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OA issues Environmental Assessment for the Eisenhower Executive Office Building

On October 16, 2026, the Office of Administration (“OA”) a component of the Executive Office of the President published a Notice of Availability in the Federal Register for the Environmental Assessment (“EA”) for its proposed project to paint the Eisenhower Executive Office Building (“EEOB”) white. This Notice opened a 30-day public comment period on the EA and the project, which will close on November 16, 2026. We encourage you to read the takeaway below, as well as the recent Joint Status Report which details our statement on the deficiencies of the EA and process.

We are still litigating the false assertions that federal preservation law is optional. In the Notice and EA, OA asserts that the project is not subject to NEPA or the NHPA because (1) OA is not a federal agency, and (2) Section 107 of the NHPA exempts the EEOB from Sections 106 and 110(f) review. We maintain and are still litigating that General Services Administration may not reroute federal property work through OA to evade otherwise applicable duties and that Section 107 does not exempt the EEOB from NHPA review.

Primary Takeaway

The EA marks the first time the government has admitted that the painting project would adversely affect at least three nationally significant historic resources, including the EEOB. The EA also acknowledges a non-damaging solution that Plaintiffs and the public have long supported: a cleaning-and-lighting (no painting) alternative that would improve the EEOB without adversely affecting it or other historic properties. Yet, the government insists on moving forward with the painting project as the preferred option, indicating that the desire of the President to look at a white building is more important than the preservation of the nation’s historic resources. The purpose of the project makes this conclusion all the more clear: to “better align the building’s visual character with that of the White House,” as called for in President Trump’s Executive Order 14344: “Making Federal Architecture Beautiful Again.”

  • A viable, no painting alternative is now documented. When OA presented the proposed painting project to the Commission of Fine Arts (“CFA”) and the National Capital Planning Commission (“NCPC”), it did not include a cleaning-and-lighting alternative. The EA finds that the cleaning-and-lighting alternative would cause long-term, beneficial visual and aesthetic impacts and would cause no adverse effect to the EEOB or other historic properties. Thus, the cleaning-and-lighting alternative would do exactly what we have long asked for: it would allow the government to systematically clean, evaluate, and fix necessary parts of the building, while respecting its character defining features and historical significance while avoiding adverse effects.
  • Scaffolding, Cleaning, and even Painting, EVERY year. OA admits that the painting project would require ongoing, annual maintenance, requiring scaffolding around the whole building every year to “soft wash” the building. While the EA explicitly excludes the total cost and anticipated timeframes of both the initial project and its annual maintenance, we can infer that each year’s upkeep is roughly a whole-building job. As we have analogized before, maintaining this kind of upkeep on the EEOB is similar to maintaining the Golden Gate Bridge: start painting on one end, and by the time you are to the other end, you must start over at the beginning.
  • Painting is likely not reversible without damage. The government has not shared any testing results with the public or experts. The EA notes expressly that the reversibility of the painting project is uncertain. Worse, some visible surface changes would remain even after removal attempts. The EA also notes that there is limited research on removing mineral-silicate coatings from natural stone, but intentionally does not include the initial results from OA’s testing on EEOB’s facade. The EA stipulates that additional  testing is still required.

While this is not a compliant process, the public should still comment. While OA still claims that the EEOB project is exempt from the NHPA and NEPA review, we are asking the public to submit comments objecting to the preferred alternative and the process. The Notice opened a 30-day comment period and solicited consulting parties. Comments are due by November 16, 2026. You may submit comments, identified by docket number OA-2026-0001, by either of the following methods:

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