RFK plan should conserve scenery, not create a circus

The Washington DC Chapter of the Sierra Club issued this statement in regard to Events DC's proposal for redeveloping the site of RFK Stadium. The Chapter also encourages concerned members of the public to share their thoughts with Events DC via its website.


The Washington DC chapter of the Sierra Club appreciates the opportunity to review and comment on Events DC’s proposal for the RFK Stadium/Armory Campus. We oppose the proposal, as it contravenes the 1916 directive that National Parks shall “conserve the scenery and the natural and historic objects and the wildlife therein.”

For over 75 years, this stretch of Anacostia Park and the Anacostia River -- between the Arboretum and Poplar Point -- has been a dumping ground for toxic, dangerous, unsightly and otherwise undesirable land uses of every imaginable sort.  The facilities that have been dumped into this area include:
1. The Kenilworth trash dump, which accepted municipal trash from 1942 to 1968. exposed adjacent neighborhoods (Kenilworth, Parkside and Eastland Gardens) to the noises, odors and health risks that every trash dump generates.  This site remains contaminated with toxic substances.
2. The Benning Road Power Plant, which generated electricity from 1968 until 2012, exposed nearby neighborhoods (Parkside, Eastland Gardens, Langley Heights, River Terrace, and Kingman Park) to unpleasant and toxic emissions from its oil-fired generating units.  Its five towering smokestacks stood as eyesores that blighted the entire east side of our City.  This site remains contaminated with toxic substances.  A “remedial investigation” is underway.
3. The trash incinerator that operated until 1994 near Benning Road.  This facility, with its short smokestacks, spewed dioxins and toxic metal pollutants into the neighboring communities for decades.
4. The Benning Road trash transfer station.  Built on the site of the former incinerator, this facility remains a hub for diesel-power trash compactors as well as long-haul semitrailers.  It attracts vermin of various sorts (e.g., seagulls and rats).
5. The DC Jail, which was built on the west bank of the River in 1972.
6. Mayor Williams’ Formula 1 racetrack (“the Cadillac Grand Prix of Washington”), built in RFK Parking Lot 6, which was authorized for a 10-year period without any environmental review.
7. The Anacostia Freeway, a major source of ground-level air and noise pollution east of the river.
8. The Architect of the Capitol’s tree-cultivation station at Poplar Point, which became contaminated with chlorinated hydrocarbons and other toxic pesticides. This site remains contaminated.  A “remedial investigation” is underway.
9. Other facilities built along the River’s west bank have had the effect of fencing out DC residents and generating localized air and water pollution.  These include DC General Hospital and Congressional Cemetery.

As a result of these and other undesirable land uses (e.g., the Washington Gas Light superfund site near 11th St. SE, the former munitions manufacturing plant at the Navy Yard), communities along the River have been stigmatized.  Community pride has been depressed and property values lowered.  The health of residents of a half-dozen nearby neighborhoods has been jeopardized.  Harm to the Park and the River has been substantial, and the costs of remediation will run in the tens of millions of dollars, at a minimum.

These were only the projects that were constructed and operated along the River.  Then there were many other projects that the DC Government and/or federal governments attempted to construct near RFK Stadium.  In the early 1970s, the federal government began construction of an amusement park on Kingman and Heritage Island to commemorate the nation’s Bicentennial.  In the 1980s this was converted into a public-private partnership known as the “Children’s Island Amusement Park.”  A coalition of neighborhood and environmental groups successfully campaigned for 12 years to kill the project in 1997.

Then there was the Barney Circle Highway project, which called for the construction of a new interstate highway bridge near DC General Hospital.  This project was similarly challenged by neighbors working with environmentalists -- with eventual success.  Similarly, for many years the SEED School cultivated local and congressional support to build a private school on the land under RFK Parking Lot 6; it, too, died.

All of these projects -- the ones that were built and operated, as well as those which were proposed -- are manifestations of environmental injustice.  The federal and DC governments readily propose any manner of commercial or industrial enterprises to be built alongside the predominantly African-American communities that lie adjacent to Anacostia Park.  No similar facility has ever been proposed -- much less constructed -- for the parklands that line the Potomac River, even though there is plenty of undeveloped land there -- e.g., Theodore Roosevelt Island and Hains Point.

Consideration of environmental justice are not the only sound reasons for rejecting most elements of the proposed RFK redevelopment project.  The proposal also violates federal law.  The District of Columbia Stadium Act of 1957, D.C. Code §2-326, was amended by Congress in 1986.  Public Law No. 99-587 provides that the DC Government, in managing the lands that it leases from the National Park Service near RFK, may conduct or permit only activities related to recreation.

These elements also contravene the spirit of the 1916 National Park Service Organic Act, and supporting Sierra Club general policy, both of which urge that national parks – including Anacostia Park – serve as sites where nature and history are conserved and enjoyed.

The Sierra Club, under our policies regarding national park land, does concur with a few elements of Events DC’s proposal. In particular, the added green spaces and slightly reduced parking footprint would be a great asset to the area and the community at large, particularly given the river bank’s ecological importance. Similarly the proposed pedestrian bridges, as well as the RFK memorial and the urban gardens, would allow more people to enjoy the space while preserving the natural integrity of the park.

However, there are several aspects of the proposal that are in direct conflict with the Sierra Club’s goals for national parks. Most troubling, given the Club’s insistence that automobile traffic should be minimized or eliminated on parkland, is the increased motorized traffic that would result from adding a new road to the area. Additionally, the sports complex and playing fields would add noise and light pollution, both of which the Club seeks to avoid in a national park setting.

Additionally the proposal does not include any information on the steps Events DC would take to reduce pollution and waste, or promote carbon neutrality, in any new facilities. We would like more information on these critical features of the proposal, and hope you are taking these important factors into account.

We urge Events DC not to further despoil Anacostia Park, and instead to re-evaluate its proposal for the RFK stadium site with the conservationist ethos of the National Park Service Organic Act in mind. Specifically, we ask that you look into alternative methods for transporting people in and out of the area (i.e., shuttle buses instead of parking garages), and eliminating the light and noise pollution impact from any proposed roads, spectator sports complexes, or recreation fields.
 

An abridged version of this letter was sent to Events DC. Payton Chung, Jim Dougherty, and Julie Pflagler contributed text.