By JOHNATHAN BERARD
PROVIDENCE — The final version of the Providence Harbor Management Plan, submitted to the City Council earlier this month, will provide a road map for governance over all things related to the tidal waters within the city limits over the next five years.
While it does adequately address some current policy problems, it falls far short of what a modern, comprehensive coastal ecosystem implementation and management plan should look like.
The plan covers four main topics related to management of the harbor and the waters that drain into the estuary: public access; water quality; mooring management; and shipping, navigation and multi-use of harbor waters. Since I am no expert in these last two areas, I will limit the scope of these comments to the first two elements: public access and water quality.
First and foremost, there is a huge discrepancy between what the report claims to address and what it actual does. In the visioning statement, sent to the City Council and submitted along with the final report, the Harbor Management Commission (HMC) indicates that:
“Plan is designed to expand public access to the waterfront and increase recreational opportunities while also protecting, restoring and creating valuable coastal habitat and improving water quality. Its focus is on promoting economic development and tourism while also establishing best practices in green infrastructure. Finally, it addresses steps for the City in storm preparedness and is mindful of the future climate resiliency issues we will inevitably face.”
Unfortunately, the policy suggestions laid out in this implementation plan only addresses a handful of these things while glancing over several others. Green infrastructure is mentioned a few times throughout the report, but never in any sort of meaningful detail. Most glaringly, the last sentence in the above quote is the only mention of “climate resiliency” in the entire 90-plus-page document.
The HMC identifies some other potential policy problems as well, but, puzzlingly, never outlines any concrete guidance on how to address them. For instance, several pages are spent detailing the problems of nutrient pollution, a dearth of submerged aquatic vegetation, and the proliferation of manmade riprap shorelines, but doesn’t offer much in the way of actions to remedy them beyond vague, nebulous recommendations to “encourage the installation of best management practices” on developed shoreline properties and “support CRMC designation of coastal wetlands and other marine habitats.”
In fact, many of the action items listed in the policy recommendations section don’t do anything to meet the objectives outlined just a few sentences before. As an example, under the topic of water quality, the third objective directs program managers to promote “water quality improvements through improved wastewater treatment, stormwater management, and investment in ‘green’ infrastructure projects.”
Yet, the actions only direct the city to address stormwater management concerning a single outflow into the Seekonk River, to consider the establishment of a stormwater enterprise fund — presumably a fee on impervious surfaces — to promote the purchase of more street sweepers, and to encourage the use of Rhode Island Department of Transportation settlement funds to accomplish all of these things.
Nowhere does the HMC list suggestions for the types of green infrastructure to be considered or locations for potential projects. There are no calls to address problems at any other stormwater system sites — it’s borderline preposterous to think that the rest the city’s stormwater infrastructure is in perfect working order.
There are no efforts to remediate nutrient pollution through best-management practices, even though nutrient pollution was clearly identified as a problem earlier in the report; the only pollutant addressed here is sediment — to be remedied by street sweeping — and the only suggestion for slowing nutrient pollution, despite the connection never actually being explicitly made in the report, is to rip up pavement.
But, most noticeably absent from the report, is the almost total omission of anything relating to climate change. It’s the most pressing environmental, social and economic issue that our generation — and those that come after us — will face, so it’s downright baffling that the only mention of anything remotely addressing it in this plan can be found in the very last recommendation in the report, buried in the section on shipping, navigation and multi-use of the harbor:
“[The city should] incorporate sea level projections into the construction of bridges and other structures in flood zones and vulnerable waterfront areas.”
Climate-change mitigation and adaptation should inform every single aspect of this plan. The HMC does future program managers — to say nothing of the citizens and business owners of the city — a tremendous disservice by not incorporating climate resilience into its policy recommendations.
To its credit, the HMC spends a great deal of the report examining opportunities for increased and improved public shoreline access. This is reflected in the relative thoroughness of its analysis of the issue and resulting suggested action items — which makes the vagueness of the water-quality section even more head-scratching. The recommendations range from increasing the number of public-access sites to improving connectivity between these sites along the shoreline and promoting knowledge of these community assets through signage and education.
Most of these actions, however, are slated to take place north of I-195 — namely, on the East Side and downtown sections of the city. This leaves a significant portion of residents on the South Side, mostly minority and low-income communities, without adequate access to the shoreline.
Two caveats here: (1) the HMC recommends that the city “investigate and promote Oxford Street as a potential public right-of-way to the water and potential site for interpretive signage, art installations, and wetland restoration,” so, to be fair, it is aware that this is an issue; and (2) historical zoning and development has left much of this part of the waterfront a designated heavy industrial and port use, which makes providing access here a challenge. However, this is a great opportunity for the city to investigate designating underutilized sections of this part of the city for public waterfront access, thereby giving residents living south of downtown access to shoreline green space in their very own neighborhoods.
The report’s vision statement lays out a very admirable blueprint for the management of the harbor over the next five years. The analysis of the policy problems is pretty robust and thorough. But it’s in the policy recommendations and action items where the HMC loses a grip on the plan. The plan has a sense of incompleteness; to call this report final, then, is premature. The HMC needs to spell out in more specific detail how the plan will address all of the policy problems identified in the report, not just some of them.
Where are the opportunities for removing riprap and dechannelizing tidal waterways to perform wetland and habitat restoration? Where can the city install green best-management practices to mitigate polluted runoff? What kinds of best-management practices are most appropriate for these sites? How can implementation of this plan mesh with and complement the city’s overall climate resilience plan? What steps can the city take to increase biodiversity in jurisdictional waters? How can we better provide all city residents convenient access to the waterfront?
The implementation plan should include a specific plan to address all of those questions; only then will this plan a truly comprehensive way forward for the next five years. At present, it fails to do this.
Johnathan Berard is a policy analyst, community organizer and environmental advocate, with a specialization in water resource management, urban sustainability and environmental-justice issues. He has a master’s of public policy, with a concentration in urban and environmental policy, from George Washington University. He and his wife live in Lincoln, R.I.