SNA's Second I-Zone Letter

Dear Mr. Deller,

In response to your Request for Comments Regarding Changes to the Regulation of Educational and Healthcare Institutions of July 21, 2003, we offer the following thoughts and suggestions.

In our March 12th letter to you, we identified four ways that we feel the I-Zone has failed the city's neighborhoods, and we suggested four ways to strengthen institutional zoning regulations. We stand by our earlier analysis, and again suggest that the proposed changes

• eliminate the I1 zone and zone hospitals as a commercial use,
• within the remaining I-Zones, allow only buildings and uses compatible with residential neighborhoods,
• scale I-Zones to the surrounding community, and
• establish more effective buffer zones at the interface of institutions and homes.

Positive Effects of the I-Zone

Yet though these borders have held in our neighborhood, we worry that "floating zone" boundaries are too easily changed. And they have not prevented institutions from buying homes and commercial properties beyond their borders.

Institutional master plans are an invaluable resource. Though current regulations have bred institutional scofflaws and the planning process is flawed, the plans themselves provide a comprehensive view of institutions' land holdings and operations that informs debate in a way that project-by-project public disclosures cannot. Any relaxation of zoning rules that benefits institutions should be accompanied by beefed up disclosure requirements and a public approval process.

Incompatible Uses

Traffic

Institutional uses that generate traffic are anathema to residential neighborhoods. Most disagreeable are traffic patterns that result in a dramatic increase in cars, trucks or busses on local, neighborhood streets. The most egregious example of this that we know is the Fain Outpatient Clinic, built by Miriam Hospital in the middle of our neighborhood in the late 1980's. By Miriam's own numbers, the clinic generates 60,000 visits a year, as much as the whole rest of the hospital. The clinic, and the whole Miriam campus, is completely surrounded by homes and accessible only by local streets.

Noise

Large institutional buildings generate noise. Mechanical systems are usually located on the roof, and the noise they create is audible blocks away, night and day. Truck deliveries and garbage pickup are an early and noisy routine. Health care institutions have shift changes around the clock.

Light

Institutions have many good reasons to light their buildings and parking lots. But bright lights that burn through the night are a nuisance to nearby neighbors. Homeowners should not have to endure the everlasting daylight of sodium lamps aimed at their bedroom windows. A Miriam neighbor reported to us that after complaining to the hospital about its bright lights, the hospital suggested he purchase thicker curtains. Just whose neighborhood is it, anyway?

Trash

Buildings that draw large numbers of people every day generate a steady flow of trash. It rides the wind and the wakes of vehicles and settles on nearby streets, lawns and driveways, enlisting abutters in a daily ritual of trash pickup.

Toxins

Some institutional uses involve the storage, use or production of toxic substances that would not normally be permitted in a residential area. From the mundane industrial furnace to clinical or research uses of hazardous biological or radioactive materials, these represent unnecessary and unwanted risks in such close proximity to places where people live and raise families.

24/7

Some institutional uses, like hospitals, involve around-the-clock operations. Problems of excessive traffic, noise and light are made worse when they happen at all times of the day and night. A residential neighborhood has a natural circadian rhythm, a hospital has an industrial three-shift rhythm. They are not compatible.

Aesthetics

Large institutional buildings detract from the residential character of a neighborhood. Their soaring height, sheer mass, and vast walls of brick and glass overpower and diminish their surroundings. Block-size parking lots, dirty treeless asphalt voids, introduce their own kind of inhospitable urban incongruity. Such buildings block sunlight from the gardens of nearby homes and industrialize the landscape. The interface of institutions and residential areas calls for modest, neighborhood-scale buildings.

Further Thoughts on Reform

The original I-Zone was designed to encourage institutions to practice smart growth. We suggest that a better approach is to prohibit bad growth. Make it impossible for institutions to build inappropriate and unwanted structures in residential zones. Without missing a beat, they will plan accordingly and they, the city and its residents will all be better off.

Parking is Commercial

Parking lots are a commercial activity. An innovative feature of the I-Zone relaxes per-building parking requirements, allowing institutions to establish large lots that serve their whole campus. But large parking lots are eyesores that generate traffic, litter and light pollution. Large lots make sense, but only in commercial zones, not in residential ones. Miriam Hospital offers 500 surface parking spaces on nearly two full blocks in the heart of Summit Neighborhood. The parcels are zoned R1/R2 and outside their institutional zone. These lots should be returned to a more compatible use.

Mitigate Past Damage

Institutions are constantly changing, tearing down buildings, building new buildings, moving operations from one place to another. We can barely keep up with all the internal moves that Miriam programs and departments have made in the last five years. Why should zoning establish permanent non-conformance? The I-Zone enshrines the mistakes of the past and makes them a foundation for further institutional adventures. In whatever form the I-Zone continues, structures that are incompatible with surrounding neighborhoods should always be non-conforming, to ensure that they never grow, and eventually go away.

Establish a Collaborative Neighborhood Planning Process

Institutional master plans lay out specific goals for change and growth from an institutional standpoint. The comprehensive plan offers general guidelines for city neighborhoods, but does not address the specific circumstances of each neighborhood. The City and its residents ought to have a plan for each neighborhood that lays out what they value and what they wish to change, the kinds and limits of growth. A neighborhood planning process would provide a venue to disclose and reconcile the competing agendas of government, residents, businesses and institutions.

We hope you find these comments helpful, and we look forward to your proposal.

Xc: Mayor David N. Cicilline
      Council President John J. Lombardi
      Councilman Kevin Jackson
      Representative Gordon Fox
      Senator Rhoda Perry
      Catherine Horsey, Providence Preservation Society
      College Hill Neighborhood Association
      Fox Point Citizen's Association