Forrest Snyder: DEM should deny Pawtucket's land-use conversion of Morley Field and other green spaces

"There is no better example of environmental injustice in the state of Rhode Island than the abuses suffered by the kids using Morley Field in the Woodlawn neighborhood..."

[You can comment on the City of Pawtucket National Parks Conversion process here.]

To Whom It May Concern, 

I am writing today to explain, in simplest terms, the reasons for denying the City of Pawtucket’s recent application (10/31/2023) to the Rhode Island Department of Environmental Management (RIDEM) for land-use conversion of three Land and Water Conservation Fund (LWCF) funded active recreation sites - Morley Field (Woodlawn neighborhood), McCoy Stadium (Quality Hill), and Dunnell Park/Hank Soar Field (Prospect Heights).

There is no better example of environmental injustice in the state of Rhode Island than the abuses suffered by the kids using Morley Field in the Woodlawn neighborhood. If the powers that be in Pawtucket City Hall have their way, a once thriving community athletic facility will be paved over and used to park nearly 300 delivery trucks. The LWCF administrators at RIDEM must understand that once Morley Field and access to the Moshassuck River are gone, they are gone forever.

For decades and continuing to this day, the large majority of people making political, civic, and economic decisions about how and what Pawtucket should be are white and relatively wealthy. The kids in Ward 5, Woodlawn, where Morley Field is located, are predominantly black and brown, come from low-income households, and are disenfranchised by the racism and injustices they experience every single day. These kids struggle day in and day out to make themselves the best people they can be within the confines of a grotesquely unequal society and city. Removing the only playing field, Morley Field, from their neighborhood - over the united and absolute rejection by the residents of that neighborhood - would be a gross insult to the residents of Woodlawn and a clear indication that Pawtucket City Hall has thought of, and continues to view these people, as second-class citizens. 

Specifically addressing this current application for LWCF land-use conversion, the indisputable fact is that the City of Pawtucket does not own a property or properties that can be used to replace Morley Field (Woodlawn), McCoy Stadium (Quality Hill), and Dunnell Park/Hank Soar Field (Prospect Heights). Various parcels have been discussed, but all of them are speculation and cannot and should not be considered for LWCF active recreation replacement purposes. Unambiguously, there is not a parcel of land in public or private hands within the Woodlawn neighborhood that can replace Morley Field. Nobody, not the City, not the residents of Woodlawn, no one disputes this fact. Thus, Morley Field is irreplaceable.

The City of Pawtucket has for decades been wholly disingenuous in engaging with the citizens of Pawtucket, Rhode Island about LWCF parks and recreational fields. The violations are numerous and well-known - from not displaying the appropriate signage to failing to maintain the parks, to illegally converting parks and selling them. This long history of abuse and unauthorized activity from the City continues within this conversion application.

The City of Pawtucket appears to knowingly misrepresent itself to State and Federal Government agencies through various misstatements and factual inaccuracies. On a previous grant application to the Rhode Island Department of Environmental Management, the City Planning Department identified Morley Field as a “vacant parcel of industrial land” among other inaccuracies. In this current application, the City proposes to trade a fictitious park - “Riverside Park” as identified by the applicant - not owned by the City of Pawtucket for Morley Field (Woodlawn), McCoy Stadium (Quality Hill), and Dunnell Park/Hank Soar Field (Prospect Heights). There is no “Riverside Park” owned by the City of Pawtucket.

In addition, not only is this fictitious park in none of the neighborhoods of the existing parks but it is also located directly adjacent to an existing athletic facility, Max Read Field. Thus, the City proposes abandoning three neighborhoods in favor of a neighborhood that is already well-served. Perhaps most telling of Pawtucket’s insincerity concerning anything approaching environmental justice - the equal and fair treatment of its residents - not only is the land not owned by the City, but the parcel in question has severe deed restrictions which would have to be circumvented before any owner could use the land for any purpose other than a cemetery. 

For the Morley Field portion of the current LWCF land-use conversion application, the City states that “Pawtucket Parks and Recreation Director has reported that there have been no permit applications for any active recreation/league use since 2021 at Morley Field.” While perhaps true, the reason there have been no recreational permit applications is because the City asked all sports teams and leagues using Morley Field to move and then fenced off the field to prevent anyone from using the space. Any reasonable person understands that the number of recreational permits submitted should in no way be considered a good indicator of the need and/or actual use of recreational space.

The City then goes on to state “Current usage implies a lack of demand for a multi-use sports field”. Current usage has been severely restricted in recent years by the City plain and simple. Again, what the City has imposed on its residents without consent, does not reflect the true need or desire of the residents of Woodlawn or even the general public. The City goes on to imply that “neighborhood feedback” (without specifying the type or volume, let alone quoting the people of Woodlawn) is in favor of closing Morley Field and relocating recreational use to another part of the city. Nothing could be further from the truth. Time and time again, at every meeting, and every opportunity, the residents of Woodlawn have demonstrated unanimous support for having and using Morley Field in its entirety as an active recreational field and park.

Considering McCoy Stadium Annex in the Quality Hill neighborhood, the City ignored LWCF regulations and converted two actively used baseball fields and a soccer field (over-lapping spaces) at McCoy Annex into a parking lot and baseball stadium grandstands. The City admits as much, “...the prior loss and replacement of the two baseball fields was not done through an officially approved conversion...” These much-in-demand recreational fields were improperly replaced with a baseball field and a softball field in other neighborhoods. The kids and families of Quality Hill were never provided with similar or adequate recreational fields. Further, the City of Pawtucket failed to replace the lost soccer field. In addition, the McCoy Annex track and football field sees much use as open recreational spaces by runners, walkers, and youth football teams, as well as adult pickup soccer, flag football, and ultimate frisbee. For the City to promote another facility, Max Read Field, as an informal replacement is insincere at best. The existing track and field at Max Read Field are not adequate replacements for the McCoy Annex, given the almost exclusive use of Max Read field by the Pawtucket School System.

In the Goals section of the City’s application for land use conversion, the City has made additional errors. First, under “Goal 1. Invest in new and improved opportunities for outdoor recreation to meet the public’s need.” The City attempts to confuse the reader by somehow linking the existing use and purpose of Morley Field with that of another, Payne Park, a passive park. Morley Field was never intended or used for passive recreation. To bring up passive recreation, as a better use for Morley Field because another nearby park isn’t up to the task, only serves to obfuscate the actual need and use of Morley Field. The application at hand is for land use conversion of an active recreation site.

Furthermore, the City cites the Woodlawn Neighborhood Association as providing evidence for approving the conversion. This organization is one in name only and serves to promote the wishes and agenda of Pawtucket Mayor Donald Grebien. At every single publicly held meeting, including the one sponsored by the Woodlawn Neighborhood Association, the public in attendance has made its views abundantly clear by speaking against the loss or conversion of Morley Field. To imply otherwise is an outright attempt at deception.

Under “Goal 2. Strengthen, expand, and promote the statewide recreation network while protecting natural and cultural resources as well as adapting to a changing environment.” the City links proximity to schools as a positive reason for approving a land-use conversion. LWCF-funded sites are to be used primarily by the general public and not schools.

While on its face linking schools and parks may seem like a constructive endeavor, as far back as 1969, the Assistant Director of the Interior Department, Bureau of Outdoor Recreation, Arthur Underhill, wrote to the Rhode Island Department of Natural Resources expressing concern that Pawtucket schools not have nearly exclusive use of a public park, about what is now Max Read Field: 

We are somewhat concerned, however, that Pawtucket plans to construct a public school adjacent to the Elgasco eventually [now Max Read] Field, and that some of the facilities intended for the Field are normal adjuncts to schools. This project is being approved on the basis that it is a public use facility and it cannot be converted to be used primarily for school purposes. This point is called to your attention now to avoid any future problems in this regard.

Max Read Field is mostly used for school activities and may well violate LWCF rules. For the City to promote additional LWCF-funded recreational parks to be closely linked to schools shows, at best, a failure to comprehend the LWCF land-use conversion process. One must suspect, however, that the City lacks any understanding of the intended use of LWCF-funded active recreational fields in this regard.

Proceeding through the application, it is disappointing, but not unexpected, to find additional factual errors, intentional or otherwise:

• For Morley Field/Woodlawn neighborhood, in “Section 3.0 Resource Information, A. Environmental resources survey, Table 2, B. Mandatory Criteria, if your LWCF proposal is approved, would it... ” the City of Pawtucket erroneously states that the land-use conversion would not “Have a direct relationship to other actions with individually insignificant, but cumulatively significant, environmental effects” and in addition the conversion would not “Have a disproportionately high and adverse effect on a low income or minority populations”.

• Concerning the former, the applicant must have dismissed the impacts of converting a large grassy field adjacent to a river into a paved parking facility. Such a conversion would have exactly those kinds of impacts identified in the question. Regarding the latter, the City of Pawtucket knows and has been shown and given documentation time and time again that the Woodlawn neighborhood is composed primarily of disadvantaged people of color. To state otherwise is a lie.

On the current application, again for Morley Field in Section 3, the City of Pawtucket wrongfully checked “No” in response to “Have there been any previous NEPA/SEPA documents prepared that are relevant to this proposal or this specific site?” At least one document is known, an application for Targeted Brownfields Assessment Grant for Morley Field. This was submitted to RIDEM by Bianca Policastro, Planning Director on or about 10/22/2022. This grant application contained significant errors and was subsequently withdrawn. The City of Pawtucket should not be considered a reliable source of self-reporting of documentation.

Finally, the people of Woodlawn (Morley Field), Quality Hill (McCoy Stadium), Prospect Heights (Dunnel Park/Hank Soar Field), and the general public must be equally and fairly served by any LWCF land-use conversion. Locating similar (or even greater) recreational parks and fields outside of these neighborhoods does not serve these children and families or the general public in a fair and equal manner. LWCF land-use conversion would be detrimental to the well-being of these people. If there are benefits to the City of Pawtucket, they must be outside the purview of the LWCF land-use conversion application, and thus cannot be considered as justifications for conversion.

In summary, the application does not make the case for removing three LWCF-funded parks as a net recreational use positive for the City of Pawtucket. I challenge RIDEM to review this land-use conversion application by the City of Pawtucket to discover how or why, if granted, the conversion would be for the greater good of the residents of Woodlawn (Morley Field), Quality Hill (McCoy Annex), Prospect Heights (Dunnell Park/ Hank Soar Field), or the general public as a whole. No such justification exists.

Sincerely, 

Forrest Snyder