. The Zoo has not done this. Indeed, the Zoo seems to question whether it must follow any federal legislation usually connected to the use of federal funding. Dr. Fields told The InTowner, “We don’t know if federal legislation applies. The legal department has the final word”.

It is ironic that the Zoo’s presentation to the public of the mulching facility, made by the Zoo at the meeting requested by Becker, was in itself an admittance of violating the National Environmental Policy Act (NEPA), the Archaeological Resources Protection Act (ARPA), and the NHPA, all of which require agencies using federal funds to assess the potential impact of their action before it occurs.

NEPA requires an Environmental Assessment or Impact Statement analysis on several potential sites, including the impact to historic resources. NEPA also requires public participation before one site is selected. NHPA requires consultation with the aforementioned agencies before the potential impact. ARPA protects the disturbance of known archaeological sites, such as cemeteries, and carries severe fines and imprisonment to convicted offenders. Zoo officials first chose a site for the new facility and, when asked, presented their plans to the community in what appears to be a backward attempt at community involvement.

When describing the predetermined location for the mulching facility, Robin Vasa admitted to the public present at the April 23 meeting that “nobody really knows the boundaries of the cemetery, or whether it has been excavated. Documents provided to The InTowner by Becker indicate that the Zoo’s dumpsters appear to sit atop the site. (Eddie Becker: The dumpsters sit atop an area identified in Zoo documents as a part of the 1.7 acre “colored cemetery”. The site is next adjacent to the earliest European industries along Rock Creek including the grain mill, the quarry, sawmill, blacksmith shop, lumbered and farmed the land. There is also what Zoo documents describe as slave quarters in the basement of the Holt house, the house served, at different times, as the plantation house for the overseer and was used for almost 100 years by the Zoo to administer all its property.)

The alleged historic preservation violations may be the least of the Zoo’s worries. When interviewed by The InTowner, two professional naturalists, Virginia Crouch and Olin Allen, were surveying Rock Creek as part of a joint effort between the DC Natural Heritage Program and the National Capitol Area Conservation Date Center. Crouch and Allen were determining the location on Zoo property of the rare shrimp-like amphipod species.

When shown two large concession garbage dumpsters full of food waste and other garbage along the Blue Line Road, less than 20 feet from the water’s edge, Allen remarked, “they should have some sort of containment mechanism, especially before a deluge of rains that leach into the creek.” Crouch said the amphipod, just a few mm long, was not listed on the Endangered Species list because “its location on public property is supposed to be protection enough if the agency follows the current legislation.” She added that the species has a “high conservation priority.” (Becker: The Zoo has since moved the dumpsters that were along the bike path next to Rock Creek to an enclosed, gated area nearby.)

The deterioration of the Holt House by neglect also violates several provisions of the NHPA, including Sections 106 and 110. Merely disturbing the natural setting of the Holt House may be in violation of Section 106. Presently, the grounds are used as a staging area for construction projects, leaving the historic landscape cluttered with wood crates, scaffolding, gravel, and truck parking.

Currently, the Zoo has no funds for restoration or maintenance of the house. Zoo officials blame a lack of congressional funding, yet Zoo records indicate only one request for funds. The request dates back to 1985.

(Becker: The Zoo requested $400,000 for “design for health and research facility” but were turned down in the budgeting process in 1985, because the Zoo had already received that amount the year before for the identical line item.)

The Zoo Administration will not have another chance to request funds for the house until the 1998 budget proceedings, at which time the Zoo plans to request $100,000. The funds would be used to stabilize the structure of the house and to prevent further deterioration. The Zoo has made no plan to request funds for restoration or remodeling of the house.

(Becker: Michael Robinson Director of the Zoo, issued a correction on May 12, 1997. ” this information was incorrectly explained at the ANC [Advisory Neighborhood Commission] meeting. The 1998 request . . . does not include a request for Holt House restoration.” )

As for future plans, the Zoo Administration has provided only speculation about a use for the house. When asked if the Zoo has considered recently any plans for the house, Bob Hoage, Chief of the Office of Public Affairs, stated that the house “is not a priority that can be maintained”. However, Mr. Hoage did go on to describe possible uses for a restored Holt House. Possibilities include office space, a conference center, a place to quarter visiting scientists or researchers, and accommodation for visiting dignitaries from other zoos.

Robin Vasa, Assistant Director for Facilities Management and Construction, stated that just about every Zoo building is in need of renovation, and that it is hard for the Zoo to balance these necessary renovations with historical and cosmetic maintenance. However, at the April 23 community meeting, Ms. Vasa professed that “the Zoo has a soft spot in its heart for that building”. One has to wonder just how soft that spot could be, considering that no funding requests have been made since 1985.

But yet some hope does glimmer out of the recesses of this bureaucratic entanglement. Hoage responded later by saying that when facilities management completes its work orders on the various animal buildings around the zoo, there are now plans to blow out the house’s gutters and remove ivy. This is tentatively scheduled to happen sometime around late spring.

And on an even happier note, thanks to Eddie Becker and his concerned group of citizens, it now appears that the Zoo has at least temporarily abandoned its plan to build the mulching facility.

Becker and the group now have their attention turned to the Zoo’s use of a herbicide to kill Kudzu in an area adjacent to Walter Pierce Park. The group wants to ensure that the chemicals are not contaminating the community garden at the park. But that is another story.

* Matthew Lynn is a former editor at the Bureau of National Affairs, Inc.; Paul K. Williams, an historic preservation specialist, also authored this newspaper’s monthly “Scenes from the Past” until August of 2012.

Copyright © 1997 InTowner Publishing Corp. All rights reserved. Reproduction in whole or in part without permission is prohibited, except as provided by 17 U.S.C. §107 & 108 (“fair use”).