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135839690
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JGR/White House Sidewalk
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135839690
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JGR/White House Sidewalk
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Records of the Office of Counsel to the President (Reagan Administration)
John Roberts' Subject Files
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1986-12-31
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Ronald Reagan Presidential Library Digital Library Collections This is a PDF of a folder from our textual collections. Collection: Roberts, John G.: Files Folder Title: JGR/White House Sidewalk Box: 57 To see more digitized collections visit: https://reaganlibrary.gov/archives/digital-library To see all Ronald Reagan Presidential Library inventories visit: https://reaganlibrary.gov/document-collection Contact a reference archivist at: [email protected] Citation Guidelines: https://reaganlibrary.gov/citing National Archives Catalogue: https://catalog.archives.gov/ DATE: 4-28-80 The Washington Post PAGE: B-1 Sign Rules Overturned Federal officials argued that the restrictions on signs and belongings By Judge were designed to minimize possible security threats as well as to give tourists a clear view of the White U.S. Appeals, House and maintain access to the White House sidewalk for pedestri- Says White House ans. Groups that challenged the rules ar- Protests Pose Risk gued that the restrictions did not sig- anificantly improve presidential security By Stephen J. Lynton and appeared to have been drawn up Washington Post Staff Writer for political aims. They cited a Jan. 13, A federal judge has struck down a 1983, memo from former Interior Sec- series of regulations limiting the use retary James G. Watt objecting to de- of signs and other belongings by monstrations in front of the White demonstrators on the sidewalk in House. The protesters. backed by front of the White House. American Civil Liberties Union law- U.S. District Judge William B. yers, said the rules would impede law- Bryant held that the rules, imposed ful demonstrations. last year by the National Park Ser- In his ruling signed Thursday, vice, violated the First Amendment Bryant said: "No one who has lived rights of demonstrators to seek re- through the past two decades can dress of grievances. He termed the doubt the importance of protecting rules "oppressive," "unjustified," our presidents from those who would "overbroad and unreasonable." do them harm, and no reasonable The government immediately ap- person can dispute that some restric- pealed Bryant's ruling to the U.S. tions on freedom of expression may Court of Appeals. Yesterday evening, be tolerated in pursuit of this press- the appellate court issued a tempo- ing public interest." rary stay, permitting the controver- But the judge, who presided dur- sial regulations to remain in effect at ing a seven-day trial in December. least until next Wednesday. added that it "does not seem proper John Vanderstar, a lawyer repre- that peaceful demonstrators should centing the White House Vigil for be made to forgo their activities in the ERA Committee and several order to allay the fears of security other demonstrators, hailed Bryant's forces which are based on remote decision as a "very strong and impor- possibilities." tant First Amendment ruling." Although he upheld three provi- In asking the appeals court to sions, Bryant rejected nearly all the stay, or temporarily set aside, the rules, criticizing them one by one. effect of Bryant's ruling, government "The requirement that a demonstra- lawyers criticized the federal judge for maintain actual physical contact for showing a "casual approach to with a sign is oppressive, and has lit- the security of the president." They tle or nothing to do with security or contended that the rules are needed any other governmental interest. to prevent concealment of explosives The prohibition against holding a and use of signs as weapons against sign in a stationary position less police or as devices for scaling the than three feet from the ledge is of White House fence. similar character." The rules, which took effect on Sept. 2 after an initial series of legal skirmishes, restrict the size of signs used in demonstrations, prohibit The wooden signs and hollow metal sup- porting poles and bar demonstrators from leaving packages on the White House sidewalk. U.S. Department of Justice file United States Attorney District of Columbia United States Courthouse, Room 2800 Constitution Avenue and 3rd Street N.W. Washington, D.C. 20001 April 20, 1983 David Waller, Esquire Senior Associate Counsel to The President The White House Washington, D.C. 20500 Dear Dave: I thought you might like advance notice that we have coordinated new Park Service regulations for the White that should help clean up the area as well as improve security. A copy is enclosed. We've had several meetings with Jerry Parr of the Secret Service, Chief Herring of the Park Police, and Jack Fish of the Park Service, to work these out. We're providing copies to the American Civil Liberties Union on Friday, when the regulations should appear in the Federal Register. We don't know if they will file suit, but the ACLU has opposed these changes. Let me know if you'd like any further information. Sincerely, STANLEY S. HARRIS United States Attorney By: ROYCE Reyce C. LAMBERTH Chief, Civil Division Enclosure Billing Code: 4310-70 Department of the Interior National Park Service 36 CFR Part 50 National Capital Parks Regulations Demonstrations in the White House Area AGENCY: National Park Service, Interior. ACTION: Interim rule with request for comments. SUMMARY: This interim rule with requests for comments amends S 50.19 of Title 36 of the Code of Federal Regulations concerning demonstrations and special events in the National Capital Parks to prohibit signs or placards on the White House sidewalk except those that are carried by an individual. The interim rule also amends S 50.19 of Title 36 of the Code of Federal Regulations and S 50.7(h) of the same title concerning storage of materials in park areas to prohibit the placement or storage of parcels, containers, packages, bundles or other property on the sidewalks surrounding the White House. DATES: This interim rule is effective [insert date of publication] and will remain in effect until revoked, replaced or modified by a final rulemaking publication. Written comments, suggestions, or objections regarding this interim rule will be accepted until [insert date 30 days after date of publication]. ADDRESSES: Written comments regarding this interim rule should be sent to Manus J. Fish, Jr., Regional Director, National Capital Region, National Park Service, 1100 Ohio Drive, S.W., Washington, D.C. 20242. FOR FURTHER INFORMATION CONTACT: Sandra Alley, Associate Regional Director, Public Affairs, National Capital Region, National Park Service, 1100 Ohio Drive, S.W., Washington, D.C. 20242, telephone (202)426-6700; Richard G. Robbins, Assistant Solicitor, National Capital Parks, Office of the Solicitor, Department of the Interior, Washington, D.C. 20240, telephone (202)343-4338. 2 SUPPLEMENTARY INFORMATION: The following persons participated in the writing of this rule: Richard G. Robbins and Patricia S. Bangert, Office of the Solicitor, Department of the Interior. Background Recent events in the Memorial Core parks have increased security concerns for the White House and the President. On December 8, 1982, an individual backed a truck up to the Washington Monument and threatened to blow up the structure with 1,000 pounds of dynamite that he allegedly had stored in the truck. The incident, occurring a mere three blocks from the White House, highlighted the threat that could be potentially caused to the White House and the President by one determined individual. Since the incident, the National Park Service, along with other law enforcement agencies, have reviewed present regulations applicable to the White House area to determine if regulatory changes could aid in minimizing potential threats to the structure and its occupants. Two areas of concern became evident in that review - signs or placards stationed on the White House sidewalk and parcels, containers, packages, bundles and other property placed or stored on the White House sidewalk and other sidewalks surrounding the structure. (The 3 term White House sidewalk is defined in 36 CFR S 50.19(a)(5) as "the south sidewalk of Pennsylvania Avenue, N.W., between East and West Executive Avenues, N.W.".) Signs or placards leaning against the White House fence, and parcels and other property placed or stored on the sidewalks, especially those left unattended, represent potential threats to the security of the area. For example, both can potentially conceal explosives or other contraband and both can potentially be used to scale the White House fence. In fact, the Secret Service reports a recent incident in which a large sign was used to facilitate the scaling of the fence. In addition to security concerns, experience with the recent proliferation of signs or placards and parcels and other property stationed and stored on the White House sidewalk has demonstrated that the policy of allowing such activity impedes the free flow of pedestrian and emergency traffic by and through the White House and significantly diminishes the White House experience for park visitors. For example, two individuals who have in the past and are presently maintaining a daily demonstration in front of the White House have had as many as twenty-five signs or placards leaning against the White House fence. In addition to the signs, paper bags, suitcases 4 and other parcels containing personal belongings obstruct the view of the White House and impede the flow of pedestrian traffic. It is the judgment of the National Park Service that certain restrictions can be placed upon the stationing of signs or placards and placement or storage of parcels and other property on the White House sidewalk which would enhance the park visitor's experience in viewing the White House and respond to security concerns without impairing the demonstrator's ability to convey a message. Regulatory Changes To accomplish the purpose of minimizing potential threats to the White House and the President, and for the other purposes outlined above, the National Park Service is amending present regulations to prohibit signs or placards on the White House sidewalk, except those that are being hand-carried by an individual. The regulation, then, is not applicable to other parks where demonstrations are permitted. (Demonstrations are not permitted on other sidewalks contiguous to the White House. 36 CFR S 50.19 (c) (1) The interim rule would not prohibit the carrying of a sign or placard during demonstrations on the White House sidewalk. Further, it would not place any restriction on the size of the 5 sign or placard, as long as it is in fact being held or carried by an individual. The interim rule would prohibit signs or placards that are not held or carried by individuals, for example, signs that are leaned against the White House fence, signs that are left unattended on the White House sidewalk and signs that are supported by other structures. In fact, the interim rule does not dramatically change the present regulatory scheme - temporary structures are presently prohibited on the White House sidewalk under 36 CFR $ 50.19 (e) (8). The National Park Service believes that there is a substantial government interest in regulating the use of signs or placards on the White House sidewalk. Signs or placards not hand-carried and those left unattended cannot be easily moved in emergency situations. Signs or placards leaning against the White House fence may conceal dangerous materials, obscure the view of law enforcement personnel and create other security problems. For example, a sign affixed to a large structure caught fire several weeks ago, seriously damaging the fence and granite post in front of the Old Executive Office Building, a few feet from the White House sidewalk and fence. 6 In addition, signs or placards leaning against the White House fence can obscure the view of the White House for the thousands of park visitors. Signs or placards stationed on the sidewalk also incommode the passageway and sometimes cause difficulty in maintaining smooth pedestrian flow, which may include park visitors and persons having business in the area. The interim rule also prohibits the placement or storage of parcels, containers, packages, bundles or other property on the White House sidewalk, the west sidewalk of East Executive Avenue, N.W. between Pennsylvania Avenue, N.W. and E Street, N.W., and the north sidewalk of E Street, N.W. between East and West Executive Avenues, N.W. The rule will not interfere with an individual who is carrying a parcel or other property along the sidewalk. In fact, it will not even subject an individual setting a parcel or other property down on the sidewalk or attending structures for up to one hour to law enforcement action unless that individual either refuses law enforcement personnel requests to search the property, or leaves the property unattended. The National Park Service concludes, however, that when a parcel, container, package, bundle or other property is placed or stored on the sidewalks contiguous to the White House, 7 potential security problems are created. In addition, the National Park Service concludes that parcels and other property; like signs or placards, may obscure the view of the White House by park visitors and law enforcement personnel, may be difficult to move when the sidewalk must be cleared in an emergency and may incommode the sidewalk and interfere with visitor and business pedestrian traffic. The National Park Service believes that these minor restrictions on the stationing of signs or placards and the placement or storage of parcels, containers, packages, bundles or other property serve substantial government interests in maintenance of the security of the White House, preservation of the park experience for park visitors, and free passage of pedestrian traffic by and through the White House. The regulation is written in a neutral manner such that all persons are prohibited from stationing signs or placards or storing parcels or other property on the sidewalks surrounding the White House. In addition, it is unrelated to the suppression of free expression and the incidental impact on First Amendment freedoms is only as great as is essential to serve the substantial government interests in security, aesthetics and free passage of pedestrian traffic. Further, the interim rule 8 applies only to sidewalks contiguous to the White House. A substantial number of alternative forums exist close to the White House sidewalks where these restrictions do not apply. Public Participation The policy of the Department of the Interior is, whenever practicable, to afford the public an opportunity to participate in the rulemaking process. Accordingly, interested persons may submit written comments, suggestions, or objections regarding the interim rule to the address noted at the beginning of the rulemaking within the time period specified. Impact Analysis The National Park Service has determined that this document is not a major rule requiring preparation of a Regulatory Impact Analysis under Executive Order 12291. The National Park Service has also determined that the interim rule will not have a significant economic impact on a substantial amount of small entities and, therefore, does not require a small entity flexibility analysis under Public Law 96-354. The interim rule merely places restrictions on the stationing of signs or placards and parcels and other property on sidewalks contiguous to the White House. It will have no substantial impact on any aspect of the economy. 9 The National Park Service has further determined that this interim rule is not a major Federal action significantly affecting the quality of the human environment. List of Subjects in/36 CFR Part 50 District of Columbia, National Parks, National Capital Parks. Assistant Secretary for Fish and Wildlife and Parks 06 APR Date Approved PART 50 - NATIONAL CAPITAL PARKS REGULATIONS In consideration of the foregoing, sections 50.19 and 50.7 of Title 36 of the Code of Federal Regulations are accordingly amended. 1. The authority citation for Part 50 reads as follows: Authority: Section 6 of the Act of July 1, 1898 (30 Stat. 571); Sections 1-3 of the Act of August 25, 1916 (39 Stat. 535, as amended); Section 16 of the Act of March 3, 1925 (43 Stat. 1126, as amended); 10 Act of March 17, 1948 (62 Stat. 81); Act of August 8, 1953 (67 Stat. 495); Act of July 1, 1980 (94 Stat. 872); 16 U.S.C. 1-3; D.C. Code 8-137 (1981); D.C. Code 40-721 (1981). 2. Section 50.19 is amended by redesignating paragraphs (e) (9) through (11) as (e) (11) through (13) and adding new paragraphs (e) (9) and (e) (10) to read as follows: (9) No signs or placards shall be permitted on the White House sidewalk except those signs or placards that are held or carried by an individual. (10) No parcel, container, package, bundle or other property shall be placed or stored on the White House sidewalk or on the west sidewalk of East Executive Avenue, N.W. between Pennsylvania Avenue, N.W. and E Street, N.W. or on the north sidewalk of E Street, N.W. between East and West Executive Avenues, N.W.; Provided, however, that a parcel, container, package, bundle or other property, except structures, may be set down on these sidewalks for a maximum of one hour if it is attended at all times within that time period, and law enforcement personnel are permitted to search the property. 11 3. Section 50.7 (h) is amended by redesignating the existing paragraph as paragraph "(1)" and by adding a paragraph "(2)", as follows: (h) Storage. (1) * * * (2) No parcel, container, package, bundle or other property shall be placed or stored on the White House sidewalk, as that term is defined in section 50.19 (a) (5) of this Part, or on the west sidewalk of East Executive Avenue, N.W. between Pennsylvania Avenue, N.W. and E Street, N.W. or on the north sidewalk of E Street, N.W. between East and West Executive Avenues, N.W.; Provided, however, that a parcel, container, package, bundle or other property, except structures, may be set down on any of these sidewalks for a maximum of one hour if it is attended at all times within that time period, and law enforcement personnel are permitted to search the property. 12 6397A U.S. Department of the Interior National Park Service Determination of Effects of Rule Section 1. Description of Rule This interim rule would amend 36 C.F.R. S 50.19 (e) to prohibit signs or placards on the White House sidewalk, except signs or placards that are held or carried by an individual. The interim rule would also amend that section and section 50.7 of 36 C.F.R. to prohibit the placement or storage of parcels, containers, packages, bundles or other property on the sidewalks surrounding the White House. Section 2. Semiannual Agenda Listing This interim rule will be published in the April, 1983, semiannual agenda. Section 3. Purpose The purpose of this interim rule is to prohibit the stationing of signs or placards on the south sidewalk of Pennsylvania Avenue, N.W., between East and West Executive Avenues, N.W. (commonly known as "the White House sidewalk") and to prohibit the placing or storing of parcels or other property on the sidewalks surrounding the White House. The authority for this interim rule is Section 3 of the Act of August 25, 1916 (39 Stat. 535, as amended; 16 U.S.C. S 3); Act of July 1, 1980 (94 Stat. 872); D.C. Code S 8-137 (1981); 245 DM 1 (45 FR 23383); and National Park Service Order No. 77 (38 FR 7478), as amended. Section 4. Need Recent events occurring in the Memorial Core parks have increased security concerns for the White House and the President. On December 8, 1982, an individual drove a truck up to the Washington Monument and threatened to blow the structure up with 1,000 pounds of dynamite that was allegedly stored in the truck. This incident, occurring a mere three blocks from the White House, highlighted the potential security threat that could be caused by one determined individual. As a result of that incident, the National Park Service reviewed its regulations relating to the White House area. It was determined that the present regulatory scheme premitting almost unlimited stationing of signs or placards on the White House sidewalk and the placing and storing of parcels or other property on that and other sidewalks surrounding the White House create potentially threatening situations. Signs or parcels stationed on the sidewalk, especially when leaning against the White House fence, and stored parcels or other property, 2 especially those unattended, could conceal dangerous materials and could obscure the view of law enforcement personnel. Further, signs or placards that are not being hand-carried and parcels or other property, especially those unattended, may be difficult to move in an emergency situation. In addition to security concerns, stationary signs or placards and stored parcels or other property may impede the flow of pedestrian traffic by and through the White House. Signs, placards, parcels or other property also obscure the view of visitors to the White House. For these reasons, the National Park Service has determined that there is a substantial government interest in prohibiting signs or placards, except those that are hand-carried, on the White House sidewalk and prohibiting the placing or storing of parcels, containers, packages, bundles and other property on those sidewalks contiguous to the White House. Section 5. Information Collection and Record-keeping Requirements The interim rule contains no information collection or record-keeping requirements. Section 6. Economic Effects The interim rule has no estimated economic effects and is not expected to result in an increase in costs or prices. The purpose of the rule is simply to prohibit the stationing of signs 3 or placards and the placing or storing of parcels or other property on sidewalks surrounding the White House. Therefore, no private sector resources will be affected. In addition, the only governmental resources or personnel possibly called into play by the rule would be for law enforcement-type activities. Obviously, the costs, if any, of these potential activities cannot be quantified at present. Further, since the rule merely prohibits certain individual, private activities in specified areas around the White House, it should have no effect on competition, employment, investment, productivity, innovation, or the ability of United States-based enterprises to compete in domestic or export matkets. Section 7. Significant Economic Effects on a Substantial Number of Small Entities No economic impact on any type of small entity is anticipated since the rule attempts only to regulate individual, private activity on several sidewalks surrounding the White House. NO economic interests of any small entities are involved in the activities regulated. Section 8. Determination of "Major" Under the definition of a "major rule" as set forth in $ 1(b) of Executive Order 12291, the interim rule is not a major rule since it merely prohibits individual, private activities on sidewalks contiguous to the White House. 4 In accordance with Executive Order 12291, I have determined that the interim rule described above is not major. Regional National Director Capital Region 3/28/23 Manus 9 Full Concur: Russell 2. Dickenson Director, National Park Service 3/31/83 Section 9. Certification of Significant Economic Effect on a Substantial Number of Small Entities In accordance with the Regulatory Flexibility Act, I certify that the rule described above will not have a significant economic effect on a substantial number of small entities. Manus 9 Full Regional Director National Capital Region 3/28/83 Concur: Russell E. Dickenson Director, National Park Service 3/31/83 5 Section 10. Approving Official's Certification Approve: Disapprove: Other: Date: 06 Apr 83 Section 11. Distribution cc: Office of Policy Analysis, PBA Division of General Law, SOL Division of Directives and Paperwork Management, PBA Office of Small and Disadvantaged Business Utilization, OSDBU Chief Counsel for Advocacy, Room 1010 Attention: Regulatory Flexibility 1441 L Street, N.W. Washington, D.C. 20516 6 DEPARTMENT OF THE INTERIOR OFFICE OF THE SOLICITOR 4/21/83 WASHINGTON, D. C. 20240 H.P. Thought you wright be interested in OVT new regs which go into effect Fr. 4/22. These regs require that all Signs on the White House Sideralk be hand held. They also ban the placing of parcels on the White House Sidewalk. Ruh Robbine MEMORANDUM THE WHITE HOUSE WASHINGTON May 11, 1983 FOR: DAVID B. WALLER JOHN G. ROBERTS, JR. FROM: CLAUDIA MCMURRAY SUBJECT: Regulation of White House Demonstrations Title 16, United States Code, authorizes the Director of the National Park Service ("NPS") to "have the supervision, management, and control of the several national parks and national monuments under the jurisdiction of the Department of the Interior, ii 16 U.S.C. $ 2. Included within the Director's jurisdiction, among several other areas, are the "White House area, 1/ the "White House sidewalk," 2/ and Lafayette Park. Current National Park Service regulations 4/ set forth certain restrictions on demonstrations on the White House sidewalk and in Lafayette Park. 5/ According to the regulations, "demonstrations and special events may be held only pursuant to a permit, " unless such events involve 25 persons or less. 36 C.F.R. § 50. 19 (c) (1) Demonstrations are limited to 750 persons on the White House sidewalk and 3,000 persons in Lafayette Park. 36 C.F.R. §§ 50.19 (e) (1) and (2). In addition, the Director may restrict demonstrations and special events during certain weekday hours, "if it reasonably appears necessary to avoid unreasonable interference with rush hour traffic." 36 C.F.R. § 50.19 (e) (6). No structures or sound amplification equipment are permitted on the White House sidewalk. 36 C.F.R. §§ 50.19 (e) (8) (i) and (9) (i). Beginning in the late sixties and early seventies, several groups of demonstrators challenged the constitutionality of various aspects of the NPS regulations. A summary of the applicable case law is set forth below. Case Law Historically, public streets and parks have been open to the public for the exercise of first amendment rights of speech and assembly. See Hague V. CIO, 307 U.S. 496 (1939). The exercise of these rights, however, is subject to reasonable time, place and manner restrictions, which take into account a variety of governmental interests: such as control of traffic in the streets, prevention of blockage of entrances to buildings, and prevention of littering. Thus, in "public forum" cases, the courts will engage in a balancing of the first amendment rights of demonstrators against the legitimate interests of the government in regulating conduct in public areas. -2- The guidelines courts use when balancing these competing interests were first set forth in United States V. O'Brien, 391 U.S. 376, 377 (1968). According to the O'Brien test, restrictions on expression are valid if: (1) the regulation furthers an important or substantial governmental interest; (2) the governmental interest is unrelated to the suppression of free expression; and (3) the incidental restriction on alleged first amendment rights is no greater than is essential to the furtherance of that interest. Id. Governmental restrictions, then, should be neutrally framed and narrowly tailored to serve the state interest. Several cases dealing with the use of the area around the White House have utilized these guidelines. In Quaker Action Group V. Morton, 516 F.2d 717 (1975), several groups challenged the Park Service's denial of a permit for planned demonstrations on the White House sidewalk and in Lafayette Park. The D.C. Circuit upheld as constitutional the permit system as a whole, citing the government's interest in the security of the White House area as sufficiently important to justify some kind of prior restraint on demonstrations. Id. at 726. In addition, the court said, the Park Service must be permitted to allocate competing demands on the time and space of the White House, due to its status as a "unique situs." Id. The court in Quaker Action Group upheld other provisions banning sound amplification equipment on the White House sidewalk and restricting demonstration activities during rush hour. The government has a significant interest, the court found, in assuring quiet for the numerous White House staff members working in the area, as well as the smooth flow of traffic on the streets and sidewalks. Id. at 727. The D.C. Circuit also found, however, that the numerical limitations on groups on the White House sidewalk and in Lafayette Park should be interpreted as minimum, rather than maximum, restrictions. Id. at 731. The court found no evidence that large groups create more of a security risk to the President or the White House complex than do smaller groups. Id. at 730. In the late sixties, a group called Women Strike for Peace (WSP) repeatedly sought permission to erect a small temporary display on the Ellipse. See Women Strike for Peace V. Morton, 472 F.2d 1273 (1972). The Park Service rejected WSP's requests for permits as contrary to the government's interest in preserving the Ellipse as an unspoiled area. Id. at 1276. Moreover, the Park Service claimed that WSP's display (consisting of 11 styrofoam tombstones intended to commemorate those who died in -3- Vietnam) would interfere with the Pageant for Peace held on the Ellipse during the Christmas season. Id. The D.C. Circuit rejected the articulation of these interests, finding that the government action was discriminatory on the basis of the content of the WSP's message. Id. at 1294. According to the court, the Ellipse was large enough to accommodate both activities without preempting the WSP's demonstration entirely. Id. In 1974, the Vietnam Veterans Against the War challenged the Park Service's refusal to issue a permit for a "symbolic campsite" on the Mall. See Vietnam Veterans Against the War V. Morton, 506 F.2d 53 (D.C. Cir. 1974) (per curiam). According to the Park Service, it could not allow four days of continuous camping, because such activity violated § 50.19 (e) (8) of the Park Service regulations, which prohibits camping in certain national park areas. Id. at 57. The court upheld the Park Service's position, finding that cooking and camping overnight were "beyond the pale of first amendment protection." Id. Even if camping did merit first amendment protection, the court accepted the Park Service's claim that camping is too taxing on the government's law enforcement and sanitation resources. Id. at 59. This year, a case similar to VVW V. Morton awaits the granting of certiorari by the Supreme Court. See Community for Creative Non-Violence V. Watt, No. 82-2445. In this case, the Community for Creative Non-Violence (CCNV) applied for and was granted a renewable seven-day permit to conduct an around-the-clock demonstration, commencing on the first day of winter, on the Mall and in Lafayette Park. Id. at 4. The purpose of the demonstration was to illustrate the plight of the poor and homeless to the President, the Congress and the public at large. Id. The Park Service denied CCNV's request for a permit to sleep, a decision the CCNV challenged as an abridgment of their first amendment right to free expression. Id. The Park Service claimed that allowing the demonstrators to sleep would violate its anti-camping regulations. See 36 C.F.R. § 50.19. The District Court reached the same result the D.C. Circuit had reached in VVW V. Morton: sleeping, in the form of camping, is not within the first amendment's scope of protection. Id. at 9. The D.C. Circuit overturned the lower court's decision finding that sleep was indeed part of CCNV's message and therefore constitutionally protected. Id. at 15. The court rejected the Park Service's argument that sleeping demonstrators would drain more of the government's resources than they would if awake. Id. at 22. The court did find that the government had an interest in preventing the storage of personal belongings in Lafayette Park but concluded that the Park Service could regulate this activity by less restrictive means than a total ban on sleeping. Id. On March 15, 1983, the Supreme Court granted a stay of the Court of Appeals decision, pending a decision on a writ of certiorari. The CCNV, therefore, was prohibited from conducting their planned demonstration this year. 6/ -4- Other Situses: The Supreme Court and the Capitol Grounds Challenges similar to those discussed above have been brought regarding the use of the Supreme Court area and the Capitol Grounds. In Jeannette Rankin Brigade V. Chief of Capitol Police, 342 F. Supp. 575 (1972), a coalition of women against the Vietnam War challenged a law which prohibits "processions or assemblages" on the Capitol Grounds. The Jeannette Rankin Brigade wished to march from Union Station to the Capitol grounds, and then to assemble at the base of the Capitol steps. Id. at 578. Permission for the march was denied. Id. The District Court struck down the law as a clear first amendment. Id. at 585. It said that no governmental interest in "peace," "serenity," and "majesty" around the Capitol grounds could override the fundamental right to petition the government. Id. The Supreme Court recently handed down a decision in United States V. Grace, No. 81-1863, a case involving the right to picket on the Supreme Court sidewalk. In Grace, the court struck down as a first amendment violation a law prohibiting the "display of any flag, banner or device designed or adapted to bring into public notice any party, organization or movement" in the United States Supreme Court building and on its grounds. Id. at 12. The Court could find no sustainable governmental interest in preventing traffic obstructions or the injury of passersby, which would permit the adbridgment of an individual's rights. Id. at 10-11. In classifying the sidewalk area as a public forum, the court concluded "there is nothing to indicate to the public that these sidewalks are part of the Supreme Court grounds or are in any way different from other public sidewalks in the city. " Id. at 12. Interim Regulations On April 22, interim regulations governing the use of the White House sidewalk went into effect. The new regulations prohibit signs or placards on the White House sidewalk "except those that are carried by an individual." 36 C.F.R. § 50.19 (e) (9). In addition, the regulations provide, "No parcel, container, pack- package, bundle or other property shall be placed or stored on the White House sidewalk. " 36 C.F.R. § 50.19 (e) (10). Such a parcel or container may, however, be set down on the designated sidewalks for a maximum of one hour "if it is attended at all times within that time period, and law enforcement personnel are permitted to search the property." Id. The Park Service articulates several purposes for the change in regulations. Primary among those: "Signs or placards leaning against the White House fence may conceal dangerous materials, obscure the view of law enforcement personnel and create other security problems.' NPS interim regulations, p. 6. The Park Service cited an incident several weeks ago, when a sign caught fire and seriously damaged the fence and granite post in front of the Old Executive Office Building. Id. -5- The Park Service also feels that signs left unattended can "obscure the view of the White House for thousands of park visitors. Id. at 7. NPS cited many instances when pedestrian traffic has been impeded by signs left unattended. Id. In comments attached to the regulations, the Park Service expresses its belief that the regulatory changes place only "minor restrictions on the activities of demonstrators in front of the White House.' Id. at 8. The Park Service contends that the regulations are "written in a neutral manner such that all persons are prohibited from stationing signs or placards or storing parcels or other property on the sidewalks surrounding the White House. Id. The Service claims that any incidental impact on speech is outweighed by governmental interests in security, aesthetics, and free passage of pedestrian traffic. Id. The American Civil Liberties Union has challenged the interim regulations as a violation of the first amendment (they also make a fourth amendment challenge, not addressed here). This week, Judge Bryant heard an ACLU motion for a temporary restraining order to keep the Park Service from implementing the rules. In light of the case law in this area, the Park Service has some strong arguments for upholding the regulations. The restrictions apply to all demonstrators who carry signs, rather than only those with a particular message. (Although, conceivably, it could be argued that the regulation discriminates against those with long messages that cannot be carried by hand.) In addition, the regulations only prohibit leaving a sign or placard unattended. It is well settled in this area of constitutional law that people who want to express their views do not have a constitutional right to do so "whenever and however they please." Adderley V. Florida, 385 U.S. 39 (1966). Furthermore, the Park Service has articulated two substantial governmental interests in justifying these regulations. It appears that the security of the President and the White House area is a very real concern. Certainly, the D.C. Circuit found such an interest to be significant. See Quaker Action Group at 727. The interest in keeping the White House area clear and unobstructed has also been recognized. See id. The Supreme Court's granting of a stay in CCNV V. Watt is also significant. Although the Court has not granted certiorari in that case, it appears at least that the Court would be open to reasonable restrictions on demonstrations in the Whtie House area. FOOTNOTES 1/ The "White House Area" is defined as all park areas, including sidewalks adjacent thereto, within these bounds: on the south, Constitution Avenue, N.W.; on the north, H Street, N.W.; on the east, 15th Street, N.W.; and on the west, 17th Street, N.W." 36 C.F.R. § 50.19 (a) (4). 2/ The "White House Sidewalk" is defined as "the south sidewalk of Pennsylvania Avenue, N.W. between East and West Executive Avenues, N.W." 36 C.F.R. § 50.19 (a) (5). 3/ "Lafayette Park" is defined as "the park areas, including sidewalks adjacent thereto, within these bounds: on the south, Pennsylvania Avenue, N.W.; on the east, Madison Place, N.W.; on the north, H Street, N.W.; and on the west, Jackson Place, N.W." 36 C.F.R. § 50.19 (a) (6). 4/ "Current regulations" discussed in this section of the memorandum are those in effect prior to the implementation of the interim regulations on April 22, 1983. The interim regulations will be discussed later in this memorandum. 5/ According to National Park Service regulations, no permits are issued for demonstrations in the "White House Area" as defined in footnote 1. See 36 C.F.R. § 50.19 (e) (5) (i). 6/ The CCNV was successful in a similar challenge last year. See CCNV V. Watt, 670 F.2d 1213 (D.C. Cir. 1982). The D. C. Circuit, however, construed the NPS regulation in order to avoid the constitutional issue. 3 50.19 endanger the life or limb of other per- use by fishermen of waters open to Street, NW.; on the east, 15th Street, tion. The numerical limitations listed sons. fishing in areas administered by Na- NW.: and on the west, 17th Street, below are applicable only for demon- tional Capital Parks, the Superintend- NW. § 50.16 Model planes. ent, in his discretion, may close to strations conducted without a permit (5) The term "White House in such areas. Larger demonstrations NO model powered plane shall be fishing all or any part of such open sidewalk" means the south sidewalk of flown from any park area unless au- may take place in these areas pursu- waters for such periods of time as may Pennsylvania Avenue, NW., between ant to a permit. thorized by an official permit. be necessary. Provided, the notice East and West Executive Avenues, (i) Franklin Park. Thirteenth Street, thereof shall be given by the posting NW. § 50.17 Gambling. between I and K Streets, NW., for no of appropriate signs, notices, and (6) The term "Lafayette Park" more than 500 persons. Gambling in any form, or the oper- markers. Fishing in Prince William means the park areas, including (ii) McPherson Square. Fifteenth ation of gambling devices whether for Forest Park shall be prohibited in sidewalks adjacent thereto, within merchandise or otherwise in park areas designated for swimming, boat- Street, between I and K Streets, NW., these bounds: on the south, Pennsyl- for no more than 500 persons. areas, is prohibited. ing, or other public use, such areas to vania Avenue, NW.; on the north, H (iii) U.S. Reservation No. 31. West of be designated by posting of signs. Street, NW.; on the east, Madison § 50.18 Hunting and fishing. 18th Street and south of H Street, Place, NW.; and on the west, Jackson § 50.19 Demonstrations and special events. NW., for no more than 100 persons. (a) Hunting in park areas prohibit- Place, NW. (iv) Rock Creek and Potomac Park- ed. The parks are sanctuaries for wild- (a) Definitions. (1) The term "dem- (7) The term "Ellipse" means the life of every sort and no person shall way. West of 23rd Street, south of P onstrations" includes demonstrations, park areas, including sidewalks adja- at any time or at any place within a cent thereto, within these bounds: on Street, NW., for no more than 1,000 picketing, speechmaking, marching, park area, trap, catch, kill, injure, or persons. holding vigils or religious services and the south, Constitution Avenue, NW.; pursue any wild birds or wild animals, all other like forms of conduct which on the north, E Street, NW.: on the (v) U.S. Reservation No. 46. North except dangerous animals when it is west, 17th Street, NW.; and on the side of Pennsylvania Avenue, west of involve the communication or expres- necessary to prevent them from de- east, 15th Street, NW. Eighth Street and south of D Street, sion of views or grievances, engaged in stroying human lives or inflicting per- by one or more persons, the conduct of (8) The term "Director" means the SW., for no more than 25 persons and sonal injury, or destroy, remove or dis- which has the effect, intent or propen- Director, National Capital Parks, Na- south of D Street, SE, for no more turb the nest or eggs of any wild bird. sity to draw a crowd or onlookers. This tional Park Service, U.S. Department than 25 persons. The Superintendent is authorized to term does not include casual park use of the Interior, or his authorized rep- (c) Permit applications may be ob- take necessary action to capture or de- resentative. tained at the Office of Public Affairs, stroy wildlife which is damaging Gov- by visitors or tourists which does not (9) The term "other park areas" in- National Capital Region, 1100 Ohio ernment property. have an intent or propensity to attract cludes all areas, including sidewalks Drive, S.W., Washington, D.C. 20242, a crowd or onlookers. (b) Unauthorized possession of wild- adjacent thereto, other than the or at the Main Information Desk of life. Unauthorized possession within a (2) The term "special events" in- White House area, administered by the National Visitor Center. Union park area of any live wild bird or cludes sports events, pageants, celebra- National Capital Parks. Station, Washington, D.C. 20240. animal, or the dead body or any part tions, historical reenactments, regat- Permit applications shall be submitted thereof, of any wild bird or animal tas, entertainments, exhibitions, pa- NOTE: The darkened portions of the dia- in writing on a form provided by the rades, fairs, festivals and similar grams at the conclusion of this section show shall be prima facie evidence that the National Park Service so as to be re- person or persons having the same, are events (including such events present- the areas where demonstrations or special events are prohibited. ceived by the Director at least 48 guilty of violating this section. ed by the National Park Service), hours in advance of any proposed (c) Fishing in park areas in Mary- which are not demonstration under (b) Demonstrations and special demonstration or special event. This land and Virginia. Persons fishing in paragraph (a)(1) of this section, and events may be held only pursuant to a 48 hour period will bei waived by the areas under the jurisdiction of the Na- which are engaged in by one or more permit issued in accordance with the Director if the size and nature of the tional Park Service, lying within the persons, the conduct of which has the provisions of this section except: activity will not reasonably require the geographical limits of Maryland or effect, intent or propensity to draw a (1) Demonstrations involving 25 per- commitment of park resources or per- Virginia, must be licensed by and crowd or onlookers. This term also sons or less may be held without a sonnel in excess of that which are nor- comply with the applicable State laws. does not include casual park use by permit provided that the other condi- mally available or which can reason- (d) Fishing in park areas in the Dis- visitors or tourists which does not tions required for the issuance of a ably be made available within the nec- trict of Columbia. Persons fishing in have an intent or propensity to attract permit are met and provided further essary time period. Forms shall be re- waters in the District of Columbia con- a crowd or onlookers. that the group is not merely an exten- ceived only during the hours of 8 a.m.- trolled by the Secretary of the Interi- (3) The term "national celebration sion of another group already availing 4 p.m., Monday through Friday, holi- or shall comply with the fishing regu- events" means the annually recurring itself of the 25-person maximum days excepted. All demonstration ap- lations for the District of Columbia special events regularly scheduled by under this provision or will not unrea- plications, except those seeking waiver approved by the Secretary of the Inte- National Capital Parks, which are sonably interfere with other demon- of the numerical limitations applicable rior and adopted by the Commission- listed in paragraph (d)(1) of this sec- strations or special events. to Lafayette Park (paragraph (e)(2) of ers of the District of Columbia. tion. (2) Demonstrations may be held in this section), shall be deemed granted, (e) Closing of waters. During a (4) The term "White House area" the following park areas without an subject to all limitations and restric- period of emergency, just prior to and means all park areas, including official permit provided that the con- tions applicable to said park, unless during special ceremonial events or sidewalks adjacent thereto, within duct of such demonstrations is reason- denied within 24 hours of receipt. competitive aquatic events, adjacent to these bounds: on the south, Constitu- ably consistent with the protection However, where a permit has been docks and floats, or to prevent over- tion Avenue, NW.; on the north, H and use of the indicated park area and granted, or is deemed to have been the other requirements of this regula- granted pursuant to this subsection, 224 225 Title 36-Parks, Forests, and Public Property § 50.19 Chapter I-National Park Service, Dept. Interior § 50.19 the Director may revoke that permit official annual commemorative Jeffer- for two week period In approximately marshal the demonstration In such a pursuant to paragraph (f) of this sec- son birthday ceremony. late June and early July. fashion so as to render unlikely any NOTE: The darkened portions of the dia- (vi) Columbus Day Commemorative substantial risk of unreasonable dis- tion. (1) White House Area. No permit grams at the conclusion of this section show Wreath-Laying. At the Columbus ruption or violence. In making a shall be issued authorizing demonstra- the areas where demonstrations or special statue on the Union Plaza on Colum- waiver determination, the Director tions, except for the White House events are prohibited. bus Day. shall consider and the applicant shall sidewalk. Lafayette Park and the El- (d) Permit application for demon- (vii) Inaugural Ceremonies. The furnish at least ten days in advance of lipse. No permit shall be issued strations and special events shall be White House Sidewalk and Lafayette the proposed demonstration, the func- authorizing special events, except for Park, exclusive of the northeast quad- tions the marshals will perform, the the Ellipse, and except for annual processed in order of receipt, and the rant, for the exclusive use of the Inau- means by which they will be identi- use of a particular area shall be allo- commemorative wreath-laying ceremo- gural Committee on January 20, 1981. fied, and their method of communica- cated in order of receipt of fully ex- nies relating to the statues in La- (viii) Other demonstrations or spe- tion with each other and the crowd. ecuted applications, subject to the cial events shall be permitted in these This requirement will be satisfied by fayette Park. limitations set forth in this section: (2) Other park areas. No permits particular park areas to the extent completion and submission of the Provided, That a permit may be shall be issued authorizing demonstra- that they do not significantly inter- same form referred to in paragraph (c) denied in writing upon the personal fere with the National Celebration tions or special events in the following of this section. approval of the Director, or, in his ab- Events listed in this paragraph. No ac- (4) No permit shall be issued for a other park areas: sence or unavailability by an author- tivity containing structures shall be demonstration on the White House (i) The Washington Monument, ized delegate of responsible rank and permitted closer than 50 feet to an- Sidewalk and in Lafayette Park at the which means the area enclosed within function upon the following grounds: other activity containing structures same time except when the organiza- the inner circle that surrounds the (1) A fully executed prior applica- without the mutual consent of the tion, group, or other sponsor of such Monument's base, except for the offi- tion for the same time and place has sponsors of those activities. demonstration shall undertake in good cial annual commemorative Washing- been received, and a permit has been (2) It reasonably appears that the faith all reasonable action, including ton birthday ceremony. or will be granted authorizing activi- proposed demonstration or special the provision of sufficient marshals, to (ii) The Kennedy Center, which ties which do not reasonably permit event will present a clear and present insure good order and self-discipline in means the area under the administra- multiple occupancy of the particular danger to the public safety, good conducting such demonstration and tion of the National Park Service area; in that event, an alternate site, if order, or health. any necessary movement of persons, within the building known as the John available for the activity, shall be pro- (3) The proposed demonstration or so that the numerical limitations and F. Kennedy Center for the Performing Arts and includes the roof terrace and posed by the Director to the applicant: special event is of such a nature or du- waiver provisions described in para- Provided, however, That the following ration that it cannot reasonably be ac- graphs (e) (1) and (2) of this section outdoor terraces on the north, south, national celebration events shall have commodated in the particular area ap- are observed. and west portions of the institution as priority use of the particular park area plied for; in that event, an alternate (5) No permit shall be issued author- well as the driveways leading to the parking garages. For the purpose of during the indicated period, as follows: site, if available for the activity, shall izing demonstrations or special events (i) Christmas Pageant of Peace. In be proposed by the Director to the ap- in excess of the time periods below this section, the term "Kennedy the oval portion of the Ellipse only. plicant; in this connection, the Direc- provided that these periods shall be Center" does not include the east building sidewalk, outdoor plaza or during approximately the last three tor shall reasonably take into account extended for demonstrations only, grassy areas at the Center. weeks in December. possible damage to the park, including unless another application requests (ii) President's Cup Regatta. In East trees, shrubbery, other plantings, park use of the particular area and said ap- Demonstrations are permitted on Potomac Park for approximately two installations and statues. plication precludes double occupancy: those latter areas provided entrances to the Center are not obstructed or ve- days during the first week in June. (4) The application proposes activi- (i) White House area, except the El- (iii) Cherry Blossom Festival. In the ties contrary to any of the provisions lipse: Seven days. hicular traffic in its vicinity is not im- of this section or other applicable law Japanese Lantern area adjacent to the (ii) The Ellipse and all other park peded. or regulation. areas: Three weeks. Tidal Basin and on the Ellipse and the (iii) The Lincoln Memorial, which (e) Issuance of permits shall be sub- (6) The Director may restrict demon- Washington Monument Grounds adja- means that portion of the park area ject to the following limitations: strations and special events weekdays cent to Constitution Avenue, between which is on the same level or above (1) No more than 750 persons shall (except holidays) between the hours 15th & 17th Streets, NW, for six days the base of the large marble columns be permitted to conduct a demonstra- of 7:00-9:30 a.m. and 4:00 to 6:30 p.m. surrounding the structure, and the usually in late March or early April. tion on the White House sidewalk at if it reasonably appears necessary to single series of marble stairs immedi- (iv) Fourth of July Celebration. On any one time. avoid unreasonable interference with ately adjacent to and below that level, the Washington Monument Grounds. (2) No more than 3,000 persons shall rush-hour traffic. except for the official annual com- (v) Festival of American Folklife. In be permitted to conduct a demonstra- (7) No special event shall be permit- memorative Lincoln birthday ceremo- the areas bounded on the south by tion in Lafayette Park at any one ted unless approved by the Director. Independence Avenue, NW.; on the time. In determining whether to approve a ny. (iv) The Jefferson Memorial, which north by a line running adjacent to (3) The Director may waive the 3,000 proposed special event. the Director means the circular portion of the Jef- the south side of the Reflecting Pool person limitation for Lafayette Park shall consider and base his determina- ferson Memorial enclosed by the out- between 17th Street, NW., and Lincoln and/or the 750 person limitation for tion upon the following criteria: ermost series of columns, and all por- Memorial Circle; on the east by 17th the White House Sidewalk upon a (i) Whether the objectives and pur- tions on the same levels or above the Street, NW.: on the west by Lincoln showing by the applicant that good poses of the proposed special event base of those columns, except for the Memorial Circle and 23rd Street, NW., faith efforts will be made to plan and relate to and are within the basic mis- 226 227 § 50.19 Title 36-Parks, Forests, and Public Property Chapter I-National Park Service, Dept. Interior sion and responsibilities of National as practicable after the conclusion of § 50.19 also require a permit from the District Capital Parks, National Park Service. the permitted demonstration or spe- of Columbia or other appropriate gov- Issued for a special event is revocable, (ii) Whether the park area requested cial event. ernmental entity for demonstrations at any time, in the reasonable discre- is reasonably suited in terms of acces- (iii) The Director may impose rea- or special events sought to be conduct- sibility, size, and nature of the pro- sonable restrictions upon the tempo- ed either wholly or in part in other delegate. tion of the Director or his authorized posed special event. rary structures permitted, in the inter- than park areas. (g) Information Collection. The in- (iii) Whether the proposed special est of protecting the park areas in- (f) A permit issued for a demonstra- event can be permitted within a rea- volved, traffic and public safety con- formation collection requirements con- tion is revocable only upon a ground sonable budgetary allocation of Na- siderations, and other legitimate park for which an application therefor tained in this section have been ap- tional Park Service funds considering value concerns. would be subject to denial under para- proved by the Office of Management the event's public appeal, and the an- (iv) Any structures utilized in a dem- and Budget under 44 U.S.C. 3507 and ticipated participation of the general onstration extending in duration graph (d) or (e) of this section. Any such revocation, prior to the conduct assigned clearance number 1024-0021. public therein. beyond the time limitations specified of the demonstration, shall be in writ- The information is being collected to (iv) Whether the proposed event is in paragraphs (e)(4) (i) and (ii) of this ing and shall be personally approved provide notification to park managers, duplicative of events previously of- section must upon 24 hours notice be by the Director, or, in his absence or United States Park Police, Metropoli- fered in National Capital Parks areas capable of being removed and the site unavailability, by an authorized dele- tan Police, and the Secret Service of or elsewhere in or about Washington, restored or the structure secured in gate of responsible rank and function. the plans of organizers of large-scale D.C. such a fashion so as to not unreason- During the conduct of a demonstra- demonstrations and special events in (v) Whether the activities contem- ably interfere with use of the park tion, a permit may be revoked by the order to assist in the provision of secu- plated for the proposed special event area by other permittees authorized ranking U.S. Park Police supervisory rity and logistical support. This infor- are in conformity with all applicable under this section. official in charge if continuation of mation will be used to further those laws and regulations. (v) Individuals or groups of 25 per- the event presents a clear and present purposes. The obligation is required to (8) In connection with permitted sons or less demonstrating under the danger to the public safety. good order obtain a benefit. demonstrations or special events, tem- small group permit exemption of or health or for any violations of ap- (h) Further information on adminis- porary structures, may be erected for § 50.19(b)(1) shall not be permitted to plicable law or regulation. A permit tering these regulations can be found the purpose of symbolizing a message erect temporary structures other than at 47 FR 24299, June 4, 1982. or meeting logistical needs such as small lecterns or speakers platforms, first aid facilities, lost children areas This provision is not intended to re- or the provision of shelter for electri- strict the use of portable signs or ban- cal and other sensitive equipment or ners. displays. Temporary structures may (9) In connection with permitted not be used outside designated camp- demonstrations or special events, ing areas for living accommodation ac- sound amplification equipment shall tivities such as sleeping, or making be permitted, provided prior notice preparations to sleep (including the has been given to the Director, except laying down of bedding for the pur- that: pose of sleeping), or storing personal (i) No sound amplification equip- belongings, or making any fire, or ment shall be used on the White doing any digging or earth breaking or House sidewalk, other than hand-port- carrying on cooking activities. The able sound amplification equipment above-listed activities constitute camp- which the Director determines, in the ing when it reasonably appears, in exercise of his judgment, is necessary light of all the circumstances, that the for crowd-control purposes. participants, in conducting these activ- (ii) The Director reserves the right ities, are in fact using the area as a to limit the sound amplification equip- living accommodation regardless of ment, so that it will not unreasonably the intent of the participants or the disturb nonparticipating persons in, or nature of any other activities in which in the vicinity of, the area. they may also be engaging. Temporary (10) Authorized permits may contain structures are permitted to the extent additional reasonable conditions and described above, provided prior notice additional time limitations, consistent has been given to the Director, except with this regulation, in the interest of that: protecting the park site, the use of (i) No structures shall be permitted nearby areas by other persons, and on the White House sidewalk. other legitimate park value concerns. (ii) All such temporary structures (11) Permits issued under this sec- shall be erected in such a manner so as tion do not authorize activities outside not to unreasonably harm park re- of areas under administration by Na- sources and shall be removed as soon tional Capital Parks. Applicants may 228 229 PENNSYLVANIA AVENUE WEST EXECUTIVE AVENUE WHITE HOUSE EAST EXECUTIVE AVENUE x 230 E STREET THE WHITE HOUSE RESTRICTED N 231 POTOMAC RIVER - > ENTRANCE PLAZA - -National Park Service, Dept. Interior RESTRICTED RESTRICTED N LINCOLN MEMORIAL KENNEDY CENTER N 50.19