Every ten years, the city of Providence is required to publish a Comprehensive Plan to guide zoning, planning and growth for the following decade. The last Plan was passed in 2014, and a new Plan is being written for adoption in 2024. On June 18, the City Plan Commission (CPC) meets at 4:45pm at 444 Westminster Street to vote on a final draft of the Plan (to be adopted formally, the Plan must be approved by the CPC, the City Council, and the state).
Over the last five months, PPS staff and members have followed the development of the Comprehensive Plan closely because we know that it will have lasting ramifications on the look and feel of the City, on community members’ capacity to shape planning and development decisions in their neighborhoods, and because we know that decisions made today may fuel gentrification and displacement in the years to come. Hearing from our members and partners that there was interest in gathering as a community to understand and discuss the Plan, PPS organized two conversations about it on May 30 and June 3 at our offices on Meeting Street, which were attended by about 75 people (a summary of these discussions was published in The Providence Eye on June 12 here).
We have been and will continue to be deeply invested in this process as it moves from the CPC to the City Council over the next few months. PPS staff attended all five CPC meetings devoted to the Plan between February and May and gave public comments at each of these meetings encouraging the Planning Department to go further to ensure the preservation and adaptive reuse of our existing building stock in the context of rapid growth and development. At every one of these meetings, PPS members and partners also advocated forcefully for this position. To be clear, PPS supports a more populous Providence and the creation of more affordable housing to address our housing crisis. We also see that preservation and adaptive reuse are critical to the City’s sustainability goals now and into the future, as these goals become increasingly ambitious, as they must, to keep up with the pace of the climate crisis.
There are many new elements in the 2024 Comprehensive Plan that PPS strongly supports, including new sections prioritizing the preservation of modern architecture and historic places in underrepresented communities, a stronger focus on the redevelopment of surface parking lots, the idea of exploring the viability of “lesser regulated local historic districts,” and proposals that would pressure institutions such as Brown University and Rhode Island School of Design to do more to protect their historic buildings.
However, we see a need for change in four key areas of the Plan that relate to issues of equity, sustainability and the City’s duty to act as responsible stewards of the built environment.
1. This Plan positions Providence for rapid growth and development; the growth strategy map in the Land Use chapter will dictate where this growth is encouraged, and where it will be restricted, proposing a growth scale such that development in “historic districts” will be more restricted than in the next four designated areas (managed growth, enhanced growth, growth corridors and priority growth). The current Plan defines “historic districts” as the city’s existing local historic districts (8 contiguous districts and 1 noncontiguous district). PPS strongly recommends that the Comprehensive Plan should redefine “historic districts” to include all of the federally recognized historic districts and landmarks in the City that are listed on the National Register of Historic Places (recognized by the US Park Service for their historical significance), prioritizing those districts and sites that are in wards that do not have local historic districts.
The argument for this redefinition is that the city’s existing historic districts overrepresent affluent white neighborhoods, while the federally designated historic districts and landmark sites are more balanced and inclusive. Neighborhoods listed in the National Register include triple-deckers and other multi-family dwellings built in the 1890s and early 1900s that housed Providence’s immigrant communities in Smith Hill; the beloved Pine Street Historic District in Upper South Providence; 19th-century mills and mill housing in Wanskuck and Olneyville; and one of the city’s first historic suburbs in the Summit neighborhood, among others. PPS believes that an unwillingness to redefine “historic districts” in the suggested manner presents an equity problem as it will magnify existing spatial inequities, restraining development in many of the City’s most affluent white neighborhoods, and encouraging increased density and development in less affluent neighborhoods and neighborhoods of color despite the fact that many of these latter neighborhoods contain nationally recognized historic districts and landmarks.
2. PPS recommends that a new section of the Built Environment chapter be added titled “Preventing Demolition.” PPS believes that the Plan should do more to limit demolition as the upzoning that is being proposed (increasing allowable densities in every zone) could lead to a demolition spike causing significant displacement in those neighborhoods that are not in local historic districts (about 90%) as single-family houses and duplexes might be replaced by more profitable multi-family dwellings.
3. PPS urges the Planning Department to strengthen and add language that prioritizes the adaptive reuse of existing buildings and other sustainable building practices. This would be in line with the trajectory of carbon reduction policies that are evolving from setting benchmarks for buildings’ operational carbon emissions to more holistic policies that increasingly account for and regulate projects’ embodied carbon emissions – the emissions that are produced during demolition and new construction and in the creation of the materials that are used. Two good examples include London’s Whole Lifecycle Carbon Assessments policy (2022) and the state of California’s CALGreen Mandatory Measures for Embodied Carbon Reduction (2023), as well as other cities’ policies governing the deconstruction, salvage and reuse of building materials.
4. PPS strongly recommends that the City establish an advisory design review committee composed of urban design and preservation professionals to advise on key development projects and urban design initiatives, including City-led plans, plans of a specified scale, or projects that use City resources. We believe that the City has a responsibility to ensure that the next generation of Providence’s building stock lives up to our historic fabric, and that it is in fact in the City’s interests to do so, to ensure Providence’s continued reputation as a desirable place to live and visit. We recommend Chicago’s Committee on Design as a model that is advisory, and that offers developers an accelerated approval process. PPS’s own Planning and Architectural Review Committee has operated for decades as an effective advisory review for developers with projects in historic districts and neighborhoods and could serve as an effective model.
On June 9, PPS submitted a memo to the Planning Department presenting these comments, along with suggested in-line edits to the Land Use and Built Environment chapters that we believe would make the City more equitable and sustainable in the decades that follow this one, and will help us to retain the distinct spirit that makes Providence unique (see the complete submission here). As the Comp Plan is taken up by the City Council for consideration this summer, PPS will continue to advocate for these changes.