Testimony of John Haecker
Sierra Club DC Chapter
Agency Performance Public Oversight Hearing
District of Columbia Department of Buildings
Committee of the Whole
Council of the District of Columbia
February 12, 2026
Introduction
Sierra Club DC appreciates the opportunity to submit testimony to the DC Council for the Performance Oversight Hearing on the Department of Buildings (DOB). We have had a strong relationship with the DOB, having worked with them on net-zero building standards, building code updates, materials recycling, and other programs. In particular, the Office of Construction and Building Standards' Green Building division, responsible for regulating construction in the District that falls under the regulations of the Green Building Act, Green Construction Code, and Energy Conservation Code, has been a valuable partner in the implementation of DC climate commitments related to buildings.
This testimony focuses in large part on the redevelopment of the RFK site, including the construction and operation of Commanders’ Stadium. It also includes broader DOB issues, notably the zero waste issues of recycling and reuse of building materials as well as the move to deconstruction. We provide an introduction to the RFK issues below, followed by the zero waste building materials issues. We also appreciate that Director Hanlon previously offered to provide our contact details to the Commanders. Unfortunately, we have not received any outreach from the Commanders. We therefore request that Director Hanlon organize a meeting between the Commanders and environmental stakeholders so we may hold discussions.
RFK Redevelopment
The DC DOB has a critical role leading the redevelopment of the RFK site, managing its planning, infrastructure, and delivery. Sports fans throughout DC and the DMV are excited to see their home team play in a new state-of-the-art Commanders’ stadium. The initial renderings presented by HKS architects present a beautiful, modern facility that blends well into the city aesthetic.
However, the construction and operation of large sports stadiums has a tremendous impact on the environment in the communities where they are located, consuming vast energy resources, potentially producing large amounts of waste, and affecting storm-water runoff and related contamination into waterways. These effects can be mitigated, though, through a variety of sustainability and environmental best practices.
The RFK Campus Redevelopment Act (Act 26-150), which the DC Council passed on September 25, 2025, stipulates that the Commanders shall construct, maintain, and operate the stadium in a manner consistent with the LEED Version 5 (v5) Platinum certification of the U.S. Green Building Council. We applaud the Council for including this in the legislation, and the Commanders for pledging to it in their July 29, 2025 commitment letter. The Commanders’ commitment letter to the District also pledged that “the team’s goal is to operate at zero waste, including striving to divert all solid waste from landfill or incineration, similar to other stadiums, such as Mercedes-Benz Stadium in Atlanta.”
The LEED v5 platinum requirements include, among other things: full operational electrification, eliminating on-site fossil fuel combustion for HVAC, water heating, and cooking; the offset of 100% of a building's energy usage by either on-site or off-site renewable energy sources; a minimum 20% reduction in embodied carbon in materials compared to a baseline; and the development of a zero waste operations plan. The DOB has a crucial and instrumental role in helping to ensure the Commanders meet or exceed the LEED platinum requirements, both in the construction and operations of the new stadium. Further, the DOB can ensure that the Commanders’ zero waste commitments, as well as other sustainability best practices, are achieved.
The DC community, as well as the NFL and sports public, need a Commanders’ stadium that is not only an economically beneficial and vibrant sports venue, but also one that preserves and protects the health, environment, and climate of Washington, D.C., residents, and the larger community. New development at the RFK site should showcase best practices for healthy, sustainable development in the District that will benefit Ward 7 residents and serve all DC residents. Beyond the LEED standards, there are many important sustainability features and environmentally responsible approaches the Commanders should incorporate. These features and approaches also tend to reduce operating costs through efficient energy and water use, strengthen the team’s brand, and enhance the fan experience. The stadium should fully support DC’s vision for carbon neutrality and climate resilience by 2045. It should be a state-of-the-art, sustainable facility, and the shining star of the sports community for protecting the environment, climate, and public health.
Along with the LEED v5 Platinum requirements, the Sierra Club DC has a number of proposals to be included in the redevelopment of the RFK site to ensure protection of the environment, climate, public health, and the Anacostia River. We describe these below and include a complete list at the end of our testimony.
Clean Energy and Energy Efficiency
The stadium and the surrounding grounds will have an enormous impact on the site and on our city for generations. All buildings on the entire site, not just the stadium, can and should be from the outset powered by efficient, clean energy, with no fossil fuel combustion. The LEED standards already stated as a goal should be more than that—an integral part of planning and construction of the entire infrastructure. This will avoid costly rework at a later time, and make the entire project a model for the rest of the country of net-zero efficiency. This is an opportunity for this project to expand on net-zero efficiency, like Seattle’s new net zero stadium, but with a wider reach, covering the other entertainment venues and the housing development also envisioned.
We ask that DOB plan for all buildings on the site to be equipped with efficient electric utilities from sources like solar and geothermal power, which will provide much lower operating costs over the life of the project than fossil fuels. Incorporating clean energy will also provide measurable health benefits to our city by not adding to air pollution, and will help DC to attain its climate goals by not producing greenhouse gas emissions such as the methane that combustion produces. This is a wonderful opportunity for the DOB to build on the energy sources of the future, not those of the past.
A zero waste Commanders’ stadium
The Sierra Club District of Columbia Chapter calls on the DOB to work closely with the Commanders to design for and implement the following proven zero waste measures leading stadiums and arenas throughout the U.S. have already adopted:
Zero waste infrastructure:
- A shared wash hub at the venue (both to wash reusable cups for use at the stadium and to be used by other reusable foodware businesses operating in the District, exactly the kind of innovative economic opportunity promised by RFK supporters) (r.World, a leading reusable cup provider, builds wash hubs in economically depressed areas and hires socioeconomically disadvantaged citizens);
- A resource recovery room to facilitate source-separated collection and hauling of materials for reuse, compost, recycling, and landfill (implemented at Mercedes Benz Stadium [MBS]); and,
- Water bottle refill stations throughout the stadium (Lincoln Financial Field, Yankee Stadium).
Zero waste operations and maintenance policies and practices:
- Require all non-packaged beverages be sold in reusable cups (Arrowhead Stadium);
- Allow fans to bring their own refillable water bottles (MetLife Stadium, NYC law);
- Require food rescue and composting (MBS stadium; also required by DC law as explained below);
- Require source-separated collection of materials for reuse, compost, recycling, and landfill (multiple sports stadiums); and,
- Ensure staff collects and sorts left materials in the stands during and following each game or event (multiple MLB franchises).
LEED standards are not enough to ensure zero waste practices.
Section 6 (a)(1)(D) of Act 26-150 states that the Developer will construct and maintain the stadium “in a manner ‘feasibly consistent’ with the objective” LEED Platinum B+C and O+M certifications. Neither certification is sufficient to ensure waste prevention. Even if the stadium obtains LEED v5 Platinum certification, given the way the point system is designed, it can do so with little more than a zero waste plan consisting of basic recycling and compositing, three months of reporting on waste diversion, and a waste diversion rate as low as six percent.
Further, the Sierra Club asks this hearing to report on what actions it has taken to date to promote integration of zero waste measures into the design of the new stadium. We appreciate that Director Hanlon offered to provide our contact details to the Commanders. Unfortunately, the Commanders have never contacted us. We therefore also request that Director Hanlon organize a meeting between the Commanders and environmental stakeholders so we can hold discussions.
The Anacostia Floodplain
Sierra Club views the RFK site along the shore of Kingman Lake, which is fed by the Anacostia River, as a lynchpin in the environmental recovery of the Anacostia and its water quality. The Anacostia floodplain must play a key part. The floodplain includes all the low-lying areas adjacent to the river at the RFK site that are subject to periodic flooding. Approximately 65 percent of the 177 acre site is in the floodplain.
The Anacostia floodplain is a dynamic natural system that plays a crucial role in both the ecological health and hydrological processes of the Anacostia. Ecologically, the Anacostia floodplain supports diverse ecosystems, including wetlands, riparian forests, and unique wildlife habitats. Hydrologically, it acts as a natural sponge, temporarily storing excess water during flood events and slowly releasing it, thereby attenuating flood peaks and reducing downstream flood impacts. It also filters pollutants, improving water quality, and contributes to groundwater recharge. The RFK campus, including the commercial and residential development, can be designed, at a minimum, to not contribute to flooding potential, and ideally contribute to effective flood prevention along the Anacostia River.
Developers can use two possible approaches for the floodplain in the redevelopment of the site. One is to protect the floodplain, which prioritizes the preservation and restoration of the floodplain's natural functions to enhance its capacity for flood attenuation, thereby reducing flood risks to communities located further downstream. The other approach is to use Best Management Practices (BMPs) in developing the site to mitigate flood risks and environmental impacts through engineered solutions and careful planning. BMPs include: elevated structures to keep the lowest floors of a structure above floodwaters; flood storage to compensate for filled land; permeable surfaces and Low-Impact Development (LID), incorporating permeable pavements, rain gardens, and bioswales to reduce stormwater runoff; and setbacks and buffers, maintaining vegetated buffer zones along watercourses to allow for natural floodplain processes, filter runoff, and provide space for floodwaters.
How the DOB can help guide success
DOB Director Brian Hanlon is the appointed lead for the day-to-day management of the RFK redevelopment project, managing the planning and execution of the stadium and surrounding campus. In its role in managing permitting, ensuring regulatory compliance, and overseeing site infrastructure development, DOB can help verify consistency with the LEED v5 certification.
With its key goals to reduce greenhouse gas emissions by 50% by 2032 (towards carbon neutrality by 2050) and accelerating the transition to net-zero energy buildings, supporting the Sustainable DC 2.0 Plan and Clean Energy DC Plan, DOB can work closely with the Commanders to incorporate a range of sustainability features, BMPs, and environmental protections in the redevelopment of the site. The Sierra Club DC Chapter would welcome the opportunity to further engage with the DOB and Commanders’ leadership to share our ideas and help troubleshoot solutions.
Broader DOB Issues - Zero Waste
Tracking, verifying, reporting, and outreach
Last year, the Sierra Club raised concerns that effective enforcement of the District’s construction and demolition (C&D) reuse and recycling mandates depends on DOB having the ability to systematically collect, track, and analyze hauling receipt data. We emphasized that C&D waste represents roughly one quarter of the District’s waste stream and that compliance with the 50 percent reuse/recycling requirement in the Green and Residential Construction Codes is essential to achieving the District’s 80 percent diversion goal and reducing climate and environmental justice harms.
We respectfully request an update on progress made in several areas we previously identified:
Tracking and data systems.
Has DOB taken steps to develop or procure a searchable database or other system capable of collecting and analyzing hauling receipt data tied to specific projects and code provisions? If DOB applied for grant funding to support such a system, what is the status of that application? If no external funding was secured, has DOB identified alternative funding sources or internal budget allocations? Additionally, has DOB conducted—or determined it still needs—a feasibility assessment regarding enhanced tracking within Accela or another platform? We are particularly interested in whether DOB can now document compliance with Section 503 of the Green Construction Code and Section 327.1 of the Residential Building Code at a level more granular than a general inspection pass/fail.
Verification and compliance practices.
Have there been any changes to inspection protocols or documentation requirements to strengthen DOB’s ability to confirm that contractors are meeting reuse and recycling targets? For example, has DOB considered requiring submission of hauling receipts rather than leaving them optional upon inspector request? What current data, if any, can DOB share demonstrating compliance rates or trends since our last discussion?
Public reporting and interagency coordination.
Is DOB now collecting C&D diversion data in a format that allows for periodic public reporting? Has DOB begun sharing relevant compliance or diversion information with the Office of Waste Diversion within DPW to support broader waste reduction planning?
Outreach, education, and enforcement capacity.
In 2024, DOB acknowledged the need for improved outreach and awareness — especially among small contractors — regarding reuse and recycling requirements. What outreach, guidance materials, training, or enforcement initiatives have been implemented since then? Has DOB designated staff time or roles specifically focused on C&D compliance education and enforcement?
Strengthening enforcement and transparency in this area remains a high-impact, cost-effective opportunity to advance the District’s climate, waste diversion, and environmental justice goals. We appreciate any progress DOB has made and encourage continued investment in systems, staffing, and reporting that allow the District to verify compliance and continuously improve outcomes.
Moving beyond C&D recycling to embrace reuse through deconstruction
The zero waste hierarchy recognizes that reuse is a more effective zero waste practice than recycling. Deconstruction is a well-established practice for reuse of building materials.
Action 5 of the DC Zero Waste Plan calls for DOB (and the Department of Energy and the Environment) to update the DC Green Construction Code to require deconstruction plans for all new construction, demolition and retrofit projects beginning in 2029, and redirect materials toward affordable housing. Deconstruction is the careful dismantling of a building to recover reusable materials. What steps has DOB taken to prepare for implementation of this Action to date?
As more jurisdictions adopt deconstruction policies and material reuse programs to prevent waste generation upstream, has DOB evaluated opportunities to support or pilot similar approaches in the District, whether through incentives, guidance, or coordination with other agencies? Indeed, a growing number of jurisdictions are embracing deconstruction not only for its zero waste and climate benefits but also because it generates workforce development, including for disfavored communities, and fosters affordable housing and other community projects (e.g., bus shelters). These jurisdictions include Chicago, Hennepin County, MN, Kings County, WA, Palo Alto, Portland, San Antonio, and Savannah. Policies include deconstruction requirements for older buildings, lowering permit fees for deconstruction, increasing demolition permit fees, banning landfill disposal of readily recyclable C&D materials, implementing tax incentives, providing municipal materials sorting stations, and adopting reuse resale platforms (e.g. Michigan).
Meeting DC Code composting requirements
Composting requirements for District government agencies and facilities are spelled out in Section 8-1031.04a of the District Code. This measure requires the District government to source-separate and collect composting in line with DC code 8-1301.03 once the Department of Public Works (DPW) establishes a compost collection program, subject to funding. Based on our reading of the law, and the publicly available information on the DPW and Zero Waste DC websites, this trigger was met in 2024, when the Curbside Compost: Foodwaste Collection Program was established, following a one-year curbside collection pilot. Does DOB currently have a composting program? If not, does DOB plan to implement one? What funding or other assistance does DOB require to implement a composting program?
Lastly, we want to bring a recent issue to your attention. The Mayor just dissolved the Construction Codes Coordination Board (CCCB) and killed the pending building code update. The update process had involved approximately 6,000 hours of time devoted by members of the CCCB and their technical advisory group members. We consider this a brazen disregard for the work of the code experts, design professionals, and industry stakeholders who contributed to updating the code. Six years has now passed since the last code update. (The District is required by law to update its green building code every 3 years, and to adopt a net zero energy code by the end of 2026). On paper, the Mayor plans to start from scratch and pass a new code by the end of 2027. We do not believe that is a realistic timeline if the Mayor intends to start from scratch.
Thank you for your attention to these questions and for your commitment to effective implementation of the District’s C&D waste policies.