Make Your Voice Heard

Hello Mayor Avula, Councilmember Sarah Abubaker, Director Vonck and Deputy Director Pitts,

I am writing as a resident of Stratford Hills and a member of Stratford Hills Civic Association. I appreciate the improvements made in Code Refresh Revision 3 to eliminate the duplex + ADU "tri-plex" scenario. This was a notable improvement. Thank you.

HOWEVER, many of my neighbors still have significant concerns especially as it relates to Stratford Hills / Oxford / Southampton neighborhoods that are uniquely positioned along the James River and contain sensitive areas designated in the Chesapeake Bay Act. We believe that especially for our neighborhoods, rolling this out without a comprehensive environmental, infrastructure and economic impact studies would be short-sighted.

Our neighborhoods were developed primarily around the mid-1960s, concurrent to the major land gifts that established the James River Park System as part of an effort to preserve the shoreline and falls for public recreation. JRPS and the surrounding forested neighborhoods not only provide huge pollution and heat mitigation to the City of Richmond, key spots within this watershed like Pony Pasture and Huguenot Flatwater are gems that portray one of the most charming features of Richmond life along the James. This area is frequently featured in marketing to visitors and prospective residents, as well as recently featured in a music video from Grammy-award winning Lucy Dacus. We think there is a lot of economic and environmental value to the City that would be put at risk if the impacts for this unique neighborhood and watershed are not properly studied and considered.

Given we were initially developed as a rural suburban area with narrow winding streets that accommodated large lots developed among an established forest, steep hills, winding creeks, springs and historic hunting lodges - there are really unique impacts and considerations that should be reviewed closely.

Infrastructure impact specific:

• Our existing neighborhood roads are very narrow, including some with steep drop offs instead of sidewalks. We see emergency vehicles coming to homes in our neighborhood and cutting through our neighborhood regularly. We have families and children that walk our narrow streets daily. We need to understand the expected road and parking requirements to safely add density in this area which was not designed with density in mind.
• Our water mains and sewage lines have frequent breaks, and aren't in a position to scale with additional development. It would be helpful to understand how these infrastructure improvements are being paid for and if they are already in the works or planned.
• We've recently seen an increase in school-aged children moving into the neighborhood (a shift which we love to see). It would be helpful to understand the impacts on schools and the readiness of our nearby schools, magnet schools and bus systems to accommodate an even greater increase in number of children.

Environmental impact specific:

• As we are uniquely positioned in the James River / Chesapeake Bay watershed, we are particularly interested in understanding the environmental impacts of this proposal - including tree canopy, watershed and flooding, as well as wildlife habitat impacts. Some locations with particularly hilly terrain already experience significant erosion issues and water run-off. The entire neighborhood character centers on "living in the woods" and "among the birds and wildlife" that thrive in this river adjacent ecosystem. We see ourselves as stewards of the established forest ecosystem that provides so much value to the City.
• In the past decade, we have seen homes built that had always been thought to be "not buildable under Chesapeake Bay Act". We are concerned that the City's approvals of newer construction in areas near creeks and high-erosion risk areas may already be non-compliant. We'd like to better understand the City's views in regards to these sensitive areas in general, and more specifically what the process will be for construction permitting to ensure that future building is compliant with the intent of the CBA which not only protects the food producing economic engine of the Chesapeake Bay, but also the James River that runs through the heart of Richmond.

The Stratford Hills Civic Association is asking a number of clarifying questions about Revision 3 - including implications of the new 1,200 square foot ADU footprint and the new by-right permission of 5 adults per unit (which we read as up to 10 adults on one lot if an ADU is in place) as well as conditional group home uses to further expand group living scenarios. These are real tangible concerns that we need to clarify and address. But in the interim, we want to reiterate to you the underlying concerns that this Code Revision does not seem to take into account the unique environmental and economic impacts for this neighborhood and the James River Park System.

If a City wide comprehensive environmental, infrastructure and economic study is not forthcoming, we would at least like to see our neighborhoods carved out for further study.

Sincerely,
[Your name]