Testimony by Larry Martin, PhD to the
DC Council Committee of the Whole
RFK Campus Redevelopment Act of 2025
Tuesday, July 29, 2025
Council Chairman Mendelson, thank you for this opportunity to present comments on the RFK Campus Redevelopment Act of 2025. My name is Larry Martin, and I am the Water and Natural Places Committee Chair of the Sierra Club District of Columbia Chapter. The Sierra Club is America’s largest and most influential grassroots environmental organization, with millions of members and supporters. In DC, we represent about 7,000 residents across all eight wards.
The 174 acre site of the RFK campus is, as you’re aware, directly adjacent to the Anacostia River, and the District’s sole State Conservation Area and Critical Wildlife Area on Kingman and Heritage Islands. The RFK parcel is of particular ecological importance to our city - and one of the few remaining large parcels for economic development. Development on this site must embody best practices for sustainable development.
Mayor Bowser, in her introduction to the Sustainable DC 2.0 Plan wrote: “Sustainability is about balancing the environmental, economic, and social needs of the District of Columbia today as well as the needs of the next generation, and the one after that.” The Sierra Club calls on the DC Council to realize this aspirational goal with enactment of standards for sustainable development at the RFK site that best serve DC residents’ needs now and in the future. We present to the Council a set of environmental sustainability standards that should be incorporated into legislation permitting development on the RFK site to guide a balance of environmental, economic, and social goals to make the development a world class model of sustainable development, and a healthy home for the people and wildlife who live there.
Washington is a world class city, and the development along the banks of the Anacostia river should embody our city’s commitment to sustainability. For the Sierra Club, “world class” means protective of the environment and public health, energy efficient and eliminating use of fossil fuels, meeting people‘s needs for open space and recreation, providing non-toxic indoor environments, and harmonizing the built environment with the natural environment so that natural areas are appealing to the communities that surround them and protect the Anacostia River water quality. We are alarmed that nothing in the term-sheet negotiated by Mayor Bowser even hints at these outcomes we consider of greatest importance.
There are many examples worldwide of how cities have turned large parcels of land into appealing places to live and destinations through best practices for sustainable development. We include examples in our written testimony: the Navy Yard in Philadelphia; Assembly Row in Somerville, Massachusetts; the San Francisco Eastern Neighborhoods Plan; the Lloyd Crossing Sustainable Urban Development Plan in Portland, Oregon; Dockside Green Development in Victoria, British Columbia; and Nordhavn in Copenhagen Denmark. Washington DC’s built environment has some truly great places. Let's show the world that the District of Columbia still has that capacity for greatness!
We are concerned that the conditions for development on the site in the existing term-sheet advocated by the Mayor give away development rights to the Commanders Corp with little regard for when housing and commercial development serving the neighborhood will occur. The Sierra Club wishes to highlight that the argument made for a stadium as a necessary anchor for economic development is phony and misleading. Kingman Terrace and Hill East are already mature neighborhoods, home to families that have lived in DC for generations. What they require is neighborhood-scale commercial development to serve current residents. A priority for DC should be new affordable residential development. Since this is precisely the reason for an “anchor” development - such as the stadium as described by the Mayor, a timeframe for residential and commercial development should be prescribed in legislation along-side any negotiation of large-scale benefit packages to the Commanders Corp.
We offer the following environmental sustainability standards as necessary for minimum development goals on the RFK site.
Development on the RFK site must protect Anacostia River water quality, both during construction and after. Runoff from the land is the leading source of water pollution in the Anacostia. The terms of the transfer of RFK from the Federal government to the District acknowledge the ecological sensitivity of the site to Anacostia River water quality by preserving a 32-acre buffer strip along the shore of Kingman Lake. All runoff from development on the RFK site needs to be captured and retained on site. This shouldn’t be a problem with some 43 acres of open space – but not all open space is equal. The crumb rubber used in artificial turf pollutes waterways and is toxic to wildlife.
- All stormwater runoff must be managed on site, implementing best practices for low-impact development.
- Anacostia River water quality should be protected from runoff contamination through construction of natural buffers along the river banks of no less than 60 feet measured from the water’s edge at high tide.
- Permeable pavement should be used whenever pavement is necessary, and impervious surfaces in the flood plain should be removed.
- Building materials on the site must be non-toxic. Any use of toxic materials at the site (e.g.pesticides, petroleum-based chemicals) should not be allowed to contaminate the soil on the site or to otherwise be introduced into the natural environment.
- Water fixtures and faucets should be high efficiency and designed for conservation.
The RFK site should be highly energy efficient and must not burn fossil fuels for heat or power. The District has robust climate commitments, which include eliminating all climate pollution by 2045, the DC government eliminating climate pollution in its own operations by 2040, and requiring all newly constructed buildings to be free of fossil fuels by 2027. Mayor Bowser even flew to Dubai in 2023 to trumpet her Carbon Free DC plan, which calls for eliminating fossil fuels from new buildings and gradually transitioning existing buildings off fossil fuels.
Despite these laudable commitments and pledges, DC is continuing to include fossil fuel combustion in new buildings the DC government is helping develop. For instance, the Walter Reed redevelopment and the St. Elizabeth’s redevelopment both include fossil fuel burning power plants that can provide heating during the winter. These combined heat and power (CHP) plants are sometimes labeled “microgrids” by fossil fuel business interests because they think calling them microgrids sounds better than admitting what they really are: small local power plants that spew climate pollution and health-harming pollutants like nitrogen oxides, particulate matter, and carbon monoxide. These pollutants in the air DC residents breathe reduce lung function and worsen asthma; are linked to heart attacks, strokes, lung cancer, and premature death; and reduce oxygen delivery in the body.
It is time for DC to stop repeating the mistakes of the past. We ask the DC Council to legally mandate, without exception nor any process for exemption, that all development on the RFK site be energy efficient, powered by 100% clean energy, and burn no fossil fuels on-site. The RFK legislation should state that any party developing buildings at the site construct those buildings to burn no fossil fuels for heat or power, and that if that requirement is violated, the party automatically relinquishes its right to build on the land.
The prohibition on fossil fuels on the RFK site must be ironclad, with no exemption process. Already this year, when DC taxpayers gave $515 million to the billionaire whose sports teams play in the Capital One Arena, the executive branch exempted the arena from statutory energy efficiency standards and prohibitions on fossil fuel burning in laws Mayor Bowser herself had signed. If there is an exemption process for energy efficiency and clean energy requirements in the RFK legislation, we have little doubt DC taxpayers will again subsidize dirty energy for a billionaire at the behest of the executive branch. The RFK legislation should require that all new buildings at the site are forward-looking models of green infrastructure that are fully aligned with DC’s clean energy commitments and specifically should ensure that:
- All buildings on the site are energy efficient, maximize renewable energy generation, and burn no fossil fuels for heat, power, or any other purpose;
- The RFK site deploys geothermal, waste heat, and sewage heat pumps to the maximum extent feasible, with all other heating needs met with air-source heat pumps;
- Fossil fuel and combustion heat and power systems are prohibited by law without exception;
- Inefficient electric resistance heating is allowed only in rare cases where heat pumps are not feasible; and
- The RFK site powers its own electricity needs by solar energy to the maximum extent feasible, and otherwise relies on electricity from the local grid, which is moving toward 100% renewable sources.
The RFK site should be designed to enhance the District’s capacity for flood control. Protect residents, businesses and downstream areas from flooding by prohibiting residential and commercial structures from the 100 year floodplain. Parts of DC already experience inland flooding from heavy storms. At a minimum, the RFK campus should not contribute to flooding potential, but ideally it should contribute to effective downstream flood prevention along the Anacostia River. This should be a site design priority. Climate change is already resulting in heavier rainfalls and increased flooding. Based on an examination of the current 100-year floodplain map, only about 60 acres of the 174 acre site is above the floodplain. Basically, that is the area where the stadium is currently located, street frontage along Oklahoma Avenue, Independence Avenue, and C Street, and the area adjacent to Eastern High School.
- There must be no development of residential or commercial structures within the 100 year floodplain.
- Any structures built within the 100 year floodplain, as of 2025, should not impede the movement of floodwaters in the floodplain.
- The 100 year floodplain should be preserved to manage extreme storm events on the river and help prevent flooding downstream.
The Anacostia River corridor is important for wildlife and habitat, and these natural areas should be protected and restored. Thirty percent of the RFK campus is to be dedicated to parks and open space – not counting the 32 acres preserved for riparian buffers along Kingman Lake. It is expected that much of this area will remain as playing fields – which are wildly popular and heavily used by the community. However, the city has made a substantial commitment to restoring habitat on Kingman Island, which is designated as a State Conservation Area and park. Currently, the access point to the park is obscured by the playing fields. There is an opportunity to enhance the Kingman park with well-designed ecological habitat on the RFK side of the bridge leading to the park. This would not only enhance the park, but would also enhance the wildlife habitat protected in the park. Buildings on the RFK site should prevent unnecessary bird deaths and follow regulations laid out in DC Law 24-337, The Migratory Local Wildlife Protection Act of 2022. According to the US Fish and Wildlife Service, every year more than 1 billion birds collide with glass in the U.S. alone, and most of them die from their injuries. Bird populations are declining worldwide, and North America has lost nearly 1 out of 4 birds since 1970. The glass facade of the Minnesota Vikings Stadium is known to kill more than 100 birds per year, and that figure includes only the birds that are found at the site (American Bird Conservancy study), not injured birds that die elsewhere. Through a variety of techniques, glass can be made visible to birds, preventing bird collisions.
- The buffer edge along the river must be planted and maintained with indigenous plants suitable for local wildlife habitat.
- The natural areas along the river’s edge (riparian zone) should be managed in conjunction with DC DOEE, as habitat for wildlife consistent with the District’s Wildlife Action Plan.
- The Kingman Island natural area must be integrated into the Anacostia riparian zone such that habitat on the islands and along the river’s edge is coterminous.
- Buildings on the RFK site should incorporate bird-friendly window glass to avoid preventable bird deaths as prescribed by DC Law.
The development of the RFK site should be a state-of-the-art model of zero waste practices. Because stadiums are massive waste generators, this can only happen if the District requires any commercial sports venue on the RFK site to adopt enforceable waste prevention and reduction measures as outlined below. The average National Football League (NFL) game generates 80,000 pounds of trash, much of it single-use plastic and food waste. Between games and concerts, a newly built RFK stadium would generate enough plastic cup waste to fill two and a half football fields with plastic cups each and every year.
Zero waste measures have been implemented in other sports venues, including by members of the Green Sports Alliance, and created green jobs. For example, Coors Field in Denver, CO provides reusable cups, which are supplied by the same company that already provides reusable cups at four District music venues–and also built a shared wash hub in Denver used by other reusable food ware businesses. The Atlanta Mercedes Benz Stadium is certified to achieve 90 percent waste diversion through measures including composting (1.78 million pounds) and food donation (83.2 thousand pounds or 100,000 meals donated).
Instead of RFK becoming a veritable pipeline of single-use trash from the stadium to the local neighborhood and Anacostia River, it could be the site of a shared wash hub to grow other reusable foodware businesses in the District. Development on the site should be aligned with DC’s Zero Waste, Sustainable DC and Carbon Free DC plans to reduce per capita waste generation and divert 80 percent of our waste from landfill and incineration.
- Cut toxic plastic pollution by requiring drinks be sold in reusable cups, allowing refillable water bottles onsite, and providing water bottle refill stations.
- Minimize food waste through a food recovery and composting program.
- Prioritize recycled and recyclable building materials for new construction on the RFK site.
We also take the opportunity of this hearing to flag that the demolition of the existing stadium should comply with the District Green Construction Code requirement for 50 percent reuse or recycling for commercial demolition projects. We request this Committee to act to ensure compliance. In addition, should Council approve a new stadium but not require all drinks to be sold in reusable cups, we will call on the council to amend the introduced Recycling Refunds and Litter Reduction Amendment Act of 2025 to require all commercial sports venues selling beverages in bottles and cans to take containers back and offer customers their deposit refunds.
Transportation design for RFK should limit parking and prioritize safe, equitable transit, cycling, and pedestrian access. According to DC’s Multimodal Long-Range Transportation Plan—also known as moveDC—transportation is the District’s second-largest source of greenhouse gas emissions, accounting for 21%. Achieving our legally mandated climate goals, improving air quality, and protecting public health will require shifting more trips away from single-occupancy vehicles and ensuring that vehicle travel, including transit, is powered by clean energy. All development in the District—especially one as consequential as RFK—must reflect these priorities.
Unfortunately, the original stadium deal announced in April proposed wasteful spending of taxpayer funds on parking, with no parking sales tax or fee revenue returning to the District—and no investments in Metro. We recognize that some parking will be necessary, and the updated deal announced five days ago includes some improvements: a share of parking sales tax and revenue would now go to the District, and Metro funding is included over 30 years. But these changes still fall far short. We remain especially concerned about the proposed 8,000 parking spaces. Excess parking encourages driving, which increases traffic congestion, air pollution, and climate emissions.
RFK is one of the most accessible potential NFL stadium sites by non-car modes. The deal must better reflect that. The following transportation standards should be included in any development on the site:
- On-site parking should be minimal. Instead, before opening day, investments must ensure Metro can fully serve the entire site and meet the needs of future residents, visitors, and businesses.
- Metrorail should be equipped to move the majority of event attendees—including those parking at other stations and transferring to Metro—potentially by adding a new station.
- Public education campaigns should promote non-car travel to and from the site. Incentives, such as free Metro or Capital Bikeshare rides with ticket purchases, should be considered and studied.
- Frequent and electrified transit service to the site must be planned to replace the DC Streetcar, which is slated for elimination.
- Best practices for “Complete Streets” design should be applied to prioritize expanding and improving bicycle infrastructure and ensuring pedestrian-friendly circulation throughout the site.
- The site should include ample bike racks, bike valets, and Capital Bikeshare stations to support and encourage cycling.
- All parking provided on the site must, at a minimum, comply with the requirements for EV-installed and EV-ready spaces as outlined in the recently enacted electric vehicle charging law.
- In addition to sales tax, parking fee revenue should be collected at all times—not just on non-stadium-event days—and reinvested in transit, bike, and pedestrian infrastructure within and around the site.
Development at RFK should prioritize services to residents of the surrounding neighborhoods, and their input to design should be accorded great weight.
- Hill East and Kingman Park are mature communities whose needs and opinions on development should be given great weight.
- Amenities should be conveniently located on the RFK site that serve residents of the adjoining communities such as shopping, entertainment, and attractive and accessible open space.
- The design of any and all development on the RFK site should be undertaken with utmost concern for community environmental health and at minimum be certified as LEAD for Communities.
The environmental sustainability standards specified above should be incorporated into legislation permitting development on the RFK site to guide a balance of environmental, economic, and social goals to make the development a world class model of sustainable development, and a healthy home for the people and wildlife who live there. If the RFK legislation does not reflect these principles, the Sierra Club will urge Councilmembers to vote “no.”
These following innovative projects are attracting a lot of attention and are illustrative of developments incorporating environmental sustainability standards. A project in Portland, Oregon, called the Lloyd Crossing Sustainable Urban Development Plan, is creating a neighborhood that is environmentally friendly with features like green roofs to reduce stormwater runoff and keep buildings cool, and a system of interconnected parks and green spaces to encourage walking and biking. The Eastern Neighborhoods Plan in San Francisco is revitalizing several neighborhoods with a focus on affordable housing, green spaces, and sustainable transportation. They are creating pedestrian-friendly streets with bike lanes and building parks that help manage stormwater runoff. The Navy Yard project in Philadelphia transformed an old industrial area into a vibrant, mixed-use space that elevates sustainability features such as widespread and connected green spaces, walking and biking paths, and a microgrid using renewable energy. Assembly Row in Somerville, Massachusetts is a mixed-use development built on a former Ford assembly plant site. They have incorporated green spaces, pedestrian-friendly areas, and public transportation access as foundational to a sustainable and livable community. British Columbia has a couple notable developments. Dockside Green development in Victoria is a neighborhood designed for sustainability with green roofs, solar panels, and an on-site wastewater system that reuses water for things like flushing toilets and watering plants. Another notable example is in Vancouver, British Columbia, which has a system that extracts heat from treated wastewater to provide heating and hot water to buildings in the city. Oslo, Norway, is another example of the use of heat pumps to extract heat from sewage and supply it to the district heating network. The Oslo system uses heat pumps to extract heat from the sewage, which is then used to warm up clean water, which is circulated through pipes to heat buildings in the city. Oslo's heat pumps have a COP (Coefficient of Performance, the ratio of heat produced compared to the electricity used to run the pump) of around 3, meaning they produce about 3 units of heat for every 1 unit of electricity consumed. The Nordhavn project in Copenhagen, Denmark is a whole new city district built on an old industrial harbor. They are creating floating gardens that help clean the water and provide habitat for wildlife. They are also using water-based cooling systems to reduce energy consumption in buildings.
The Sustainable DC 2.0 Plan tailors many of the innovative green ideas highlighted above to the District’s needs, has many components that are relevant to the redevelopment of the RFK campus; and should be viewed as general guidance. The Plan states that riparian zones and floodplains (which constitute more than half the RFK site) should contribute to DC’s goals for adding wetlands, protecting aquatic species and constructing living shorelines. An action to “incorporate nature into the places we live, play, and work, to reduce stress and improve health—known as biophilic design” encompasses several goals to improve public health, advance environmental education, and protect native animal and plant habitat. The Plan includes an action to: “Develop and implement an Anacostia River remediation work plan that restores fish and wildlife habitat while improving public access to the river.” Also important to any new development of the scale of RFK is the guidance to: “Incorporate neighborhood-scale stormwater collection into large-scale planning efforts early in the redevelopment process, including public right of way and parks.” and “Install and maintain four million new square feet of green roof.” RFK legislation should require the Commanders or any developers on the site to tailor a specific sustainability plan, meeting our environmental sustainability standards and subject to public comment, prior to approval of a new stadium or any development at RFK.
Today, our testimony to the Committee highlighted the need to center development at the RFK site on sound environmental planning practice to advance the District’s goals for environmental sustainability. Regardless of what is developed at RFK, our public investment needs to exemplify DC’s highest aspirations for green building, clean energy, ecological protection, natural open-space public amenities and zero waste. The RFK redevelopment is an opportunity for DC to shine green design. We should allow no less than the legislated statutes and aspirational goals already affirmed by the DC Council and Mayor, but should strive for the principles we’ve presented in the environmental sustainability standards for RFK. Thank you.