Councilmember Gregor appeals to federal and state agencies to save Morley Field

"...it remains our sincere hope that RIDEM and NPS will right this wrong ... [and] address the significant and permanent adverse impacts [of this] manifest environmental injustice..."

Pawtucket City Councilmember Clovis Gregor, who represents Ward 5, sent a letter objecting to the process being used by the Administration of Mayor Donald Grebien to pave Morley Field into a parking lot in service of out-of-state business interests. Morley Field is the only greenspace in Pawtucket's Woodlawn neighborhood. The Woodlawn neighborhood (which is just north of Providence, along I-95, west of Pawtucket Avenue) is approximately 74% people of color, 59% people living at or below the poverty rate, and 29% are children. Woodlawn is a working-class neighborhood where most people live in triple-deckers or multifamily units, often with no backyard. Since the 1970s, families in Woodlawn have used Morley Field for little league games, Pop Warner football, picnics, and reunions, and as a place to relax and breathe. For the families who live in the Woodlawn neighborhood of Pawtucket, Morley Field is an invaluable green space and escape from the densely populated corner of the city. Morley Field is also a rare public access point to the Moshassuck River and home to nesting osprey protected by the Migratory Bird Treaty Act.

Morley Field was built, in part, by federal funds from the National Park Service (NPS), which manages the Land and Water Conservation Fund (LWCF). Under federal law, greenspace created with LWCF funding can only be sold or converted if the local municipality provides new greenspace for the community of equal or greater size and value. The NPS relies on the expertise of state-level departments of environmental management to help navigate these decisions. Therefore, Councilmember Gregor addressed his letter to LWCF Chief State Liason Officer Megan DiPrete, Rhode Island Department of Environmental Management (RIDEM) Director Terrence Gray, NPS Regional Director Gay Vietzke, NPS Manager of State and Local Assistance Programs and Compliance Mary Morrison, and NPS Manager of Conservation and Recreation Assistance Collective Helen Mahan.

Here's the letter, edited for clarity (and to avoid some of the legal terminology used):

“In my capacity as Representative City Councilor for Pawtucket's District 5, Woodlawn/Oakhill, and on behalf of my constituents and the most affected residents of the City of Pawtucket, I am respectfully requesting that RIDEM, LWCF, and NPS promptly suspend and rescind the Morley Field conversion application.

“The application was prematurely and improperly submitted by the City of Pawtucket's Administration in violation of the City's Charter and prescribed governing authority. More specifically as to Morley Field, your attention is directed to a City Council Resolution approved on 10/20/2022. Paragraph number four of the Resolution specifically and categorically requires the collective City Council's review and approval, as well as an opportunity for public comment, before any conversion plan is submitted for RIDEM and NPS review and consideration. [Despite this resolution], the City Council was not, at any time to date, presented with nor did it review, consider, or approve any conversion application. The Council was [not] noticed that a conversion plan had been readied and submitted by the Administration. Equally egregious [is that at] no time before submission were city residents and the most affected public ever provided notice or an opportunity for review, active participation, or public comment.

“In light of the extremely controversial nature of this proposal and the extensive, long-standing public outcry and opposition [to the conversion of Morley Field], the pre-submission process was not only warranted but specifically required by the City Council's authorizing Resolution. Hence, the integrity of the process was not only ignored but perverted. From its inception, the proposal to expropriate this most vulnerable environmental justice community's only remaining public recreational greenspace and convert it into a parking lot for private use has been grossly mismanaged and less than transparent. It has been mostly manipulated and fraught with public misinformation, omissions, misrepresentations, and outright untruths. It, however, cannot be negated that there are significant, timely, and relevant to-the-moment issues touching on social and greenspace equity, recreational resource disparities, and historically targeted disinvestments and marginalization of a community comprised mostly of low-income people of color. Therefore, an open and transparent process is vital. Without it, the public's trust in its government, as well as in the fairness, credibility, and merits of the proposed conversion plan cannot be achieved. To do otherwise would undermine the City Council's legislative role and governing authority as well as demonstrate a deliberate contempt for the integrity of our Charter and form of government. Thus, proper vetting, deliberation, and informed consideration before application submission as specifically delineated and required by the attached Resolution, is critical - both from the collective City Council body as well as from the residents of Pawtucket. Again, in the proposed conversion for Morley Field, the most crucial prerequisite and predicated requirement has not been met.”

The letter also addresses other properties in Pawtucket that were included in this LWCF application. Councilmember Gregor addresses this in the following paragraph, before returning to Morley Field. According to Councilmember Gregor, Pawtucket's Grebien Administration has violated LWCF land agreements with the NPS at least twice previously. You can read more about that here: Pawtucket residents uncover decades of potential land-use violations by city.

Councilmember Gregor continues:

“As to the other listed LWCF-assisted sites (improperly tagged and combined with the Morley Field conversion application), please note that they are defective as having no independent legislative authorization from the City Council. To be clear, the attached Resolution only pertains to Morley Field. It does not extend the authorization for transfer or conversion consideration for other LWCF-assisted sites in the City of Pawtucket. No other conversion proposals have been presented to the Council for deliberation, consideration, or approval. As such, the Administration's inclusion of said LWCF-assisted sites in the application is entirely improper and violates our City Charter and respective governing roles and authority.

“Noteworthy and per our City Charter, the authority to sell, transfer, lease, or otherwise convey public property is vested exclusively and entirely with the City Council. There are no governing documents, legislative ordinance, or statutory authority that would allow for the Administration's suggested unilateral power to expropriate and dispose of public property without first obtaining the Council's legislative approval. It would appear that this may be nothing short of an attempt at circumventing the Council's legislative power and governing authority, while simultaneously seeking to purge itself of the various unlawful conversions already perpetuated upon the other two LWCF-assisted sites. The Administration does not possess an absolute power or unfettered entitlement to simply expropriate protected public recreational land to parcel off for private interests or dispose of as they see fit.

“As to Morley Field and in light of the above, RIDEM and/or NPS's consideration of the submitted unauthorized application must be promptly suspended and rescinded as violating the very specific Council's authorizing Resolution. As to the other two included LWCF-assisted sites, there exists no independent legislative authorization from the Council for transfer or conversion consideration. As such, RIDEM and/or NPS must similarly suspend any further consideration and promptly rescind them. To do otherwise would constitute a knowing and willful circumvention of our sovereign municipal authority and City-governing Charter. Especially, because RIDEM, the United States Department of the Interior, or the United States National Park Service retain a possessory right of title to be in a position to independently convey, transfer, or authorize a municipal conversion of an LWCF-assisted site. A specific legislative authorization from a municipal government's duly elected body with vested authority to do so would be required.

“Though it would appear that politically undue influence is being leveraged, it remains our sincere hope that RIDEM and NPS will right this wrong and that you will individually (or collectively) address the significant and permanent adverse impacts [of this] manifest environmental injustice and that this morally reprehensive and environmentally reckless proposed conversion will have upon our community. Our cherished Morley Field must serve as the quintessential poster child example of what should never be done with an LWCF-funded public recreational project. The time to act is now. Please look to this as yet another opportunity to fully reinforce Morley Field's protection as afforded under LWCF. But more specifically, unequivocally reject any proposed municipal attempt to convert the whole or any parcel thereof. Morley Field cannot be divided and must be entirely preserved just as it must never again be the subject of private commercial development consideration. The LWCF program was created under the just policy principle of social equity and the core anthem of perpetual preservation. Please let that be your guiding light.”

RIDEM recently hired a person to develop a person to develop an Environmental Justice Policy. Under that policy, RIDEM “is committed to protecting, restoring, managing, and promoting Rhode Island’s environment and natural resources to preserve and improve the quality of life of all its people. In doing so, DEM's ongoing obligation is to incorporate Environmental Justice considerations into all the Department's programs, policies, and activities, and elevate important environmental issues that have a significant impact on Environmental Justice focus areas.”

Efforts to save Morley Field, and efforts in the Port of Providence to deal with the polluting industries there are test cases for RIDEM's commitment to Environmental Justice being more than just words on a website.