August 5, 2026
Brian Hanlon
Director
D.C. Department of Buildings
Mark Clouse
President
Washington Commanders
Dear Director Hanlon and Mr. Clouse:
Sierra Club is the nation’s largest environmental organization, with chapters in all 50 states and about 3,000 members in the District of Columbia. We were actively involved in the legislative process regarding the RFK redevelopment and we continue to engage in planning for the campus. Though Sierra Club helped secure some important environmental protections in the RFK Campus Redevelopment Act of 2025, this letter discusses other statutory requirements that apply to the stadium and all other development at RFK.
Under D.C. law, new District government buildings, new publicly-subsidized buildings, and newly constructed commercial buildings must all be built to a net-zero energy standard, which prohibits the on-site combustion of fossil fuels in such buildings.
The Clean Energy D.C. Building Code Amendment Act of 2022, codified at D.C. Code § 6-1453.01, states that under D.C.’s net-zero energy standard, “[o]n-site fuel combustion shall not be permitted for the provision of thermal energy to the building[.]”1 The Fiscal Year 2027 Budget Support Act of 2026, passed unanimously by the D.C. Council on second reading on July 7, makes some changes to the buildings covered by the law, but maintains the prohibition on on site fossil fuel combustion for new commercial buildings larger than 10,000 square feet.2
The Greener Government Buildings Amendment Act of 2022, codified at D.C. Code § 6- 1451.02, requires that District-owned and substantially District-financed newly constructed buildings maintain net-zero energy compliance, as defined under D.C. Code § 6-1453.01, which prohibits on-site fossil fuel combustion.3 Because the RFK redevelopment will involve substantial District ownership and financing, these statutory requirements must be incorporated into the project’s design from the outset.
The District government’s RFK PMO Energy Master Plan RFP, issued on March 13, asks for, among other elements, proposals that “[e]valuate the integration of a combined heat and power natural gas facility and the potential for phasing in future technologies to increase efficiencies and decrease reliance on natural gas.”4 A combined heat and power facility, or any other facility on the RFK campus that relies on the combustion of natural gas or any other fossil fuel, would be wholly inconsistent with the provisions of D.C. law discussed above. A facility that mixes natural gas or any other fossil fuel with a “renewable gas” or any other fossil fuel alternative is still subject to D.C. law regarding fossil fuel combustion in new buildings. D.C. law contains no provision allowing the combustion of fossil fuels in buildings where they are otherwise prohibited simply because the fossil fuels are mixed with a non-fossil fuel.
Accordingly, if the stadium or any other building on the RFK campus is designed to rely on the on-site combustion of natural gas or any other fossil fuel, it would be inconsistent with binding D.C. law. Proceeding with a design that violates these statutory requirements could expose the District and the Washington Commanders to litigation that could delay permitting, construction, or occupancy of the stadium, increasing costs and creating unnecessary uncertainty for both the District and the Commanders. These risks can be avoided by ensuring from the outset that all buildings on the RFK campus comply with D.C.’s statutory prohibition on on-site fossil fuel combustion.
Sierra Club looks forward to reviewing the proposal selected for the RFK Energy Master Plan and to working with the District and the Commanders to achieve the District’s clean energy and sustainability commitments for RFK, and to ensure that the redevelopment complies with all applicable laws. In addition, Sierra Club requests a meeting with both of you to discuss the
project’s energy plans and its compliance with the requirements of D.C. Code § 6-1451.02 and § 6-1453.01. We look forward to your response.
Sincerely,
Sari Amiel
Staff Attorney
Sierra Club
1 D.C. Code § 6–1453.01, available at https://code.dccouncil.gov/us/dc/council/code/sections/6-1453.01.
2 See D.C. Bill 26-661, available at https://lims.dccouncil.gov/downloads/LIMS/61627/Meeting3/Amendment/B26- 0661-Amendment1.pdf?Id=242559.
3 D.C. Code § 6–1451.02, available at https://code.dccouncil.gov/us/dc/council/code/sections/6-1451.02.
4 See D.C. Office of Contracting & Procurement, Contracts and Procurement Transparency Portal, Solicitation No. Doc819384, FY26-RFK PMO Energy Master Plan (closed Apr. 23, 2026), available at
https://contracts.ocp.dc.gov/solicitations/details?id=Doc819384.