Court filings show the administration has obtained CFA approval, requested a Federal Aviation Administration review, conducted site investigations and prepared the proposal for NCPC consideration this week while litigation challenging the project advances toward summary judgment.

The structure would occupy Memorial Circle at the western end of Arlington Memorial Bridge; the administration has described the project as part of planned events commemorating the nation's 250th anniversary.

Current designs call for a monumental arch featuring a large central span, observation areas and visitor facilities. Revised plans reviewed by the Commission of Fine Arts depict a structure rising roughly 250 ft above Memorial Circle.

The latest iteration has been developed by architect Nicolas Leo Charbonneau of Harrison Design. ENR could not independently confirm a project cost estimate, financing plan or if a contractor has been selected. Trump previously described the project as privately funded, though the administration has not publicly released a final financing plan.

Design materials submitted during the federal review process show the structure positioned directly on the ceremonial approach between Arlington National Cemetery and the National Mall. 

Plaintiffs challenging the project argue it would interrupt historic sight lines between Arlington House and the Lincoln Memorial that were intentionally preserved as a symbol of national reunification after the Civil War.

At its May 21 meeting, the Commission of Fine Arts approved revised concept plans for the arch despite significant public opposition. According to court filings submitted by project opponents, approximately 1,600 public comments were submitted to the commission across two review periods, with nearly all opposing the proposal.

During the CFA meeting, Chairman Rodney Mims Cook Jr. defended the proposal, saying, "Washington is not a static city. It must grow to allow the next 250 years of Americans to celebrate their accomplishments."

At the same meeting, Rebecca Miller, executive director of the DC Preservation League, criticized the scope of the review, telling commissioners, "This is supposed to be concept approval, and they've moved to full."

Plaintiffs moved for summary judgment May 27, asking Judge Tanya Chutkan to rule that Congress never authorized the project and that construction cannot proceed without compliance with the Commemorative Works Act and other federal review statutes.

They contend Memorial Circle falls within "Area I" under the Commemorative Works Act, where Congress must approve the placement of commemorative works. The filing came while the administration's motion to dismiss remains pending before the court.

The administration has taken a different position.

In its motion to dismiss, the Justice Department argues the lawsuit is premature because the National Park Service has not issued final authorization, and construction cannot begin until the agency completes applicable reviews and issues a final decision.

Government attorneys have also argued authority for the project stems from a 1925 law associated with Arlington Memorial Bridge and Columbia Island improvements. Plaintiffs counter that the bridge project was completed in the 1930s, the original commission was dissolved and no congressional authorization exists for the current arch proposal.

The project's next milestone comes June 4, when the National Capital Planning Commission is scheduled to consider the proposal as a formal action item.

ENR requested comment from the Justice Department and National Capital Planning Commission staff but did not receive an immediate response.

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