IN SUPPORT OF THE PETITION TO PRESERVE TOWN FARM PARK
The Friends of Town Farm Park, a group of concerned community members who want to preserve the Park as a valuable recreational, cultural, and historic resource, are respectfully submitting a petition to the South Kingstown Town Council based on reasonable, valid, and compelling information described in this Position Statement. The petition urges the Council to preserve Town Farm Park as recreational land by unanimously voting against the final submission of the Land Conversion Application to RI DEM and the National Park Service.
WE POSE THIS IMPORTANT QUESTION: Why would the town propose to take a resource away from a neighborhood that wants and uses it only to force it on another neighborhood that doesn't?
The opinions and information presented herein have been formed based on applicable and publicly available regulations and documents, including but not limited to:
Meeting agendas and minutes of the Planning Board, Zoning Board, Recreation Commission, and Town Council;
The State of Rhode Island Historical Preservation and Heritage Commission (RIHPHC) correspondence;
Coastal Resources Management Council (CRMC) related documents;
L&WCF Project Boundary/RIDEM ID #44-00167 Conversion Application document;
“South County Health Institutional Master Plan 2022.” July 15, 2022, along with all associated documents;
Below we describe issues with the proposed change in land use from a park to a parking lot, focused on five general themes: 1) the historical and cultural significance of the property, 2) misalignment with the 2021 Town of South Kingstown Comprehensive Community Plan, 3) Application for Land Conversion is incomplete and lacks all relevant information regarding the land use, 4) environmental and stormwater mitigation concerns, and 5) alternative parking options have not been exhausted.
1) Historical and Cultural Significance of the Property
1871 - the land that included farm structures and a family cemetery was given to the Town by Thurston Robinson. The Town Poor Farm was established to provide burial plots for impoverished residents. RI Historical Cemetery Commission records indicate that a cemetery existed with 20 or more graves but was destroyed in 1940.
1953 - the land was established as a “neighborhood park” called Town Farm Park (a.k.a. Kenyon Avenue Playground) and included two baseball fields, a basketball court, and play structures.
1976 – The town received federal funding under the Land and Water Conservation Fund Act of 1965 to further develop the recreation space. The stipulation of said funding is that the land is to be maintained as a public recreation space in perpetuity.
1983 – the upper ballfield section of the park was sold to South County Hospital (SCH) to expand parking and the building in exchange for other lands nearby to develop a park while still leaving the majority of the original land intact.
January 2020 - RIHPHC informed the Town of South Kingstown that “the proposed SCH parking lot expansion might impact Narragansett Indian Burials,” requiring the Town to have the hospital perform an archaeological assessment on the property.
October 2020 - RIHPHC sent another letter to the Town reiterating its position that since “there are known archaeological sites and precontact burial sites in the vicinity of the parcel, and we are concerned that there may be archaeological deposits and burials on this property as well. The sale of the property has the potential to have adverse effect on archaeological sites by opening it up to development. Therefore, we recommend that a Phase I archaeological survey be done…to evaluate." This letter goes on to restate that “the Town of South Kingstown, acting under the authority granted them by RIGL 23-18 et seq., to require this assessment be conducted in advance of any ground disturbance on the parcel….”
June 2021 - the required archaeological study commenced on the subject property, which included areas of the proposed parking expansion on Town Farm Park and two additional gravel parking sites currently being used by SCH (as was requested by RIHPC).
October 2021 - a report was prepared and submitted to the RIHPHC.
November 2021 - RIHPHC issues a letter to Gray & Pape (the preparer of the archaeological study), with copies sent to SCH, VHB (the hospital’s engineer), John Brown, representing the Narragansett Indian Tribe Historic Preservation Office, NITHPO), Theresa Murphy, Interim Town Manager, and James Rabbitt, Town Planner. Paraphrasing said letter informed all parties that the project area contains a “potentially significant Narragansett site, quite possibly an extension of the nationally significant Salt Pond site.” This heightened their concern about the potential presence of Narragansett burials on the property, including the gravel lot areas currently being used for parking.
October 2022 - over two years after the Town and SCH were informed of potential Narragansett Tribal burial sites on the land and that “the sale of the property has the potential to have adverse effect on archaeological sites by opening it up to development,” RIHPHC, because they had not heard back from the Town and in response to inquiries by several South Kingstown residents that the project was still moving forward issued a letter to James Manni, Town manager dated October 5, 2022, reaffirms their “concerns that Narragansett burials are present on the property, as communicated…” and “RIHPHC considers it highly likely that Narragansett graves are present on this property, it must be considered a cemetery by the Town and afforded all the protections of the State cemetery laws (RIGL 23-18 et seq.). Under these laws, any future ground-disturbing activities undertaken on this land at any time in the future would require approval from the town under RIGL 23-18 et seq.”
We acknowledge the sensitivity and confidentiality of specific information contained in the archeological report. However, based on the correspondence, there appears to be a general disregard by the applicant and potentially by Town staff members for the significance of the archaeological findings. Based upon comments by Town Council and Planning Board members at public meetings, it appears that essential information may have been withheld that is needed by said Council and Board to render educated and thoughtful decisions.
2) Misalignment with the 2021 Town of South Kingstown Comprehensive Community Plan
The sale of the Town Farm Park parcel and conversion of the park to a parking lot is in direct contradiction with multiple elements of the Town’s Comprehensive Plans, especially given the information brought to light by the RIHPHC as highlighted below:
PG-27 – LAND USE
VISION - “To promote orderly growth patterns based upon the natural, cultural, and historic character of the Town, the land’s suitability for use, and the aspirations of its citizens.”
“The Land Use element of this Plan will preserve and enhance the unique quality of life of this civic-minded community settled among a dense core, rural villages, and natural areas. …The Town’s Native American and historic legacy will continue to enrich this quality of life, providing a prehistoric context of locations important to the Narragansett Indian cycle of life, and historic stone walls, homes, factories, and cemeteries.”
PG 159 - NATURAL RESOURCES & OPEN SPACE
VISION - “To preserve, protect, and enhance the Town’s open spaces and natural resources for the well-being of the Town’s citizens, and to ensure that our finite natural resources are able to provide for future generations by integration into the plan review and approval process.”
PG 191 - CULTURAL & HISTORIC RESOURCES
VISION - “The Town’s Native American historic legacy will continue to enrich the quality of life, providing a historic context to locations important to the Narragansett Indian Tribe’s cycle of life. The Town’s colonial and industrial legacy, now visible in the context of stone walls, homes, factories, and cemeteries, will be protected for future generations. The Town shall continue to preserve, protect and enhance its cultural resources through expanding local measures for historic preservation….”
PG 192 - CULTURAL & HISTORIC RESOURCES GOAL
“Goal 1: The measures available for protecting cultural and historic resources will be expanded to provide maximum protection to South Kingstown’s historic resources ...”
PG 195 – “Cultural and historic resources of South Kingstown mirror both the heritage of the Narragansett Indian Tribe and the historic settlement patterns of the colonists and later industrialization….”
PG 197 – “Threatened and potentially threatened resources fall into the following general categories:
Large mill complexes and associated mill housing
Individual or isolated structures scattered throughout South Kingstown
Cemeteries and graveyards
Historic landscapes and farms.”
PG 217 - FACILITY NEEDS FOR ACTIVE RECREATION
“Currently, the Town has a minor shortage of mini park areas, as noted in Table 31: Comparison of Town-Owned Parks & Community Needs. As South Kingstown’s population grows, additional small park areas (known as mini-parks) located close to densely developed areas may be needed. Additional neighborhood parks, which customarily include sports fields and other intensive recreational uses, may also be needed.”
3) Application for Land Conversion is Incomplete and Lacks all of the Relevant Information
Step 3-B5 – Description of the parkland proposed for conversion
The description should be revised to reflect more detail regarding the results of the archaeological study and RIHPHC’s determination that the site contains a “potentially significant Narragansett site, quite possibly an extension of the nationally significant Salt Pond site,” and that because RIHPHC considers it highly likely that Narragansett graves are present on this property, “it must be considered a cemetery by the town, and afforded all the protections of the State cemetery laws (RIGL 23-18 et seq.).”
The description of the community served is not accurate. The description states it is based on 2010 census data and implies that the use of the facilities has declined or is not relevant to the Town’s demographic. Based on public commentary by Recreation Commission members, this park could have easily been reconfigured to better meet other growing recreation needs of the community and increase the active use of the site. Also, based on the 2021 Comp Plan, surveys performed indicate that there is a need for more mini-parks, and additional neighborhood parks may also be needed. This more current information (available at the time of the original preparation of the application for conversion) does not justify the proposed conversion.
The description states that the use of the park is limited to preschool to elementary school-aged children. Current Town Farm Park users encompass all ages and include walkers, runners, playground users, and small groups/families who use the ball field for a variety of unstructured play. This varied use is in spite of the fact that until recently, the Town has allowed the roadway and grassed areas of the park to be used as ancillary parking by hospital employees and visitors, rendering the park less desirable for recreational purposes. Because newer ball fields were built throughout the Town reducing use by softball and little league teams does not negate the possibility of enhancing recreational opportunities on the property to better meet the current and future needs of the neighborhood and community at large. For example, a reconfiguration of the field for a combination of soccer and lacrosse is a viable and reasonable option. Or, to meet the growing demand for pickleball, a combination of tennis/pickleball courts could be constructed. Pickleball is a sport that spans all ages. Lastly, the addition of benches, picnic tables, and a designated walking path can be added at the scenic overlook to take advantage of views of Point Judith Pond. These improvements would also be in keeping with Route 1’s designation as a scenic highway.
To reinforce this, we offer the following excerpt from a Narragansett Times article dated January 27, 2020:
“Since the land swap proposal came before the recreation commission last month, both Vice Chair John Biafore and Treasurer Mark Noble have been out to visit the site for themselves. Neither saw the land as equivalent — especially since it would be exchanging active recreation space for passive recreation use.
Biafore disagreed with statements that the park’s declining use had somehow made it a passive space.
“I think that it’s a short-sighted statement, in a lot of ways,” he said. “Most importantly, it has a value to us as a parks system. I guarantee you, if Rex [Eberly] changed around some line and restriped it as a soccer field, or striped it as a lacrosse field, it would be used constantly.”
Multiple members of the commission expressed frustration with the process, which Biafore said was a bit like putting the cart before the horse.
“I want to make a blanket comment to the folks who are here tonight, but we’re faced with a very hard decision — a very hard task — that this is being brought to us, it feels like, almost after the fact,” William Litvin said. “After the fact of a portion of our park being leased to the hospital, after the fact of a portion of a park being sold that was a restriction of the park’s easement.”
If any of this had come to the recreation commission beforehand, Litvin said, the recommendations received may have been very different.
Biafore pointed out that when additional space was leased from Town Farm Park, the recreation commission was not made aware of this until after the fact.”
In a later article in the Narragansett Times dated February 24, 2020, it is reported that “Members of the recreation commission looked to Murphy to ensure that their own comments on the land swap proposal will also be included in this application…” however, the Commission’s comments do not appear to be reflected in the application to RIDEM.
Step 3-B6 – Description of the parkland proposed for conversion
b. The description should be revised to reflect more detail regarding the results of the archaeological study and RIHPHC’s determination that the site contains a “potentially significant Narragansett site, quite possibly an extension of the nationally significant Salt Pond site,” and that because RIHPHC considers it highly likely that Narragansett graves are present on this property, “it must be considered a cemetery by the town, and afforded all the protections of the State cemetery laws (RIGL 23-18 et seq.).”
d. The description of how the proposed replacement site is “reasonably equivalent” is not valid. There is still a questionable appraisal, and it does not accurately reflect the opposition to the proposed swap of the Recreation Commission and the residents of the Glen Rock neighborhood. On multiple occasions, Glen Rock residents have issued comments opposing the land swap, and as stated in both minutes from Rec Commission meetings and newspaper articles covering the story, the use of the Glen Rock property is not supported by anyone except SCH.
General Public Comment
The Land Conversion application appears to have a provision for public comment. However, many residents in the surrounding neighborhoods were never contacted and/or made aware of the project and public comment period until it had apparently passed. We question the criteria for notice. Given that the land, although designated as a neighborhood park, it is available for use by the entire community, negating the validity of a standard 200-ft radius abutter notice. A minimum of at least one mile is reasonable and should have been offered, thereby capturing not only the immediate neighbors but other frequent park users. Notice of anything having to do with the SCH Master Plan and use of the park for parking has only been from the land they currently own. This effectively also eliminates the notice of most of the residents of Town Farm Road and the majority of the neighborhood that uses Town Farm Park.
4) Environmental and Stormwater Mitigation Concerns
Town Farm Park is located at the head of Point Judith Pond, which is considered by RIDEM as having impaired water quality and is the subject of a Total Maximum Daily Load study (RIDEM, 2008) to address elevated bacteria levels, which were found to be related to discharges of untreated stormwater, among other sources. As stated in the TMDL, “Achieving standards requires that both the amount of stormwater and the bacteria concentrations in that stormwater reaching Point Judith Pond are reduced.” The addition of a parking lot will only exacerbate degraded water quality conditions in the Upper Pond and threaten the recreational uses of these waters.
In a June 2021 Preliminary Determination Application to CRMC, engineers for the project stated that the parking expansion project is within the Saugatucket River Watershed and described the project as including 155 new parking spaces, a walkway system, and a stormwater management system. CRMC staff relayed that the plans lacked information on the proposed stormwater treatment. CRMC stated that the project must be designed in accordance with the latest RI Stormwater Design and Installation Standards Manual and follow Low Impact Development techniques.
The current IMP (page 16) proposes a new parking lot on the Town Farm property that will consist of 170 spaces. It is our contention that given the new archaeological information and associated site construction restrictions calling for limited disturbance and excavation, it is unlikely that the runoff generated from the proposed paved area can be adequately mitigated within the surface areas designated as “stormwater features,” and again referring to the limitation on subsurface excavation for any kind of utilities, a subsurface infiltration system will not be an option.
5) Alternate Parking Options Not Exhausted
Other than just being told, “it is not an option” or “it is too expensive” to questions about alternative solutions to the conversion of the Town Farm Park property for parking, the residents have not been privy to any alternate plans and/or data to support those claims.
Prior to the finalization of the conversion of the parkland, the hospital should be required to effectively implement all measures to improve parking as outlined in the IMP under Future Conditions & Findings of the Transportation Report. This includes:
-Demolition of the storage shed yielding an anticipated 40 spaces.
-Consider ways to increase parking on Campus by reconfiguring the lots in a more efficient layout, including striping the dirt areas and use of parking management techniques.
-Consider demolition of buildings on campus (85 Kenyon Avenue)
-Enforcement of employee parking restrictions.
Regarding 85 Kenyon Avenue – there currently appear to be 31 spaces existing that do not appear to be counted in the study. The demolition of the single-story building and reconfiguration of the parking lot may yield 15-20 spaces for a possible total of 50.
Regular observation of daytime employee parking patterns indicates that the current parking management plans in place are not adhered to or vigorously enforced. It appears that the differentiation of patient vs. staff parking spaces with white striping vs. yellow striping may not be sufficient for staff to easily comply with restrictions and are taking spaces away from patients. Before taking over recreational land, the hospital needs to make every effort NOW to employ more parking lot management tools and infrastructure to be able to truly assess its future parking needs. As their own parking analysis stated, a reconfiguration of existing lots for a more efficient layout should be considered. This, combined with permanent signage (not cardboard taped to cones and other signs), the issuance of staff tags or stickers, monitoring of authorized vehicles, and use of parking apps on employee phones, may ultimately prove more cost-effective than the potential return on investment of what may be a parking lot at half the proposed size and the destruction of recreation land.
During the October 25 Planning Board meeting, the Town Planner mentioned a “parking deck” several times relative to crafting the Planning Board’s pending motion to potentially approve the current IMP however, no proposed conceptual plans considering this has been presented and officially ruled out.
Given the valuable archaeological resources and the recommendation of RIHPHC to protect the Town Farm Park site, both the Town and SCH should revisit the option of utilizing the land currently occupied by the Town Public Services Department (formerly the South Kingstown Police building). The demolition of the existing building will make way for plenty of additional parking in an area already covered by impervious surfaces, used for parking now, and could serve as an emergency vehicle and hospital staff-only entrance. This not only preserves the valuable parkland; it has the benefit of reducing traffic on Kenyon Avenue and would be more aligned with the Comprehensive Community Plan.
Thank you for your consideration.