The deal to bring the Washington Commanders back to the RFK site is valued at about $3.7 billion, with D.C. investing about $1 billion. The city says the RFK stadium won’t get a gas-fired power plant, but it may need “limited natural gas” for kitchen appliances and heating in its early years. Under D.C. law, even that takes an exemption, and a city official says the team plans to ask for one “in the coming weeks.”
Big money, meet the fine print.
Here’s the short version. D.C. law bars burning fuel on site for a building’s thermal energy in buildings the city owns or helps finance. An exemption is possible, but it runs through an advisory panel and lands with an agency that reports to the mayor. And the current mayor leaves office in January.
What the law says
There’s no single law called the gas ban. It’s two 2022 laws working together. The Clean Energy DC Building Code Amendment Act set a net-zero energy standard that says “on-site fuel combustion shall not be permitted for the provision of thermal energy to the building.” The law carves out backup power for certain buildings essential to public health and safety.
The second law, the Greener Government Buildings Amendment Act, applied that standard to city projects. It covers new buildings and major renovations the District owns and projects where at least 15 percent of the cost is District-financed. The records don’t spell out whether the RFK stadium formally meets that test. The 51st, which reported the exemption plan, treats the law as applying to the project.
How an exemption works
The law gives the call to the mayor, who “may, in unusual circumstances and only upon a showing of good cause, grant an exemption” if meeting the standard is impractical or a hardship, if compliance wouldn’t serve the public interest, or for other compelling reasons set by rule. The applicant has to show the hardship or infeasibility.
In practice, a mayor’s order hands that power to the director of the Department of Energy and Environment. First, though, the applicant pitches the Green Building Advisory Council in a public meeting: up to 10 minutes to present, then questions and public comment. The council votes and sends a recommendation to the director, who decides in writing. Its guidelines say it won’t recommend an exemption “based on financial hardship alone,” and it can recommend a partial one.
Who’s on it? The law sets 15 members: five agency directors or their designees, including the buildings director, six people the mayor appoints from the private and nonprofit sectors, and four picked by Council committee chairs. The energy department’s director chairs it.
If that sounds like a lot of steps, you’d be right. The agency that decides answers to the mayor, and so does the official managing the stadium. That’s Department of Buildings director Brian Hanlon, whom The 51st describes as the mayor’s pick to manage the project. That’s the political wrinkle: the call sits with whoever holds the mayor’s office when the request lands.
The precedent
The city has been here before. Capital One Arena’s renovation got some exemptions from the same law and was denied others, according to The 51st. At an October 2025 meeting, the advisory council voted unanimously to recommend denying part of the arena’s request, including its ask on on-site combustion. Linda Toth, a member of the advisory council, told The 51st the arena case mainly involved keeping existing gas appliances, while RFK would mean new gas facilities.
What each side says
Hanlon told a Sept. 30 Council oversight hearing that a gas plant is “not under consideration,” though he acknowledged the city listed gas among possible power options when it sought proposals. Pepco’s nearby substation can’t fully power the stadium without on-site generation, he said. “There is going to be a gap.” He suggested gas might serve as backup, which The 51st reports the NFL requires of Super Bowl hosts.
Council Chairman Phil Mendelson called a request “premature” before the city’s energy master plan is done. “Why would they go to GBAC now and ask for an exemption when they don’t know if they need one?” he asked.
Ward 6 Councilmember Charles Allen says the team is overestimating its power needs and pointed to the Buffalo Bills’ stadium, which uses roughly half as much. Mark Rodeffer of the D.C. Sierra Club said a plant would “pollute their air.”
The team didn’t respond to The 51st. In a statement to FOX 5 on Oct. 21, a spokesperson said the Commanders are focused on making the stadium “as efficient and sustainable as possible,” and pointed to the NFL’s first ice thermal energy storage system and the most on-building solar of any current NFL stadium.
About those numbers
Stats 101: a comparison is only as good as its match. One other stadium using half the power is a fair question to ask, and the reporting we reviewed doesn’t say how the two buildings line up. The same goes the other way: in that reporting, nobody has put a public figure on Hanlon’s “gap,” and the team’s solar and ice storage claims come without numbers. Everyone has an argument. Nobody has shown the spreadsheet yet.
What comes next for the RFK stadium
Mayor Muriel Bowser’s last day in office is Jan. 2, 2027. Toth told The 51st it would be “pretty unfair to the incoming mayor to inherit major decisions like this.” No decision date has been announced.
The team is aiming to open the 2030 season. The RFK stadium request wasn’t on the advisory council’s Oct. 14 agenda. Its next regularly scheduled meeting is Dec. 2.


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