Secretary Haaland,

We appeal to you as the defender of our public lands to intervene in a case of public engagement gone horribly wrong which is now threatening over 1,200 trees—including approximately 237 Heritage trees—in our National Park system and the wildlife that depend on it.

Rock Creek Park golf course concessionaire National Links Trust engaged its wealthy donors but few others in the redesign of the golf course. Then, the general public was asked to provide input on two scenarios—doing nothing or the full bells and whistles proposed plan—with no understanding of their environmental impact. For example, the extensive tree removal was not mentioned at all in the public engagement by the National Park Service of January 2023 or July 2023. Instead, the materials presented by the National Park Service touted “environmental sustainability” as one of the project’s goals. 

Once the extent of the tree removal was presented in the Environmental Assessment in the fall of 2023, over 3,000 members of the public sent comments to the National Park Service, including most of the environmental organizations of the DC region.

The National Park Service then made only minor changes to the plan, notably increasing the number of trees to be removed to 1,364 and issued a Finding of No Significant Impact (“FONSI”) on April 17.

The FONSI is factually incorrect and fails to comply with the law in several places.

Upper Rock Creek Park is a singularly inappropriate location for an illuminated golf course or an illuminated driving range, and the proposed artificial lighting system is categorically ineligible for “Dark-Sky Approval” – contrary to the representations made by the Park Service in its FONSI).
The Park Service’s FONSI is legally defective because it fails to consider alternatives to the “Proposed Action.” NEPA requires that – in the case of every proposed agency action - Environmental Assessments and FONSIs must contain a thorough evaluation of alternatives to am agency’s preferred configuration. Klickitat County v. Columbia River Gorge Comm'n, 770 F. Supp. 1419, 1430 (E.D.Wa. 1991); Friends of Congaree Swamp v. FHWA, 2011 U.S. Dist. LEXIS 45925 (D.S.C. 2011). In this case, however, NPS gave short (no) shrift to any alternative project configuration that did not include an illuminated golf course and an illuminated driving range.

At the same time that Rock Creek Park, through its affiliate Rock Creek Conservancy, is being awarded $1 million in federal funds to promote forest resilience as part of the Inflation Reduction Act, how is it justifiable for the Federal Government to approve the clear-cutting of over 1,200 trees in that same national park?

At a time when our Federal Government is spending tens of billions of dollars to remove carbon from the atmosphere and fight the worst effects of climate change, like the burning of our forests and the increase in heat islands in our cities, how is it justifiable to cut down massive carbon- absorbing trees in our urban forests?

Our forests are increasingly under threat due to climate change. The concessions under the purview of our National Park Service should not be allowed to make this situation worse.

Please use your authority to withdraw the FONSI and direct the National Park Service to not approve the project and consider a more environmentally sensitive rehabilitation of the course that removes significantly fewer trees, does not contemplate artificial lighting, and preserves this historic course as a place of natural wonder, a safe haven for wildlife, and a place for recreation and enjoyment for all.