Please TAKE ACTION TODAY to submit written or oral testimony to the National Capital Planning Commission at their September 5 meeting during which Commissioners plan to vote on the golf course project’s final approval. Your voice is essential to save the trees at Rock Creek Park Golf Course. Below is a sample testimony with the issues most relevant to NCPC. Please personalize it and feel free to directly address any of the Commissioners.
Go to How to Comment. To testify virtually during the September 5th meeting starting at 10 am, click “Register to Speak at Meeting” by September 4th at noon. Individuals have 3 minutes; organizations have 5 minutes. To submit written comments click “Submit Written Comments” as early as possible and ideally by August 28th so your testimony will be attached to the documents sent to the Commissioners on August 30th!
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National Capital Planning Commission
Testimony regarding September 5, 2024 Action Item:
Rock Creek Park Golf Course Rehabilitation, NCPC File No. 8428
I urge Commissioners of the National Capital Planning Commission (NCPC) to vote “no” on final approval for the proposed Rock Creek Park Golf Course rehabilitation plan. While the course needs to be renovated, the proposed plan must be rejected.
The number of trees to be removed remains excessive at over 1,070 and is not justified by the “stated purpose” of rehabilitating a golf facility. In fact, most Rock Creek Park Golf Course golfers believe very few trees are in the way and do not find the shade of the trees impacts the fairways.
The proposed tree removal mitigation plan that replaces only healthy native trees over four inches in diameter is insufficient, is based on questionable data on tree condition, and falls short of NCPC’s own tree replacement procedures (Comprehensive Plan, Federal Elements/Federal Environment Element, Section FEG.2.2). Hundreds of healthy, large canopy trees that house hundreds of species will be replaced with three seedlings each that will take several decades to absorb and store as much carbon and stormwater. In the midst of a climate emergency, we cannot continue thinking of trees as fungible widgets, which NCPC should consider in allowing exceptions to the Comprehensive Plan.
No legally binding guarantees or reserve funds have been provided to ensure the promised meadow and forest restoration activities will succeed and be maintained over the span of National Links Trust (NLT)’s lease. Alarmingly, the Maintenance Reserve Account provision, which would have ensured financial resources for ongoing maintenance, was deleted from the lease agreement. This is deeply concerning because before any funds could be allocated to critical environmental stewardship, NLT is obligated to cover 1) operational costs, including fees to the privately held, for-profit golf course management giant, Troon, and 2) debt servicing for a percentage of the project’s cost estimated at $25-$35 million. Without safeguards in place, there is a serious risk that the ecological restoration and long-term sustainability of the project could be compromised.
This project is being billed as historic preservation, but the majority of the proposed work is new development that would fundamentally change the character of the site. The plan’s grandiose makeover undermines NPS’ stewardship of public lands. Economic profitability is not, has never been, nor should it be the driver of NPS' land use decision-making.
Despite NCPC’s clear directive, community engagement has continued to be primarily a sales-pitch-like effort to garner support. Although NLT/NPS’ recent submission to NCPC includes some alterations, the overall plan remains much the same and does not reflect the needs and wants of the residents of the region.
Starting from its comments on the Environmental Assessment, the public has requested alternative golf course layouts, yet none have been provided. A more modest course layout is key to environmental preservation and should have been analyzed as one of the alternatives, especially in the context of adding a driving range.
I support a more environmentally sustainable plan like the one proposed by the citizens’ coalition Rock Creek Park Golf Course for All and ask that you use your authority to direct NPS and NLT to develop a rehabilitation plan that removes invasive vegetation and reassesses trees before any non-invasive trees are cut; preserves trees of 100 inches in circumference or greater; provides a more modest course layout that preserves all but 200 trees (180 invasive trees + up to 20 non-invasive trees); excludes artificial nighttime lighting; and has binding and funded commitments to ensure environmental preservation obligations are met.
Rock Creek Park Golf Course is a unique golf course in a delicate ecosystem; transforming it into a golf course like so many others is not in the interest of the DC region. It is this golf course’s wildlife and shade that will attract visitors over the next 50 years. Let’s lead the country by example and renovate a breathtakingly beautiful recreational facility in our national park by prioritizing environmental preservation over commercialization.
Respectfully submitted,
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Additional talking points for your testimony, if needed:
Following the hottest year on record, the National Park Service has approved cutting down hundreds of iconic canopy trees, some over one hundred years old, that provide habitat for birds and other wildlife; mitigate climate change via carbon sequestration; and offer valuable shade on Rock Creek Park’s historic golf course.
Over 90% of the 3,212 people who commented to NPS about the plan are opposed to it, including a majority of golfers and the youth whom the “rehabilitation” is supposed to benefit.
We are in the midst of a climate emergency. We need all the carbon sequestration, cooling effect, stormwater retention, and wildlife habitat the natural environment of Rock Creek Park Golf Course provides. We must do everything in our power to protect our air, water, and wildlife.
Rock Creek Park Golf Course does not need to be transformed into a destination for tourists and convention-goers in order to be financially sustainable. The golf course can be renovated to display its strengths as a breathtakingly beautiful recreational facility in balance with the ecosystem of a national park.
Additionally, Commissioners representing the District of Columbia should oppose final approval of the plan because excessive tree removal undermines the District of Columbia’s Urban Tree Canopy Plan’s, which has a goal of increasing DC’s tree cover to 40% by 2032. Achieving this target “will require a sustained 25% increase in tree planting rates district-wide for the next twenty years, shared between District, Federal, and private sectors.”
The project will negatively impact several species of significant concern who call the golf course home, such as multiple species of endangered bats, and the federally endangered Hay’s Spring amphipod. 167 bird species have been identified on the golf course property. Habitats will be disrupted or destroyed by the tree removal and construction starting in November if the plan is approved.
National Links Trust, the organization that holds a 50-year management lease, plans to remove entire forest stands in order to “increase playability.” Their actions go far beyond “rehabilitation”; this plan will radically change the character of Rock Creek Park’s beloved golf course.
A 48-bay driving range structure will be illuminated until 90 minutes past sunset, disrupting nocturnal wildlife in a national park that otherwise goes dark at twilight.
Almost 40,000 square feet of combined clubhouse and driving range area is excessive. NPS/NLT’s rehabilitation project is unnecessarily expensive and overbuilt and will potentially funnel operations revenues toward debt service that were intended for golf course maintenance. A more affordable alternative that is also more environmentally sensitive is possible.