Over the next couple of months, Providence’s Comprehensive Plan is likely to be finalized, approved by the City Council, and then approved by the state – and with that, the next chapter of our city’s future will have been drafted.
Those who have been following this process over the
last six months know that only parts of the Comp Plan are binding (the Future Land Use Map), and the rest contains vision language that lays out goals in the way that all strategic plans do; and that the most impactful change in the Plan is its “upzoning” of many single-family, two-family or three-family dwelling zones to three-family or multi-family zones, getting rid altogether of the two-family dwelling designation. These are significant changes and while they are words on paper now, every single neighborhood in the city will begin to change shape once the Plan is adopted in 2025.
PPS released a statement about the Plan in July Since then, our thinking has evolved and our questions and recommendations have gotten more granular.
As the City Council takes up the Comp Plan this month and holds public hearings this fall, we urge consideration of the following amendments, which we believe would make the Comp Plan more equitable, more accountable, and better aligned with Providence’s Climate Justice Plan.
People often assume that historic preservation is at odds with increased density and new housing. While we are cognizant that that has been, and can be, the case, it is important to state that PPS supports a more populous Providence and the creation of more affordable housing to address our housing crisis – the places that we fight to protect now were once new, after all.
Equity
Over the course of the last four months of this process, PPS has clearly stated concerns about how certain provisions of the Plan exacerbate spatial inequalities in the city that have been the direct result of planning – and preservation – practices over the course of the last century in Providence. We continue to advocate for further revision to the definition and list of properties and neighborhoods in the Comp Plan’s designation of “historic districts” – adding historic districts and landmarks that are listed in the National Register of Historic Places (currently, only local, city-designated historic districts and landmarks are listed). Why? The Comp Plan defines “historic districts” as “worthy of preservation” (p.67), stipulates that the City will “strictly regulate alterations and new construction in these areas,” (p.69) and differentiates them from areas of priority growth in the city’s Growth Strategy Map. This presents an equity problem because the city’s historic districts are in overwhelmingly white, resourced neighborhoods while the national districts and landmarks are more evenly distributed across the city. PPS recommends including the National Register historic districts and landmarks to the Comp Plan’s definition of “historic districts.” Not a lot of land is at stake here: according to our calculations, this would roughly double the land in the “historic district” designation from about 5-7% today to a total of 9-12% of municipal land (this does not include some of the largest undevelopable districts listed on the National Register like Roger Williams Park, Brown University and the City’s cemeteries).
Wards that contain contiguous local historic districts that are already defined as “historic districts” in the Comp Plan include Wards 1, 2, 9, 11 and 13, with a very small section of Ward 3 included. Wards that contain National Register historic districts that are not currently defined as “historic districts” in the Comp Plan that we believe would be positively impacted by this change include Wards 1, 2, 3, 4, 9, 12, 13 and 14.
Although the language used to define “historic districts” in the Comp Plan and on the Growth Strategy Map is not binding, it will undoubtedly have an impact as developers, policy-makers, and community organizations tend to reference the Plan, as one would a manual, when contentious projects are under consideration, so this designation will have material impact.
City Councilors and community members in wards where National Register historic districts are slated to be upzoned from R3 to R4 status (three-family to high-density multi-family dwellings) should be aware of the fact that these districts will likely be the site of pronounced development, which could lead to displacement of long-time neighborhood residents and legacy businesses as well as the demolition of significant buildings that reflect Providence’s rich history of immigration and working-class histories in the 19th century. These districts include the Pine Street District in Upper South Providence/Ward 11, the Broadway-Armory District in the West End/Ward 13 which covers more ground than the city’s districts on the West Side, and multiple districts in Smith Hill/Ward 12 including the Oakland Avenue, Pekin Street and Smith Hill Historic Districts. Residents and neighborhood leaders may want to consider advocating for a zoning variance in these national historic districts to keep their current zoning status in place (in comparison, most of the city’s local historic districts seem set to remain either R1, single- family dwelling zones, or to shift to R3 – but not to R4). From our perspective as preservationists who work to protect and elevate all of the city’s heritage sites, it doesn’t seem equitable to ignore the significance of these national historic districts, many of them located in less-resourced neighborhoods, in the proposed changes to the zoning map but to continue to extend more protection to more resourced neighborhoods in the City.
In June, the Planning Department responded to PPS’s recommendation to expand the Comp Plan’s definition of “historic districts” by adding 36 individual properties to the “historic district” map and removing four (p.84-85). No explanation is given as to why these particular properties were added or removed and it would be helpful to understand the analysis that led to this outcome.
History and the Problem of the Past
Comprehensive Plans are not always, by nature, reflective. They are blueprints for the future, rather than studies of the past. However, PPS believes that it is critical and reasonable to expect that a once-in-a-decade Plan like this acknowledges the many ways in which planning tools have been used to engineer more unequal cities. These tools include segregation, redlining, exclusionary zoning, and racially restrictive covenants, as well as preservation practice, which has too often prioritized protecting sites in wealthy white neighborhoods. Why is this important? Because we are living now with the planning decisions of the last few generations – they are literally baked into the city and continue to contribute to disparities in public health, economic vitality and community wellbeing. If a document like this does not acknowledge this history, it is difficult to see how it can effectively plan for a more equitable future. PPS recommends that the Comprehensive Plan include a land acknowledgment and sections or additional language that provides a capsule history of planning in Providence and explains how the changes contemplated now will address the engineered disparities that are partially the result of planning practices. Examples of how to do this effectively can be found in Brooklyn’s 2023 Comprehensive Plan and Austin’s 2023 Equity-Based Preservation Plan, which acknowledge these histories and are exceedingly clear about how they shape each community’s vision for more equitable future.
Maps
The Comp Plan contains more than 20 individual maps in the appendix – but several additional overlay maps would help community members understand the factors that led to decisions to prioritize some neighborhoods for growth over others. These include an overlay of the Land Use Map that shows the City’s public transportation networks and bicycle lanes to show how future growth relates to these networks; an overlay of the Land Use Map that shows future floodplains and stormwater flood zones to show how future growth districts respond to these new realities; an overlay of the Land Use Map that shows the City’s many surface parking lots, which the Plan suggests are prime targets for redevelopment (p.18); and an overlay of the Land Use Map with the ward boundaries drawn in to show City Councilors and community members what they can expect in their own neighborhoods. These additional overlay maps could be created easily by the Planning Department, and would allow the public to see how and whether future growth lines up with these critical factors.
Accountability and Community Input
The most recent draft of the Comp Plan opens with data about the community participation opportunities that allowed community members to offer feedback to the Plan over the course of the last year, but it does not describe how this feedback led to specific changes in the Plan as it was drafted. Given the laudable scale of the community engagement effort that was undertaken by the Planning Department during this phase, which included 80 individual events, community members deserve to see more specificity with regard to how their input shaped the final Plan. PPS believes that adding a short summary of the feedback offered and resulting changes at the end of each section of the Plan would allow community members to understand where and whether their input registered. Brooklyn’s Comprehensive Plan models this transparency and accountability, including short summaries at the end of each chapter that do just this (“What We Heard,” followed by a bulleted list of updates to their Plan that were triggered by this feedback).
Preservation, Design and Adaptive Reuse
Preservation, high-quality urban design and adaptive reuse do not receive the same level of attention in other cities’ Plans as they do in Providence’s Plan, and as a preservation organization, PPS appreciates this care and attention. This is fitting, given the role preservation and heritage play in the city’s identity and local economy, which is recognized in the Comp Plan, and the unusual age of our building stock, which makes adaptive reuse a significant sustainable building practice as we move into a lower-carbon future. PPS has always worked with the Planning Department to strengthen policies and build awareness around the City’s heritage holdings and we look forward to continuing this collaborative work in the next decade. There are many suggestions in this Plan related to preservation that are thoughtful, creative and visionary. These include establishing a “lesser regulated [local] historic district” designation for communities that are uncomfortable with the stricter standards of the current local historic districts (p.18); suggesting that institutionally-owned National Register landmark buildings or sites should be included in the City’s local historic districts, to extend further protection to them than exists now (this would impact Brown’s and RISD’s ability to demolish or significantly modify historic buildings they own); and encouraging the state to restore the historic tax credit.
As PPS has stated previously, we appreciate the City’s recommendations that adaptive reuse be “promoted” (p.18), “considered” (p.19) and “encouraged” (p.30) and that it is seen as “desirable,” (p.74) but we continue to recommend that adaptive reuse be “prioritized” in the Plan as this stronger language aligns with Providence’s Climate Justice Plan.
As PPS has stated previously, we believe that the city should establish a design review committee composed of urban designers and preservation professionals to advise on key development projects and urban design initiatives, including City-led plans, plans of a specified scale or in a National Register historic site, or projects that use City resources. Many neighborhoods in Providence already benefit from public design review by committee, including Downtown and the local historic districts on the East Side, West Side and Elmwood. Such a public design review committee would allow other less resourced neighborhoods to enjoy the benefits of additional levels of attention, care and scrutiny when significant or publicly financed projects are under consideration. Chicago’s Committee on Design and New York’s Public Design Commission provide models for how to carefully define the types of projects that come up for review to achieve a balanced approach that supports development and high-quality urban design.
PPS appreciates the work that has gone into the development of the City’s Comprehensive Plan, the resources allocated to community participation meetings over the course of more than a year, and the many opportunities that have been provided for public comment. We know and work with Planning Department staff in many different ways throughout the course of each year and appreciate the spirit and culture of public interest, as well as the deep expertise, that drives this work. PPS will continue to strongly advocate for the amendments described in this statement this fall as the Plan is finalized because we believe that they will make the Comp Plan – and by extension, the City – more equitable and sustainable, while maintaining responsible stewardship of our shared heritage.