Course correction needed for Providence's Comprehensive Plan

"We want to see major changes in this section - or else don't say that you're putting environmental justice in the comp plan. You wouldn't be."

On Monday the Providence Sustainability Commission hosted leadership from the Providence Department of Planning and Development for an update on the Comprehensive Plan, currently being drafted by the Comprehensive Plan Commission (CPC). There are two chapters of the comprehensive plan available in draft form. There’s the draft Sustainability chapter, which seems consistent with current plans around climate and environmental justice, and there’s the draft Land Use chapter, which the members of the Providence Sustainability Commission determined fell far short of the goal.

“…the land use plan is the most legally binding piece of this document. As it's currently written, there are parts where the draft plan is inconsistent with itself because of what you have in the land use section around industrial and the green/blue waterfront zones.,” noted Sustainability Commission Chair Julian Drix.

The following is an edited transcript of the pertinent parts of Monday’s meeting. The meeting began with a presentation about the draft Land Use chapter that was essentially the same as one presented two weeks earlier and available on video here:

Joe Mulligan [Director of Planning for the City of Providence]: Since my first day on the job, which was about a year and two weeks ago, we have been fully immersed in the comprehensive plan process… We've received a lot of good feedback and are now in the process of drafting the relevant chapters, including the one for sustainability and resiliency, as we begin to formalize the Comprehensive Plan, which stages Providence for growth while respecting its history and its unique historic fabric.

Folks might be aware that Rhode Island, over the past decade, has been 45th in the country for new housing stock per capita, and that manifests itself in pernicious ways. The other telling stat is that for the last couple of years, Providence has led the country in increasing housing costs. The two issues are related. What we're looking to do in this comprehensive plan is find opportunities to position ourselves for greater residential density in most neighborhoods and throughout growth corridors.

Committee member Chadelle Wilson sought clarity on the definition of low-, medium-, and high-density housing areas, terms the CPC is using to replace the current classification scheme of R1, R2, R3, and R4 zoning. If the proposed changes are included in the final document, R1 zoning, which covers low-density, single-family lots, will be known as “low-density.” R2 and R3, roughly, will be combined into the medium-density category and comprise areas with two- and three-family units. Apartment complexes will be considered high-density.

Joe Mulligan: In the middle of the century - the 1950s and 60s - cities were challenged in terms of their socioeconomic condition. There was increased suburbanization and an attempt to transform cities to be more suburban you started to get things like suburban shopping and mall-style retail zoning to give residents or prospective residents the sense that they didn't have to go far for the suburban lifestyle -they could have it here in the city. That's contrary to how, historically, the city had been zoned. We're going back, maybe, to the urban zoning that existed before that era.

Industrial Zoning

Tim Shea [Manages community-based projects & processes at Providence Planning & Development]: Three things that are driving our changes here. What we heard loud and clear from the public is that we want to better align our economic development goals with our public health, environmental, and climate goals and prioritize cleaner, less carbon-intensive uses.

We also wanted to clarify where we think business and industry should expand versus where residential uses should be allowed and try to define where residential uses are incompatible with industry or where a hot housing market risks crowding out certain business uses that we don't want to be crowded out.

[For example, we want to make sure that] luxury apartment building conversions of mill buildings don't crowd those maker/creative types of businesses in the Valley, preserving manufacturing hubs that provide employment today.

In the draft Land Use chapter, there are a few places where we're trying to better align our economic development goals with public health and environmental goals. In the definitions of our port industrial areas and our general industrial areas, we are now saying that we want to prioritize clean, sustainable, resilient forms of economic development...

Greg Gerritt [Sustainability Commission member]: One of the terms that people use in this case is cumulative impacts. The cumulative impacts of our industrial areas must go down rather than up. If you put more industry in there, you'll have more impact unless you have regulations that say that new businesses will be cleaner than anything else that's already there. That's how we reduce the overall pollution in the neighborhood as we continue to industrialize. I would like to see your document emphasize that the cumulative impacts on the neighborhoods that adjoin these areas do not go up.

Julian Drix: I was able to attend the CPC two weeks ago where this draft land use chapter was presented. I spoke at that meeting as an individual because we hadn't met to vote and discuss and I wasn't there representing the commission because I wasn't approved to do that.

You can see Julian Drix’s comments here:

Julian Drix: I think there's a lot in what you presented. There's a lot of alignment around housing as a major priority of the climate justice plan. Focusing on housing affordability and preventing displacement is critical and the intersection between sustainability and housing is key to reducing emissions, and a big priority of the Climate Justice Plan that prioritizes local emissions.

A lot of times emissions reductions can be worked out through these accounting schemes of emissions elsewhere counting towards local consumption. Importantly, the Climate Justice Plan prioritizes local emissions because of the environmental justice impacts of the harmful pollutants that come with carbon emissions. That has been a big focus in the Port of Providence and a major environmental justice concern. I hear some of those concerns reflected in the draft Sustainability plan. It's acknowledged and I appreciate that they're acknowledged there. The draft Sustainability chapter is great. I'm glad to see all those things in it, but,

You said the Land Use Plan is the most legally binding piece of this document. As it's currently written, there are parts where the draft plan is inconsistent with itself because of what you have in the land use section around industrial and the green/blue waterfront zones.

And the Land Use Plan is the part that matters. We studied how to integrate the Climate Justice Plan into zoning and we have a lot of things moving forward from that. But the most important parts of the Climate Justice Plan are not able to get into zoning because of what's in the current comprehensive plan. That is why these changes are necessary in the next comprehensive plan. For the rest of the Climate Justice Plan to be integrated into zoning, we have to start with the plan first. The Land Use chapter, as it currently stands, is nowhere near where it needs to be. Major changes need to be made before I would feel comfortable supporting it. I ask our colleagues on the Comprehensive Plan Committee and the Providence City Council to not support this until those changes are made.

There are some pieces in the industrial section of the Land Use Plan about potential land use conflicts between industrial areas with residential areas in particular. That's why residential is not allowed in industrial zones and why businesses need the ability to expand predictably, but we're not talking about the neighborhoods that are already next to industry. [Those residents also] need to live healthy, sustainable lives. We already have land use conflicts, from bad decisions over decades being built into our current land use.

Particularly along that Allens Avenue area, the hospitals are the most important infrastructure not just in the city but in the state in terms of things that you can only get in that one place. Right next to the hospitals, you have not just the highway, but Sprague, which has been cited by the Department of Environmental Management for multiple violations and odors. You have Narragansett Improvement Company asphalt, [which negatively impacts] quality of life and air quality in the neighborhood. You've got a pipeline that almost exploded a couple of years ago from a rupture. You've got Rhode Island Recycled Metals, which the city has a cease and desist order against right now. You have a whole host of things there that are already in conflict with the neighborhood, the community, and the hospitals.

These conflicts are already there. It's a question of which side of this conflict the city is going to come down on. Staying in the middle and saying more business as usual, more industry in these areas is completely unacceptable.

Joe Mulligan: It's a delicate balance between maintaining the underpinnings of Rhode Island and Providence's economy, finding ways to make these uses less detrimental to the health and wellbeing of the community, and charting a path for their transition to different uses and new economies. That being said, there are still some traditional business uses that need to be located somewhere and we're hesitant to eliminate that area as our industrial corridor. I think the ways they are managed and operated will be our focus in the immediate future as we are looking for ways to transition to different uses moving forward.

David Everett [City Planner]: I will add that since we're just coming out with these drafts, we want to have the opportunity to defend them and explain what our rationale is for these different policy ideas.

Joe Mulligan: This is not a final presentation. We were looking forward to the opportunity to meet with you and hear your feedback as well as additional input from the community. The expansive waterfront master planning is going to be a big learning experience for all of us and we're committed to making sure that there is similar, if not more engagement with the community throughout that process. There's no intention to do that in the dark of night [without public input].

Julian Drix: I'm hearing a lot about the ProvPort Master Plan¹. We know that our commission has a role in that, especially around the sustainability funds. If the comprehensive plan timeline is to be finished and approved by the city council sometime this fall, then the ProvPort Master Plan process will be happening after that. The public engagement periods will be happening then. I would not feel comfortable saying that we're going to defer these big-picture questions to the ProvPort Master Planning process. ProvPort is a private, independent, nonprofit entity that the public has no say over.

I understand you [Joe Mulligan] sit on the board of ProvPort [which gives us limited say], but this comp plan vision for the next 10 years is our public process chance to address these longstanding issues.

If you're serious that the plan prioritizes resiliency and centers environmental justice - this is what it means to address environmental justice. We can't just say that [identifying problems] and [maintaining] the status quo, with some minor changes would be doing justice to environmental justice. I'm asking you to hear the feedback that we are sharing with you today. We want to see major changes in this section - or else don't say that you're putting environmental justice in the comp plan. You wouldn't be.

Dwayne Keys [Future Commission Member]: You say there are economic benefits that need to be weighed against climate justice. My question is - Where's the data or documentation? What's something we can read and see that that is true? I would argue that there is money being made on one side, but the cost of healthcare, environmental cleanup, and all the other hazards [weigh against that]. We're not only not making money, we're probably paying more out for these. When you say that there are benefits, where is the data to back that up?

Joe Mulligan: I want to clarify a separation between what the land is being allowed to be used for - the type of use - versus who the current user is. We're all concerned about many of the current users, but should they go, the intent is that that area could be used by its successor in a way that has less or even no impact. We still need plans for industry that support our economy versus who's there right now doing whatever are doing.

Chandelle Wilson: Correct, and the stipulations we put into this plan will help ensure that we will be able to hold their successors to that standard. If we wait for the ProvPort Master Plan - that's just ProvPort. That has nothing to say about the people who come after them. This is our opportunity to put something on the books that says this is how the land is to be used and this is how we're looking at it for future use so coming in, businesses know that this is our expectation for doing business in this area.

Joe Mulligan: We are expanding our analysis beyond the physical boundaries of ProvPort to take a hard look at the adjacencies, including things about circulation, greening, alternate uses, and public access to the water. Julian cited the major offenders. They're there and the question is, “How long are they there and what happens [when they leave]?” The plan speaks to what it should be like, but I don't know how...

Julian Drix: The plan isn't saying what should be. I don't see anything in this Land Use chapter that says “These are the problems that are here that we don't want to see.” There's nothing that says [bad] operator should be banned. Over the past 10 years of this current plan, we've seen many “new” development proposals - either from existing entities that are there that want to expand or new ones that want to come in - that say, “We're consistent. This is zoned industrial, it is designated industrial. We are consistent with it.”

And once you have a problem player - Rhode Island Recycled Metals has been a problem player for decades - they keep operating. It's hard to get rid of them once they're there. We need to be very specific about what types of things we no longer want, how we're going to phase them out, and what types of industries are supportive of the vision. I mean, Rhode Island Recycled Metals can say they are part of the green economy, right? It says recycling right in the name.

Chandelle Wilson: It's not about changing the tide today or tomorrow, it's about making room for the tide to shift. If we don't make that room, it's never going to shift.

Joe Mulligan: That's what the sustainability section is directed at. Maybe we're not completely lined up as you say. Certain uses have diminished in recent times. You don't see it all, but there are fewer tanks with petroleum products. Many of them are over by ProvPort, so you won't notice. There are a couple of leases that have expired in the ProvPort envelope and adjacent to it. It's getting cleaner and greener all the time, but you don't necessarily notice that because the places where you smell things are still happening. A lot of the good stuff is out of sight and the bad stuff is obvious.

Julian Drix: Improvements are happening in the ProvPort area and I do want to give credit to ProvPort for the steps they've made - while we want to see more. Outside of the ProvPort footprint - that census tract - Allens Ave, the hospitals, 95, 195, all the way down to the Thurber's Ave intersection, Eddy Street - that section there is the worst in Providence and the state in terms of the National Environmental Justice Index. It scores 99%. It has worse environmental justice impacts than 99% of the rest of the country. It is a problem.

Greg Gerritt: This is a document that will follow us to 2035 and by 2035 hopefully, the world will be much changed. The world will need to eliminate a lot of emissions between now and 2035. I don't know if it goes into the comp plan, but maybe what you should put in the comp plan is that by 2035, emissions will be reduced by 30, 40, 50, or whatever percent. That would be a planning document. Emissions can be reduced in a variety of ways. Polluting industries can leave and the new industries can be cleaner.

Joe Mulligan: Isn't that explicit in the state's fossil fuel reduction plans?

Greg Gerritt: It is in Act on Climate...

Joe Mulligan: We can't exempt ourselves from state policy...

Julian Drix: State laws are consumption-based, not production-based. The Climate Justice Plan specifies production-based accounting because it's concerned with the local point sources. It's not just saying that we must reduce our consumption so our electricity generated elsewhere gets reduced, but that must we reduce the most harmful impacts locally because that's making us sick.

Greg Gerritt: And that relates right back to cumulative impacts. If the total emissions in the area go up, there’s a greater cumulative impact on the areas we're talking about. I wouldn't mind you guys putting in your document how much that reduction of emissions has to be because it's a 10-year timeline from 2025 to 2035 and this is a critical period. We need to do this and we need to say it very clearly.

Joe Mulligan: In the last week, the state of Massachusetts has instituted regulations requiring cumulative impact analysis in these situations. There's a statewide model out there as of a week ago... We can encourage something like that.

Justice Gaines [Sustainability Commission member]: There seems to be a deep focus on economic development and growth. I'm curious about where that came from, but, [in terms of] how we set up the city for the next 10 years - What are the ways that you can, in the comprehensive plan, show what sunsetting fossil fuels infrastructure in Rhode Island and Providence looks like so that even if there are legacy industries, once they are gone we make sure that the space they leave is zoned for something green, community-based, or can be rezoned into green space?

In a lot of areas you're increasing high-density residences without increasing green space and there are a lot of low-density areas, areas that are not being increased in their density, particularly Blackstone, which is kind of absurd considering how much space Blackstone has.

I'm a little confused at the lack of imagination and not using this plan to guide the city forward on a green space sustainability model first. The word “recycling” does not make something part of the green economy, let's be clear. Adding pretty language does not make something part of the green or sustainable economy. It's the practices that come with those places that matter. What are the ways that sunsetting these industries that are not useful to our city - and not useful to the health of the people - can be built into the plan?

Joe Mulligan: I don't want us to lose sight of what we think is a pretty serious pivot in the language in this chapter around business and industrial areas. Previously, it said that water-dependent economic development goes in the Port, whereas now, we're clearly saying we want to prioritize clean, sustainable, resilient economic development. We're referencing what we've heard from community members. We're referencing what we see as the opportunities in economic development which are in the green and blue economy.

And while I think it's fair to say that the Comp Plan is setting the vision - and some of that language may feel kind of fluffy and non-specific - we see it as us setting the vision and maybe the ProvPort Master Plan gets specific parcel by parcel and says, “This use here is what we want to transition out but we've set the broad picture as clean, sustainable, and resilient.” ... There are a lot of ways that it could be implemented, but I don't want us to lose sight of what is a real pivot in how the city views industry on the waterfront. And I'm thinking about not only the waterfront but all the industrial areas.

Justice Gaines: It's not only the waterfront that should be part of the sustainability effort of the city. It needs to be the entire city. That is what I am having an issue with - it seems the focus is “Here's an area where we can make sure everything is green and resilient and sustainable,” but that's not built into the other parts of the industrial aspect of the land use plan. How is the land use chapter being [implemented for] the entire city?

Joe Mulligan: There are opportunities that we can avail ourselves of, one being through the ProvPort refinancing. We also have a cache of funds that will be used for acquisition and remediation that would fall under the responsibility of the city. We're eager to take on that process and will be informed by the ProvPort Master Plan as well. We should all agree that ProvPort's deep water berth is a very rare natural asset. Most cities do not have that asset. The challenge we're confronting is how are we going to use that asset. Right now it's being used in a way that is lacking as a benefit to the community.

In terms of larger greening strategies - it ties back to some of the concerns and comments about multimodal transportation as well - we have over $30 million that just arrived at the beginning of the year to be deployed for multimodal connectivity and bike lanes and additional infrastructure. That money is going to be important in how we reconceive some of these public open spaces - particularly the transit corridors - to increase room and the ability for qualified modal transportation, but also to look at ways to create green retention and catchment areas to help capture stormwater, facilitate stormwater management, and use as some modicum of filtering.

I think a good example is the Woonasquatucket Greenway project where we're eliminating a full travel lane on a major corridor and turning it into a one-way circulation. That existing travel lane is being transformed into a green ribbon that will look at the Woonasquatucket less as an industrial channel and more as a natural resource that needs to have buffering and recreational uses attached to it, including a kayak launch and additional open space.

In a city nearly 400 years old, part of the good land was snapped up. What we have for open space is what you see. Part of this plan and part of our ambitions in planning and zoning is what I'd call space mining. We've got to go in and find places that are not currently positioned for open space and greening and begin the process of transitioning them away from paved nonpermeable surfaces. The Woonasquatucket Greenway is an example where we might not have a big park that's got a soccer field and a baseball field on it but if you take it in its aggregate, it is a significant amount of greening that occurs along strategic natural assets. So it's not that attention isn't being paid to it, but the good story is that we have a pipeline of funding and we have several projects in process that will begin to address that strategy.

Chandelle Wilson: About the zoning and housing affordability issues and lack of housing stock - I grew up in Providence. I feel like we have more housing stock than we've ever had. I've seen developments go up left and right. I don't understand how people don't have access to housing and why it costs so much. I don't think the solution is mandating an increase in the zoning density of residential properties, especially in already dense neighborhoods that have precarious health outcomes. We already have poor health outcomes.

I count myself in this. I grew up on Alabama Avenue and Ashmont Street. I grew up right off of Eddy Street. I raised my kids on Public Street. I've had adverse health issues living in those neighborhoods. My children have suffered. Increasing density is not the issue and it's not the answer, especially without increasing green space and accessibility to affordable food. We can't feed ourselves, we can't afford to live in this city. That's what's pushing us out. It's giving developers tax write-offs and tax incentives to build luxury condos that our people can't afford to live in. That's what's starving us out, not that there's not enough housing in our neighborhoods. How many of these luxury apartments are sitting empty right now? It's killing me. We need to figure out a people solution to the problem, not a “build more” solution to the problem. There's a real people solution and this proposal isn't it. When I first read the proposal, I was upset and afraid because some of this proposal feels like a recipe for unhealthy communities.

Doug Victor [Providence resident]: I live on Princeton Avenue in the Elmwood neighborhood and chair a neighborhood organization. From the outset, neighborhood organizations have been asking to have a meeting with planning and development about this. What we've gotten is not a meeting where we're all sitting together at the same level, at the same table. We have gotten presentations and we've been talked at. We have not yet had a successful communication between us.

I have some problems with the use of “we” and “our” - who that includes and who that doesn't include. Would you please define that for us in the communities, especially the communities that have been underrepresented and underresourced for decades?

I want to go back to the slogans “Do no harm” and “Do no future harm.” Has this plan been looked at through the lens of racial equity? I'm talking about the 1930s when Woodrow Wilson created the situation where certain neighborhoods were redlined. We have many neighborhoods in our city that were redlined. People were not able to get housing because of race or class. Have you examined how this document may perpetuate that? Do you need help examining that? This must not continue.

The south side of the city lost so much property over the decades. We've lost incredible architecture… We're at a pivotal point in our history. This comprehensive plan can have a major impact on that as long as the wording in the plan is specific enough so it's not going to be challenged by future developers...

Dwayne Keys: Going back to housing, what role does planning play when it comes to economic mobility and helping people get out of poverty? The reality is that housing costs are going up, but wages are staying where they are. When I hear about economic development and activity, [I wonder] how that benefits the folks who can't get to these meetings. What benefit do they get out of this?

Linda Perri [Providence resident]: We desperately need industrial heat islands all along the Port. The map that we have of the Port with the growth of the Port area on Allen's Avenue is going to be changing when that land is purchased and put in for reuse and resealed. There's nothing sustainable about what's going to happen there. Nothing. It's going to increase diesel traffic and the misery index and the heat islands and the runoff and the asphalt and the health issues. There's a lot of work yet to be done in South Providence. I live there, I smell it every day

We need strong language to chart a path for health, land use, and all the improvements that are not specified in this plan. I implore you to go back to the drawing board and communicate with the people. The hell with the industrial zone. They're grandfathered in. People are going to come and go in the neighborhoods, they're going to sell their houses, new people are going to move in, they're going to adapt, they're going to inherit what's already there and they and their kids are getting sick. The hospitals should be part of the solution. They have a giant heat island down on Allens Avenue. In a perfect world, that should all be solar panels in my opinion. That should all be solar panels for another 25 years to reduce our carbon. We need to put cumulative impacts into writing.

1. As part of the 30-year tax agreement with the City of Providence, ProvPort has agreed to a Master planning process that includes greater community input (minimum of four community meetings and a public hearing before the city council). The ProvPort Master Plan process will begin after the Comprehensive Plan has been finalized. See: Improved ProvPort deal on its way to full City Council for approval