Statement of Sprague Energy

December 1st, 2009

Statement of Sprague Energy, 144 Allens Avenue

On the Waterfront Plan and the Allens Avenue & Port Redevelopment Plan

December 1, 2009

Sprague Energy appreciates this opportunity to provide written comments on the Waterfront Plan and the Allens Avenue & Port Redevelopment Plan. In general, Sprague believes the Providence Department of Planning and Development should be applauded for the public effort undertaken to gather relevant experiential data through the June 2008 Waterfront Charrette and the September 2008 charrette follow-up session. The Department should also be commended for bringing in impartial subject matter experts from other port communities that are further along than Providence in the development of comprehensive waterfront planning policies. With that said, we believe the latest version of the Waterfront Plan fails to take into account the very testimony made by those same subject matter experts.

More specifically, at the Waterfront Charrette we heard testimony from Baltimore, Maryland and Portland, Maine that residential uses such as condos and hotels should not be allowed along industrial waterfront areas. Both communities have taken proactive steps to stop the growth of incompatible condo and hotel uses along their industrial working waterfronts. In the last year both communities have reaffirmed this commitment. Baltimore recently extended its Maritime Industrial Zoning Overlay District (MIZOD) protected area, and Portland declined a proposed change that would have weakened their working waterfront protection regulations. Both ports have large working waterfront areas that are separate and distinct from their lesser intensity waterfront areas where residential and hotel uses are permitted.

Sprague can reaffirm the importance of separating incompatible waterfront uses from our own experiences. In East Hartford, Connecticut we were recently forced to sell our terminal, the last on a street that once housed 5 terminals. Nearly five year’s ago, Goodwin College was allowed to expand onto this same street through a zoning change from industrial to mixed use. The traffic conflict eventually became a major safety concern. A well-intended City position that first promised peaceful coexistence, eventually became a call for our departure even though the conditions of our operations had never changed. In Quincy, Massachusetts a condo with supporting marina was built adjacent to our terminal. Those pleasure boats now pose a navigation impediment to our ocean going vessels. Additionally, the residents have stated opposition to vessel offloading pumps and tug boats sounding whistles when they dock vessels at night. Those whistles are the way tugs communicate their position and intended direction changes to each other. In addition to past noise complaints, we were also forced to structurally alter a storage tank at considerable expense as residents complained that it hindered their view of the Boston skyline. Despite the fact that this tank and the terminal had been built decades prior to the construction or occupancy of the condominiums, the expectations of the residents could not be ignored. This is a case of residential quality of life complaints directly impacting critically important marine safety measures and our ability to operate our business. These examples clearly show that any zoning which allows for overnight inhabitants will lead to complaints about typical marine industrial operations. Similar examples of conflict can be found via an internet search in Portsmouth, New Hampshire or Portland, Oregon.

Our concerns are also directly reflected in a November 10, 2009 letter from the U.S. Department of Energy, which states that mixed-use zoning may not be appropriate next to industrial oil terminals, such as our facility on Allens Avenue:

“A mixed use commercial district would allow the building of hotels, marinas, and condominiums immediately adjacent to existing oil terminals. This could have a negative impact on the commercial operations of those fuel terminals. Rezoning may result in future restrictions on terminal operations to accommodate residential preferences that could endanger the economic viability of terminals given the differing nature of the established and proposed uses of the areas in question. This could eventually result in the loss of petroleum storage capacity for the region.”

Sprague currently operates 16 terminals throughout the Northeast. Many of our terminals provide other services for manufacturing concerns in or around the port. For example in Newington, New Hampshire we import gypsum rock for a large dry board manufacturing plant a mile down the road. In Searsport, Maine we import kaolin clay for paper manufacturing. In Portland, Maine we are exporting pulp for a new venture that will be making second generation biofuels as a byproduct of a pulp making operation. This venture recently received over $25 million in federal funds to support its efforts. All of these firms are major employers in the local areas. We have experienced industrial growth in almost all port communities over the last dozen years. That same growth has actually been experienced at ProvPort. Unfortunately, similar growth has not happened on Allen’s Avenue. The reason for this lack of growth can be directly attributed to the repeated public efforts to gentrify this industrial area. Since the Narragansett Landing and Providence 2020 plans, the City has been attempting to rezone our area as mixed use residential. This threat of proven incompatible growth makes it impossible for privately funded organizations to risk their capital and make the investments to attract these types of growth opportunities. Again, we heard from ProvPort officials at the charrette that space for additional expansion is very limited at ProvPort. This is evidenced by the need for the Providence Redevelopment Agency to take additional property to support the latest growth initiative. Unfortunately, with the rezoning of Allens Avenue the City will preclude future opportunities for the next round of job creating port initiatives.

Sprague Energy believes that Allens Avenue’s working waterfront can and will experience the same job creating growth that has been seen at ProvPort and in other port cities. To achieve this however, zoning must be put in place to protect Allens Avenue’s marine industrial businesses from incompatible residential and hotel uses. Unfortunately, the current Waterfront Plan does not provide these important protections which have been shown to work in other port communities.

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