National Park Service Decision of the Rock Creek Golf Course Rehabilitation Sidesteps Environmental Concerns

Written By Nature Forward Volunteers, Anne Cottingham and Christine Powell.

Last September the National Park Service (NPS), in cooperation with the National Links Trust, issued an Environmental Assessment (EA) evaluating the impacts of a proposed rehabilitation of the Rock Creek Park Golf Course. The RCP golf course, which opened in 1923, occupies about 100 acres in northeast Rock Creek Park and is listed in the National Register of Historic Places as a contributing resource to the Rock Creek Park Historic District. The stated purpose of the golf course restoration is quite specific: to “address deferred maintenance, increase playability, broaden course appeal to the local community, and achieve financial stability for the operation of the course.” Notably, the issuance of the EA prompted the submittal of 3,212 public comments, including a letter from Nature Forward (NF), last November. Many of the comments focused on perceived environmental concerns raised by the NPS golf course restoration plans. 

The EA analyzed two options: Alternative 1, the No Action Alternative, was used as a baseline against which to evaluate the effects of the proposed action (Alternative 2). Alternative 2 will include constructing a 9-hole par 3 golf course, a new clubhouse, a practice putting green and short game area. The maintenance facility will also be relocated. The proposal also calls for new cart paths, a nature trail, a retention pond for golf course irrigation, and lighting for night use. It would remove 1139 mature trees and create more than eleven acres of meadow habitat on abandoned golf course holes and repair or replace the water distribution and irrigation system.   

In its November 2023 comments on the restoration plan, Nature Forward expressed support for the rehabilitation of the RCP golf course in a manner that will enhance the experience of park visitors, including both golfers and other members of the public, with minimal adverse impacts. However, NF noted, the restoration plan as described in the EA lacks specificity and many of the conclusions in the EA are not well-supported. The EA does not provide the requisite “evidence and analysis” to support its conclusions, and thus does not support a finding of “no significant impact.” For that reason, NF recommended that NPS delay issuance of a final decision until additional information is made available to the public, including additional alternative proposals that could meet these goals without creating adverse environmental impacts. We continue to believe that this would be the better course of action.  

However, in late March 2024 NPS issued its long-awaited final decision on the RCP Golf Course Rehabilitation in a “Finding of No Significant Impact” (FONSI). The FONSI affirms the conclusions of the NPS’s 2023 Environmental Assessment with little additional discussion. While perhaps not surprising, this outcome is disappointing. Despite the submittal of more than 3,200 public comments reflecting various environmental concerns about the NPS golf course restoration plan, that plan remains essentially unchanged. The FONSI concludes (p. 4) that “the NPS selected alternative will result in beneficial and/or adverse impacts on several park resources, including cultural landscape and historic district, vegetation, wildlife and wildlife habitat, visitor use and experience, and adjacent communities.” Further, the FONSI concludes that Alternative 2 (the only restoration proposal presented) and its associated actions “will not have a significant effect on the quality of the human environment considering the potentially affected environment and degree of effects of the action (40 CFR 1501.3(b)(7)).” Accordingly, the NPS will not prepare an Environmental Impact Statement. (Id.). The NPS responses to the public comments on the EA are discussed in Appendix C to the FONSI. 

Nature Forward’s Environmental Concerns with the Plan 

Tree Removal: Of particular concern to Nature Forward as well as other commenters, NPS will remove 1,139 trees (approximately eight acres) from the golf course to facilitate wider fairways and accommodate the new golf course routing. NPS states that another seven acres of trees (around 1100) on the northeastern part of the course will remain intact; thus, more than 50% of the existing trees on the golf course will be removed. FONSI, pp. 5-6. To mitigate the tree removal, more than 200 native trees would be planted. The EA does not address the size or the species of trees to be cut down. Approximately 35% of these trees are described as dead or in poor condition. The other 65% will be removed for purposes of “construction” or “agronomy” (presumably to maintain adequate sunlight to the fairway grass). All trees are not equal; large mature trees provide better habitat for birds and wildlife and transpire more than small trees. Forests change and go through succession. The historic forest in Rock Creek Park in the 1920s differs markedly from the forest there today.  Planting 200 small trees falls far short of mitigating the removal of 1,139 mature trees. Further, the NPS proposal will arguably exacerbate the loss of tree cover throughout the District of Columbia by negating years of tree planting efforts by Casey Trees, NPS, and District citizens. 

Groundwater Issues: Nature Forward’s comments also suggested that NPS’s proposed use of groundwater to augment irrigation water for the golf course must include an assessment (not yet performed) of how groundwater removal would affect groundwater and wetlands both on the golf course and in the Rock Creek stream valley beyond the boundaries of the golf course. While NF supports the proposal to capture stormwater and rainfall in cisterns and in a pond for golf course irrigation, both the EA and the FONSI lack quantitative information as to how much water will be needed for irrigation of the golf course under different rainfall patterns. 

Wildlife Impacts: The EA notes the presence of wild turkeys and coyotes at the golf course but does not mention that both species breed/roost in wooded areas of the golf course. These are some of the only places in DC where these two species breed and thrive because of the brush in the wooded areas between the fairways of the golf course. The EA downplays the possible adverse effects of the project on wildlife; the FONSI states (p. 6) that forested habitat will be lost, likely displacing some wildlife such as wild turkeys. Migratory birds will have less forested habitat available, at least during course reconstruction. 

Nature Trail and Social Trail Impacts: Nature Forward applauded the NPS proposal to build a “nature trail” around the perimeter of the golf course to improve pedestrian and cyclist access to the golf course. As described in the EA, the plan does not include a walking trail that connects to the extensive network of designated park trails and paths. The FONSI describes “an ecological trail” and “a multiuse path along Joyce Road NW and up to the golf course entrance.”  (p. 8). It is not clear from this discussion whether this ecological trail could serve as a waking trail that connects to designated park trails and paths. (If a nature trail and perhaps a snack shop/restaurant are developed in the new clubhouse, some walkers along Beach Drive are likely to cut through the woods to access these. A trail connecting the golf course trail to Beach Drive other than along Joyce Road could be a useful addition.) 

Environmental Justice Impacts: Although environmental justice impacts were dismissed from further analysis due in part to a commitment from NLT to ‘keep play affordable,’ we feel that this is a laudable goal consistent with Rock Creek Park’s status as a public park with no entrance fee.  

Continued Advocacy  

Environmental advocates organized to ask the National Capital Planning Commission (NCPC) not to approve the plan submitted by the National Links Trust (NLT) and the National Park Service (NPS) to rehabilitate the Rock Creek Park Golf Course. The NCPC meeting took place on Thursday, May 2. According to the National Capital Planning Commission, “Following a public testimony period with more than 40 people providing their thoughts, and having received more than 230 public comments, the Commission approved the preliminary plans and requested that the National Park Service coordinate additional public engagement on the tree inventory, removal, and replacement plan and other environmental issues raised in the public testimony to allow time to consider any potential improvements, prior to submitting for final review”.

More than 90% of the 3,212 people who commented to NPS about the plan are vehemently opposed to it, including many golfers and the youth whom the “rehabilitation” is supposed to benefit. If allowed to go forward, the plan will affect our air quality, add strain on our entire watershed, exacerbate the urban heat island effect, and further endanger the species that rely on Rock Creek Park. 

What Can You Do?  

In a joint Action Network campaign, Nature Forward, the DC Sierra Club and other organizations encourage you to send a letter to the Secretary of the Interior Deb Haaland, to withdraw the Finding of No Significant Impact (FONSI) and direct the National Park Service to meaningfully engage the public to develop a more environmentally sensitive plan to rehabilitate this historic course preserving it as a place of natural wonder, a haven for wildlife, and a place for recreation and enjoyment for all. We also encourage residents to sign this petition.  

You can find more information on community concerns at 

A special thank you to our Nature Forward Conservation Research Volunteers, Anne Cottingham and Christine Powell for their work on the organization’s comments and this blog post.  

Download and read Nature Forward’s comments below.