FFF Asks NPS to Deny Transfer of Francis Field Land to D.C. Jurisdiction
Posted: May 16, 2023.
Thirty days after the District government and the National Park Service (NPS) announced that they were considering a transfer of jurisdiction of Francis Field parkland, the Friends of Francis Field (FFF) sent NPS a letter in opposition to the proposed transfer.
A copy of that March 23 letter is on this website in PDF format.
The NPS land in question is shown in green in the diagram at right. The striped area is the portion of Francis Field over which the District government has current jurisdiction.
The NPS portion of Francis Field is part of U.S. Reservation 360, which is also known as the Rock Creek and Potomac Parkway—and is now a historic district in addition to being a part of Rock Creek Park, a unit of the National Park System.
We provided proof in our letter that the strip of NPS land which is now a part of Francis Field was acquired under an Act of Congress in 1913, for the purpose of landscape architecture and the prevention of dumping trash into Rock Creek.
The landscape architect was Frederick Law Olmsted, Jr., who described the parkway concept in some detail in the well-known "McMillan Plan" of 1902. The park-like roadway was part of the dignified architecture designed for the National Capital, the National Mall, and the connection of Rock Creek Park to Potomac Park on the river.
Several federal laws regulating National Park land prohibit its use for purposes other than that for which it was acquired or set aside. One of these laws is the 1978 act which states that the management of NPS units "shall not be exercised in derogation of the values and purposes for which the System units have been established, except as directly and specifically provided by Congress."
DPR is on record as planning a full-size, regulation soccer pitch on Francis Field, along with an expanded dog park.
Transferring land purchased for the landscaping of the National Capital to be used for either of those purposes is not what Congress intended or stated in the Act that created the parkway.
FFF has no objection to an expanded dog park on the section of the field under current DPR jurisdiction; but we must object to replacing Olmsted's landscape architecture with a competitive sports arena.
The natural turf field is large enough to accommodate elementary and middle-school field sports, but a full-size soccer pitch for adult competition is contrary to—and would be a derogation of—the park values of the Olmsted architecture for which the land was acquired.
Several legal and regulatory steps will be required for the proposed transfer of jurisdiction to occur, including:
- NPS internal review of the D.C. government proposal
- Approval by the National Capital Planning Commission
- Legislation by the Council of the District of Columbia
- Review of that District legislation by the U.S. Congress
- Review of any resulting plans by the U.S. Commission of Fine Arts
DPR and DGS are not conservation or historic preservation agencies, and they have different purposes and values than NPS does. Preserving Francis Field's park values and leaving it in as natural a state as possible is our goal.
FFF hopes that this apparently "illegal" transfer of jurisdiction will be stopped in the NPS internal review. FFF is gathering additional documentation regarding the stewardship of the field for submission to the National Capital Planning Commission if that should become necessary.