February 1, 2024
Mayor Donald R. Grebien
City of Pawtucket
137 Roosevelt Avenue
Pawtucket, RI 02860
Director Terrence Gray
RI Dept. of Environmental Management
235 Promenade Street
Providence, RI 02908
Dear Mayor Grebien, Director Gray, and whom it may concern at the City of Pawtucket and RI Department of Environmental Management:
Thank you for the opportunity to comment on the vital matter of preserving the only green space in the majority Black and brown Woodland Neighborhood of Pawtucket. Roots 2Empower is a Pawtucket-based nonprofit that works to build community power and resilience through mutual aid, community gardening, dialogues, visioning sessions, and entrepreneurial training. Despite the work that we do to enable civic engagement for justice-impacted, low-income, and marginalized residents of Rhode Island’s urban core, our impact is limited without a transparent and democratic process. Regrettably, that has been the case with the unnecessary closure of Morley Field and the application to convert part of the field into a parking lot.
Although the Woodlawn Neighborhood has been vocally opposed to the conversion and closure of Morley Field since it was first proposed, the application states several times that the conversion would “result in a resource that is better aligned with the identified neighborhood needs.” Comments from local residents have been well documented and unilaterally state that Morley Field has been a haven – a place to find shade in the heat, to relax, to get exercise, connect to nature, and for their kids to play and develop as athletes. This proposal goes against our city and state’s commitment to combat climate change, promote environmental justice, advance health equity, and give all Rhode Islanders access to a safe and healthy environment. And it is an egregious offense against the residents of the majority Black and Brown neighborhood.
According to the White House Council on Environmental Quality’s Climate and Economic Justice Screening Tool, the Woodlawn Neighborhood is in the 99th percentile for people with asthma, 77th percentile for low-income households, 90th percentile for average energy cost divided by household income, and the 96th percentile for lack of green space. The Tool also reports this neighborhood is in the 96th percentile for proximity to hazardous waste facilities, 92nd percentile for proximity to risk management plan facilities, and 92nd percentile for traffic proximity and volume. The EPA has designated this area a priority Environmental Justice Area. To pave over the only green space in this neighborhood, increasing and perpetuating disenfranchisement and adversity this community already faces would be a criminal act.
Morley Field was developed with federal grants through the Land and Water Conservation Fund Act (LWCF), a fund established under the National Parks Service (NPS) in 1965 to provide outdoor recreation resources for present and future generations. Under the agreements between the City of Pawtucket and NPS, the City is prohibited from converting the park for non-recreational use without the consent of NPS under strict conditions, including that there is a replacement park. The application to NPS submitted by RI DEM falsely claims that the proposed project would not impact air quality, climate, contamination or hazardous materials, environmental justice (minority and low-income populations), water quality, wetlands and floodplains, and socioeconomics – all of which is difficult to believe given the lack of vegetation in this area that is explicitly designated as an environmental justice zone. The application also falsely claims there would not be a significant impact on public health, have controversial environmental effects, establish a precedent for future action, or have a disproportionately high and adverse effect on low-income or minority populations. Based on the comments and public out roar at this proposal over the last two years, these claims are absurd at best.
Paving over this park would increase emissions and particulate matter associated with asphalt, increase our carbon footprint, and create a heat island. Conventional paving materials transfer excess heat and release harmful particles into the air when they reach a temperature of 120-150 degrees Fahrenheit, increasing the severity of asthma and respiratory disease and the risk of heat-related illness and death. Grass takes in carbon dioxide and stores carbon in the soil, meaning destroying this park would further exacerbate pollution in this neighborhood and increase overall carbon emissions in the state.
This neighborhood is approximately 74% people of color with 59% of people living at or below the poverty line and 29% of the population are children. Testimony from residents of the neighborhood has stated time and time again that the park has served as an oasis where countless memories have been made. Still, the park was shut down and fenced off before the property was even sold based on allegations of hazardous contamination which DEM later confirmed were not at levels necessitating its immediate closure. Given the federal commitment to environmental justice and the funding that’s been made available to achieve the White House’s climate justice agenda, the neglect to accurately report the impact on this environmental justice community is unsettling.
In a neighborhood that has been impacted by racial deindustrialization, displacement, redlining, and predatory spending, the city and state’s approach to this project reinforces the systemic racism at the roots of our state’s manufacturing era and economic foundation. This field may be “excess” land to the developers who aim to profit from their development project, but to our community, it is an essential place to rest, exercise, play, and connect to the healing power of the earth. We implore you to take a new approach and heed the calls of the community to reject this proposal and keep Morley Field intact in this neighborhood that is in the 96th percentile for lack of green space nationwide.
Thank you for your consideration,
Tarshire Battle
Executive Director
Roots 2Empower