On Tuesday, January 24, 2023, the Friends of Noyes Park Board of Directors submitted the following public comment on the DC Department of Parks and Recreation Ready2Play Master Plan.

To: DC Department of Parks and Recreation
1275 First Street NE
Washington, DC 20002

Attn: Nick Kushner, Community Planner
Dulce Naime, Community Planner

From: Board of Directors
Friends of Noyes Park
3121 7th Street NE
Washington, DC 20017

RE: Public Comments on DC DPR Ready2Play Master Plan

Dear Nick Kushner and Dulce Naime,

The Friends of Noyes Park (FoNP) is pleased to participate in the public comment period for DC Department of Parks and Recreation’s Ready2Play Master Plan. Friends of Noyes Park is a 501(c)(3) non-profit organization dedicated to maintaining Noyes Park as a safe and beautiful community space through a cooperative agreement with the Department of Parks and Recreation. Consistent with the purpose of DPR’s “Friends of” partners, FoNP stewards, advocates, and hosts programming, education, and events to help maintain the grounds and assist in the planning process for the park. The work of FoNP is made possible by the in-kind and financial support of individual neighbors, local businesses, and government agencies who trust FoNP to fulfill our organizational mission in safe, equitable, and engaging ways.

Ready2Play is very thoughtfully drafted. We welcome it and this comment period as an opportunity to rectify some of the maintenance, health, and safety issues in parks that current operations and maintenance processes have failed to address. We believe Friends of Noyes Park is an ideal park partner with whom to pilot the rollout of some of the plan’s key recommendations outlined in the Ready2Play Master Plan. We provide more details below.

BACKGROUND
Noyes Park is located at 1000 Franklin Street NE in Ward 5, and is classified by DPR as a Small Park. The park was constructed in 2013 and includes a pavilion for community events, children's play area, exercise equipment, an artificial turf field, a community garden, and a picnic area with grills and tables. The park playground is an extremely popular neighborhood asset and is regularly used by neighborhood children with their parents and caretakers as well as students attending nearby K-12 education facilities through all seasons.

The Friends of Noyes Park formed shortly after park construction was completed, and has been actively leading stewardship activities at Noyes Park for nearly a decade. Since its inception, the Friends of Noyes Park has hosted nearly 50 park cleanups and facilitated over 5000 hours of volunteer work from neighborhood residents, local university students, and returning citizens. FoNP also manages the Noyes Park Community Garden and the Noyes Park Playground and recreation areas, spaces which engage patrons across a wide variety of ages, racial demographics, income levels, and backgrounds that reflect the rich diversity of the surrounding community.

In addition, the Friends of Noyes Park has been a longstanding advocate for consistent and high-quality park maintenance activities by the DC agencies charged with implementing these aspects of care at Noyes Park and community spaces throughout the District, including the Department of Parks and Recreation, the Department of General Services, Department of Transportation Urban Forestry Division, and the Department of Public Works. When necessary, FoNP has engaged the local ANC, the DC Council, and Mayor Bowser directly to ensure the park is adequately maintained.

SUPPORT FOR THE READY2PLAY MASTER PLAN
It is within the aforementioned context that the Friends of Noyes Park provide commentary specific to the DC Department of Parks and Recreation Ready2Play Master Plan. FoNP applauds DC DPR for facilitating an engagement process to create a Master Plan for the development and major renovation of its play spaces as well as the creation of the Equity Framework to guide decision-making regarding DPR’s future capital investments, operations, programming, and maintenance.

FoNP strongly supports the key priorities guiding the approach to developing the substantive details of the master plan, including prioritizing resilience and sustainability, promoting access, connectivity, and diversity of recreational experiences, ensuring accessibility and inclusion, decreasing health inequities and increasing health outcomes, integrating technology, innovation, and education into play and recreation spaces, celebrating identity and culture, ensuring equitable enhancement and maintenance activities, and expanding collaboration with partners.

FoNP acknowledges FY2031 as DPR’s projected timeframe for a capital investment in a new playground at Noyes Park, designed and constructed through a facilitated community engagement and planning process. With regard to an entirely new playground, FoNP believes that the projected time frame is reasonable as the playground structures themselves are sound, interactive, of sufficient variety, and well utilized by children of all ages.

CRITICAL SHORTCOMINGS OF THE READY2PLAY MASTER PLAN
FoNP strongly believes that operational excellence is a key determinant of the extent to which master planning processes achieve their intended outcomes. FoNP acknowledges that operational activities are reflected in the Strategic Plan (Section C, page 59) as part of Goal 4: Transparent, Efficient, and Engaged Operations - Provide financially sustainable, efficient, and innovative operations and customer care that is transparent and responsive to residents’ needs, which is comprised of three strategies:

Strategy 4A: Explore approaches to improve fiscal sustainability and enhance site and building maintenance.
Strategy 4B: Expand and enhance engagement practices to empower residents and promote transparency.
Strategy 4C: Increase operational efficiency, enhance the user experience, and provide gold-standard customer care to be a national leader in the field.

While pursuit of strategies 4A-4C is laudable, the indicators and metrics used to track progress and celebrate successes on Goal 4 allow for longstanding and critical structural deficiencies within the governmental administration of park maintenance activities to persist. Without a system-wide overhaul to the District’s operations and maintenance structures, processes, and mechanisms for accountability, operations and maintenance of parks and playgrounds will fail to be transparent, efficient, engaged, or credible.

DGS Competing Priorities and Lack of Accountability Leads to Inadequate Maintenance

The Ready2Play Master Plan acknowledges that the DC Department of General Services (DGS) is “responsible for managing construction of all DPR capital projects and for regular maintenance and upkeep of the parks and recreational facilities in DPR’s portfolio.” In addition, the Ready2Play Master Plan describes DC’s unique – and, from the FoNP perspective, deeply inadequate and ineffective – approach to park maintenance budgets and scope of duties. From page 141 of the Ready2Play Master Plan:

Many parks and recreation agencies across the country would manage maintenance out of their operating funds; however, in DC, DPR does not manage its own maintenance, as the Department of General Services handles all maintenance duties. DGS receives operating funds annually in its budget to manage all government facilities, including schools, parks, and other facilities. A portion of these funds are dedicated to DPR projects, but DC does not have maintenance budgets allocated by site.

This operating structure creates conditions for quick deterioration of capital investments; in many instances makes it unlikely DGS will conduct maintenance and operations unless communities advocate for them; and provides no accountability for DGS failing to properly maintain sites. The resulting dynamic is one which FoNP has experienced for years with regard to the extremely deteriorated poured-in-place (PIP) playground surface at Noyes Park – a situation in which all government agencies continue to refuse to accept responsibility for resolving a critical, longstanding, and significant problem that negatively impacts childrens’ health and safety despite ongoing advocacy, significant community involvement, and continued surface deterioration.

No Resolution for Issues Outside the Scope of Annual Maintenance Costs

PIP playground surfaces—a failed technology that has been shown to result in increased exposure opportunities to hazardous chemicals, including lead—were prioritized by DPR and in cities across the US for use in playground construction due in large part to their low need for maintenance. The Noyes Park PIP playground surface has demonstrated critical structural failures of the technology itself and the agencies charged with maintaining it since its installation.

The rapid and prolonged deterioration of the Noyes Park PIP playground surface is a key example of a park safety and usability issue that “falls through the cracks” of the ineffective operating structure by being too large of an issue for typical operations and maintenance fixes and budget administered by DGS, but too small to be a capital project under the oversight of DPR. The cost of this administrative dysfunction is borne out in the following ways:

increased slip, trip, and fall injuries to children utilizing the Noyes Park playground,
more opportunities for dermal, ingestion, and inhalation exposures of hazardous chemicals likely in the deep layers of PIP surface that are visible throughout the playground, and
a DPR park asset that appears unkempt and uncared for despite an active and engaged “Friends of” Park Partner and the general enjoyment of the park by community members.

Park Partners Alone Cannot Solve Structural Operational Failings

The Ready2Play Master Plan cites growing the prevalence and influence of “Friends of” groups by “expanding and enhancing partnership agreements and DPR’s capacity to address day-to-day maintenance concerns” (Action 4.A.4) as a strategy toward ensuring transparent, efficient, and engaged operations. The approach will only be successful if existing administrative inefficiencies and dysfunctions associated with park operations and maintenance activities are eliminated or Park Partners are given significantly more oversight on the operations, maintenance activities, and budgets specific to their sites.

FoNP has used all proper channels time and time again to request maintenance on the PIP playground surface, including submitting 311 tickets and direct communication with DPR and DGS liaisons and maintaining photo records of continued surface deterioration over time to demonstrate the scope and severity of the issue. FoNP has also led advocacy efforts on social media and through a community letter-writing campaign to engage DPR, DGS, the DC Council, Mayor Bowser’s office, community liaisons from various government agencies, and the Chair of the Council’s DGS Oversight Committee, among others to draw attention to this increasingly severe situation. This effort has continued for over 5 years with relatively little response from DC agencies and no resolution to the issue.

DPR’s own recommendation to extend the concept of Facility Condition Assessments to smaller parks to provide conditional assessments of park properties (p. 47)—while good in intention—needs credible oversight, transparent reporting on progress, a clear mechanism for park partners to escalate critical issues, and methods for accountability when agencies fail to uphold their responsibilities.

This is not a sustainable way to maintain DPR park and playground facilities – and, more importantly – this reality will keep current and future Park Partners and “Friends of” groups from delivering on the goals and objectives DPR lays out for them in its Ready2Play Master Plan.

RECOMMENDATIONS
Friends of Noyes Park strongly recommends our involvement in implementing (or piloting the implementation of) a number of Key Recommendations outlined on page 111 of the Ready2Play Master Plan. These recommendations are pivotal to achieving the intended outcomes of the Ready2Play Master Plan and also tend to be the types of activities that are deprioritized because they are complicated and challenging to administer successfully.

GR.16: Use the Equity Index to prioritize sites to proactively audit and engage communities around ongoing maintenance concerns.

Noyes Park is an ideal candidate for a site audit and community engagement process given our well-established maintenance issues, and documented history of efforts to resolve these issues through existing processes available within agency structures. The Friends of Noyes Park can provide thoughtful and insightful feedback on the audit and engagement process to ensure it delivers on effectiveness in identifying issues and results in issue resolution.

GR.17: Work with DGS to develop an updated process for estimating annual maintenance costs.

The Friends of Noyes Park is an ideal candidate to provide DPR and DGS case data on the various types of maintenance issues present at small parks with a variety of amenities, describe how these various issues fail to be adequately served by the existing maintenance budget planning and implementation, and offer strategic recommendations for budget planning, implementation, and oversight models that would address the existing gaps.

GR.18: Develop park-specific maintenance and operating budgets.

The Friends of Noyes Park is an excellent candidate to pilot the concept of park-specific maintenance and operating budgets. Our organization has strong governance structures, has maintained compliance with our DPR Cooperating Agreement, and promotes equity and transparency through our park stewardship activities. FoNP could serve as a test case to explore the opportunities and challenges associated with park-specific maintenance and operating budgets, present opportunities for strengthening partner relations among Friends of groups, DPR, and DGS, and help design a scalable program for site-specific budgeting.

GR.19: Expand DPR’s Level 1 (Ready Team) to tackle routine and emergency maintenance tasks not currently under DGS’s oversight.

The Friends of Noyes Park is an excellent candidate for engaging with the Level 1 Ready Team to understand their scope and purpose, determine how they could more strategically serve park spaces, and leverage the Park Partner model to increase park user experience and customer satisfaction by demonstrating timely and transparent resolution of routine and emergency maintenance issues.

The Friends of Noyes Park is an established, well-known, financially solvent organization that is trusted by community stakeholders including individuals, businesses, schools, peer civil society organizations, and government agencies alike. We have been an active advocate for Noyes Park for nearly a decade, bring a deep understanding of the realities, opportunities, and challenges associated with partnership models to steward public goods, and are interested in tackling and demonstrably improving complex operational and administrative challenges.

We believe that our organization can play a key role in advancing critical objectives and recommendations put forth in DPR’s Ready2Play Master Plan that will create meaningful benefits for not only Noyes Park, but also parks, public spaces, and recreational facilities throughout DC.

We look forward to our continued engagement in this process.

Thank you,

Christina Macken
On behalf of the Friends of Noyes Park Board of Directors