Why would Code Refresh destroy our homes?

Neighbors ask: "Why would Code Refresh destroy our homes?"

In Jackson Ward, the average home is 1,800 square feet. In Randolph and Westwood, 1,300 - 1,400 square feet. Maymont's average home is 1,100 - 1,500 square feet, and in Swansboro, 1,300 - 1,550 square feet.

Church Hill 's average homes span 1,500 - 2,500 square feet; Carver's, 1,600 - 1,660.
The City Stadium neighborhood typically averages around 1,200 to 1,400 square feet. 
Bellevue ranges between roughly 950 to 3,500 square feet.

Does Code Refresh intend to demolish average/smaller Richmond homes to build LARGER duplexes that fill these lots?

Does Code Refresh intend to destroy our existing small ownership opportunities for permanent rentals?

Today, renting a 1,500 sq ft apartment falls between $1,700 - $2,400+ per month.

If Code Refresh *really* cares about AFFORDABLE HOUSING (or the environment!) it would keep additional units small, 500-800 square feet, and focus on RETROFITS.

About 60% of Richmond's housing is rentals. Shouldn't Richmond protect home ownership opportunities so families can achieve home ownership to pass on to future generations?

86% of renters WANT TO OWN A HOME.

Demolishing homes to create permanent rentals keeps the next generation from building wealth, weighing them down with permanent leases. Single-family rental households in Richmond grew 31% over the last 20 years, outpacing owner-occupied homes.

We already allow second units on every lot with ADUs, don't forget. We know the first thing developers are going to do, including the non-profit "affordable housing" developers, is knock down existing cottages (don't forget many neighborhoods' average homes are about 1,500 ft.) to build footprints twice as large just with two units. 

So the insults "green" and "affordable" YIMBYs hurl out as McMansionizing is actually what they intend to do: RentMcMansionize.

A new member added another layer of insight: by allowing duplexes, developers are tapping in to existing pipes without a mandatory infrastructure plan that would otherwise be required on new lots without infrastructure.

Is Code Refresh anti-ownership, anti-environmental? 
It's certainly not following Richmond 300.

Code Refresh must maintain today's unbuilt yard percentages to protect affordable housing and save Richmond's living, irreplaceable trees.

Code Refresh must maintain today's unbuilt yard percentages to protect affordable housing and save our living, irreplaceable trees.

Retrofits are Richmond's most powerful affordable housing tool - and they save trees.

Retrofits affordably modernize aging structures, keeping longtime residents in place instead of displacing them. They cut energy bills by 30% or more, directly lowering costs for low-income families. They improve health through better insulation and air quality. They cost far less than new construction. Retrofits don't destroy Richmond's irreplaceable trees.

Retrofits overwhelmingly preserve affordable housing AND our tree canopy. That's not a coincidence. That's smart, humane city-building.

WE NEED TREES EVERY SINGLE DAY, not just for Earth Month.

It's refreshing to hear planning and sustainability staff talk about trees, sunlight, and soil. (Last year, sustainability staff told us tall concrete was great because it puts neighbors in permanent shade and brings wind shear!)

But our lungs don't work on a calendar: Richmond needs every inch of tree canopy shading us in brutal summers, opening us to winter light, filtering our air, absorbing our stormwater 365 days a year.

Here's what's at stake:
- 2008: Richmond's tree canopy covered 42% of our land.
- 2018: 32%.
- Today: The average Richmond neighborhood has just 23% coverage.

Picture your block from above, only 23% trees. The rest? Concrete. No air filtration. No heat relief. No stormwater absorption. No food gardens. Just heat, flooding, and pollution.

We cannot afford to lose another inch.

Why do yards matter so much?
Because 85% of Richmond's trees are on private residential lots.

Not in parks. Not in tree wells along sidewalks. In yards, that Code Refresh is about to diminish.

Planners talk often about public tree wells, but they don't replace yard trees, and they can't. Public trees serve public space. They do not fulfill a private lot's obligation to its neighbors, just as a public park cannot substitute for private green space. That's not a technicality. That's the difference between a livable block and a heat island.

Tree funds don't work. Up to 50% of newly planted urban trees die within the first year. Ninety percent of tree funds fail. A mature, thriving tree is not a line item you can budget for. It took decades to grow. It cannot be replaced.

Reducing unbuilt lot percentages in Code Refresh is a direct attack on Richmond's health.

Eighty-five percent of our trees are in yards. 

Reduce those yard requirements, and you are choosing - in writing, in city code - to sacrifice the air quality, heat resilience, and livability of our neighborhoods. You are telling low-income residents that their block doesn't deserve shade. That their children don't deserve clean air. That their flooding doesn't matter.

Unacceptable.
Code Refresh must not only maintain today's unbuilt lot percentages, it must strengthen them. Every lot, including apartment buildings, should be required to support soil-based habitat, food-growing gardens, and tree canopy. Resilience isn't a luxury. It belongs to every neighbor, on every block.

Protect the trees we still have. Grow more. Code Refresh must protect Richmond, not destroy it.

Photos: Irreplaceable trees in Richmond's irreplaceable Bellevue and Frederick Douglass Court.

Concerned Over Code Refresh? Join the NeighborhoodS.

Concerned Over Code Refresh? Join the NeighborhoodS.

NeighborhoodS are concerned!

• Loosening Zoning Does NOT Lessen Our Affordable Housing Crisis.

• RKG Associates' Consultant Conflict: Beyond Subdivisions: Mapping the By-Right Density Expansion in Richmond’s RA and RM Districts

• Homes for All Our Neighbors is... MISLEADING and ANTI sustainability.

• Code Refresh Eliminates Family, to Bring Back Rooming Houses.

Don't believe a tuk tuk, WHERE'S THE INFRASTRUCTURE?

Want a sign? Order yours here.

That's not all that's missing. Stay tuned, for more.

December 5

We are pleased to see some changes to the proposed zoning codes and land use regulations in Code Refresh Draft 2, but believe that these zoning and land use reforms will mean monumental changes for neighborhoods city-wide, and so should be carefully researched and vetted for potential outcomes. 

We heard from neighborhoods who are not pleased with draft 2.0 and from others who have felt excluded from the conversation. This is worth taking our time to get it right and to engage as many stakeholders as possible, including those often marginalized. If you believe that the process should be slowed down to ensure that the process ensures open, effective dialogues with stakeholders, that we have as many tools as possible in the toolkit to incentivize the kinds of diverse and affordable housing as we need for our future, and that land use regulations regarding conditional uses and criteria for bonuses awarded to developers are clearly defined, then sign the petition today!

As we chew over Code Refresh's 2nd Draft, a few items come to mind:

1. The preservation bonus is a good step. Richmond values carbon life cycles and historic charm! Retrofit is 60% less expensive, greener than any new build, and doesn't displace residents! Carbon counts in whole life cycle impacts on communities, and thus there should also be a demolition tax!

2. We don't understand how sublots and duplexes will create affordable housing vs. removing affordable housing to become luxury rentals and short-term rentals remotely owned. Where is zoning's action on STR oversight on these majority remotely-owned illegal Airbnbs? Investors are already speculating on their next lucrative duplex possibilities that used to be affordable housing.

3. Land values continue to rise and upzoning raises them further! Displacement is underway.

4. Height transition standards must be driven by solar impacts! Mandatory shadow-modeling for anything over 3 stories to allow solar opportunities for ALL OUR NEIGHBORS! Richmond is supposed to be Net Zero by 2050.

5. Tree canopies must be protected and not diminished. Tree Removal Permits for any tree 4" in diameter!

6. We love adaptive reuse of churches, especially for affordable housing! YIGBY (Yes In God's Back Yard) is great but it seems like the majority of properties are simply being sold instead being redeveloped affordably. MX3 has huge implications on communities and should be more gentle.

7. WHERE'S THE INFRASTRUCTURE? We can't evolve without adequate sewer, solar, water, and other utilities. The Department of Public Utilities and Department of Public Works staff must be part of the Code Refresh process.

RKG Associates' Conflict: Beyond Subdivisions: Mapping the By-Right Density Expansion in Richmond’s RA and RM Districts

This quiet street, made up of mostly 2-story owned and rented homes, has now been zoned mixed-use 5 stories allowing 6 units by right. Investors are enticed, and local home buyers lose out.

An analysis submitted by a resident of Southside shows conflicts and missing data in RKG Associates' study that claims "...even under the most intense development scenario, Richmond’s citywide rezoning would lead to the addition of new units on just under 300 lots in existing single family neighborhoods annually."

"The Richmonder March 19 report on the RKG Associates study presents an incomplete dataset by focusing on 'subdivision feasibility' rather than volumetric density increases. While the study grounds its findings in RD lot constraints, it fails to account for the by-right density shifts in the RA (Residential Attached) and that Code Refresh made them RM-A (6 units), RM-B (12 units), and RM-C (unlimited Residential Mixed-use) districts.

1. The 1,200% Volumetric Loophole

The study calculates impact based on "new lots" created, ignoring unit-counts per existing lot. In the RA-C district (prevalent in the 23223 and 23220 zip codes), the 2026 Code Refresh allows for "Stacked Flats" of up to 12 units per building by-right. Replacing a single-family structure with a 12-unit multi-family building represents a localized density spike that requires no subdivision. By removing the Special Use Permit (SUP) requirement, the City eliminates the public's ability to audit the infrastructure load of these 1,200% increases before approval. 

2. Fiscal and Infrastructure Incompatibility 

The RKG study ignores the correlation between by-right density and the $47.6 million Department of Public Utilities (DPU) debt anchor.

• Administrative Incapacity: The Finance Department currently reports a 1/3 vacancy rate. 
• The Gap: A city that cannot project its own surplus—revising its $22M estimate down to $12.6M in February—cannot be trusted to monitor the tax compliance or physical load of 12-unit developments in neighborhoods where utility infrastructure is already failing to recover costs. 

3. Forensic Conflict: The 897-Page Nexus 

The "independent" nature of the RKG study is contradicted by SCC filing history. On October 4, 2013, an 897-page batch filing moved ​RKG Associates and thousands of development entities to a centralized administrative hub at 100 Shockoe Slip under Commonwealth Legal Services Corporation (a subsidiary of CSC). 

​RKG Associates shares the exact same Registered Agent and administrative infrastructure as the entities currently land-banking parcels in Blackwell​, a significant conflict of interest. The firm providing the "limited impact" analysis is structurally linked to the organizations benefiting from the rezoning. 

Furthermore, the August 13, 2015, Articles of Domestication for RKG is missing its digital image in the SCC portal, preventing verification of the signatures that link these out-of-state principals to Richmond land-holders. 

The RKG study is an analysis of lot layouts, not community impact. 

For Southside residents, a 1,200% density increase on 19th-century infrastructure is not "limited." It is a fundamental restructuring of our blocks without a corresponding plan to address the $47.6M utility deficit."

District	Pre Code Refresh	Post Code Refresh 2026	Impact
RA-B	1-2 units, duplex	Up to 6 units BY RIGHT	+300% density BY RIGHT
RA-C	1-4 units (Limited)	Up to 12 units BY RIGHT	Multi-Family By-Right Consolidation
RX-4	Variable height	Up to 4 Stories BY RIGHT	Commercial VERTICALITY

About the Author
I live in a historically Black neighborhood south of the James River with my wife and kids, where the sound of the river rapids and the 19th century train trestles are our daily backdrop. We walk our dog, Lucy, past the brick building  of the old Dunbar School and through the streets of Blackwell, while our cat, Tobi, stays home in our historic house. As a member of the Richmond Civic League, I value the preservation of these actual blocks over the abstract models used to justify citywide rezoning. I remain anonymous to keep the focus on the data, but I am a neighbor who sees the consequences of city planning every time I cross the T-Pott bridge.

Homes for All Our Neighbors is... MISLEADING and ANTI sustainability.

This quiet cobblestoned street, a mix of mostly 2-story renter and homeowners is now zoned MX5, allowing 5 stories to shade out neighbors. This will deeply impact the community's solar, soil, sustainability, and resiliency opportunities. 

To: Richmond Office of Sustainability
Subject: Opposition to Homes for all our Neighbors Manifesto
Date: March 18

Homes for All Our Neighbors (HOAN) Endorsement

The Richmond Sustainability and Resilience Commission has on your agenda this week an endorsement of a lengthy statement from Homes for All Our Neighbors regarding the rewriting of Richmond city’s zoning regulations. It is inappropriate for a city entity to support or join such a dubious private coalition.

Most people support the coalition’s stated goals of using the city’s proposed Code Refresh zoning overhaul to:

• “expand housing options,
• promote affordability, and
• prevent existing residents from getting pushed out”.

What is more debatable are the specific policies that are being proposed to try to implement these goals. While we are now in the period between the second and third draft of the proposed ordinance, I would ask you to re-examine and not support that organization’s statement. It contains a number of misleading or inaccurate statements, has one-sided information, and presents speculative assumptions.

In their online statement HOAN states -“What we know: Some of Richmond's most desired neighborhoods could not be built today. Zoning changes in the 1960s and '70s made it illegal to build popular housing types like many of those we see in the Fan, Jackson Ward, Carver, and Church Hill“

WRONG! - There are no “illegal” housing types in the city of Richmond (other than structures that don’t meet standard building codes for safety and construction integrity). There are tens of thousands of parcels in the city that are currently designated for duplexes and row houses. These lots allow construction of new houses exactly like buildings in these listed neighborhoods.

HOAN states - “It’s also illegal to build apartments in most parts of our city. Richmond’s current zoning code allows only single-family homes on 59% of the land here.”

WRONG! -There are apartments of all shapes and sizes in most neighborhoods in the city. There are now many areas that allow large apartment buildings in areas that recently were primarily commercial and industrial. Just look at all the new construction in Scott’s Addition, Shockoe Bottom, lower Chamberlayne Avenue, the Diamond District, and Manchester. Look at all the tall office buildings in downtown that are being converted to apartments.

American Heritage apartments in downtown's Central Business District.

There are no longer any single-family parcels in the city of Richmond. When the zoning code was updated two years ago to allow Auxiliary Dwelling Units (ADU), all residential parcels are now “multi-family”. 

HOAN states -“Renters are 58% of our population—a majority competing for a minority of space. Stiff competition drives up prices and pits neighbors against each other.”

MISLEADING! - The percentage of renters in the population has remained fairly steady in recent decades. It is a questionable assertion that there is link between zoning policies and availability of rental units. The economic evaluation has struggled to find correlations between availability of homes for purchase, and rental unit numbers and the availability/affordability of those units.

HOAN states - “In a 2023 resolution declaring a housing crisis, Richmond’s City Council estimated that we have a shortage of at least 23,000 homes.”

MISLEADING! - There have been a number of projections of the Richmond region’s population growth and housing needs incoming decades. These are regional projections and the population growth and related problems problems don’t stop at the city line. Henrico, Chesterfield, Hanover, and even New Kent are integral parts of the solution to area housing needs. Richmond is only a fraction of the area’s population and can’t be expected to solve issues on its own.

HOAN states - “Housing costs are historically high. Mortgage payments today for median-priced homes are double what they were in 2020. Average Richmond rents have jumped by a third in the same span.”

MISLEADING! - Housing costs are indeed high. This is a nationwide problem. Zoning is only a small part of housing cost. Construction materials, labor cost, and land prices all contribute to the total. The solution isn’t to build more houses in already dense and desirable neighborhoods where land prices are high. Affordable housing starts with acquiring and building on parcels where land costs are not as expensive.

HOAN states - “Richmond has room to grow: today’s population is 20,000 lower than in 1970. But the homes we have don't meet the needs of today’s neighbors and families.

MISLEADING! - While the city’s population has dropped over the last 50 years, the available housing stock has continued to increase. There are almost 40,000 more units now than in 1970. Therefore, the amount of housing units is not a direct factor in availability and affordability.

Note the lack of trees & permeability, how this concrete structure (and others) enhance Richmond's urban heat islands WHILE shading historic Black neighborhoods in concrete, permanently destroying their solar benefits in Newtowne West, Carver, Jackson Ward... but I bet those new towers have green roofs and solar for their luxury residents!

HOAN states - “Richmond's legacy of segregation means some neighborhoods have absorbed development pressure while others have been protected. If Code Refresh takes a truly citywide approach, we can ensure all neighborhoods contribute to solving our housing shortage, rather than asking a few to shoulder the entire effort. Richmond has an opportunity to expand housing choice and create less segregated, more inclusive neighborhoods—action required by the federal Fair Housing Act. Our current zoning code sharply limits where families of different backgrounds can live. Code Refresh could help reverse decades of exclusionary policy and create pathways to opportunity for all residents.”

WRONG! - The city’s current housing code was implemented (and has been updated numerous times) under minority leadership. The implication that the desire for zoning rules and preservation of existing neighborhood character is a racial issue is incorrect.

HOAN states - “RVAGreen2050, Richmond's Climate Equity Action Plan, notes that changing our land use and transportation patterns is critical to reducing emissions. Building more housing near transit, jobs, and services can create more walkable areas, resulting in fewer car trips and a greener, healthier city.”

WRONG! - The climate equity action plan and the city’s master plan have a number of environmental goals. Reducing emissions via the zoning update is just one small part. 

Code Refresh has largely ignored or negated many of these environmental protections in other city plans.

• First, there is the inability of the city’s current water, sewer, and stormwater utilities to handle the increased construction incentivized by the proposed rezoning. Much of the utility infrastructure is now 50 years older, and that the environmental requirements are now more stringent, than in 1970. Back then, the city was allowed to dump almost unlimited raw sewage in the James River whenever it rained. The city is now under a strict deadline to reduce its combined sewer overflow.

• More importantly, the dense zoning proposal doesn’t address the issue of the last mile connectivity. We have significantly more dwelling units now than in 1970. In 1970, there were almost 3 people in every dwelling unit. By 2020, the average number of people in each unit was down to 2.1. So while we have fewer people, we have more separate units and connections under our streets, but less capacity to add new units.
  
  
• The new zoning increases the allowable impermeable structures on most city parcels. This will also increase the environmental impact on the James River.
  
  
• The new zoning does for the first time specifically address the tree canopy. However, while there is a small incentive to keep current trees when developing, the plan does little to address the profound benefits of mature trees in carbon sequestration, shade, reducing the heat island effect, and reducing storm runoff.
  
  
• The new zoning proposals generally increase new building height, reducing the ability to use solar panels and have green yards.
  
  
• The master plan incentivized the development of transit corridors by calling for density to be focused on the high frequency transportation networks and the commercial nodes they connect. By increasing density across the board, the zoning proposals are in direct opposition to the goals of the master plan.

HOAN states - “Code Refresh—building on the city’s nationally award-winning master plan, Richmond 300—would make it easier to build the homes we need, gently adding to the landscape of housing options here while retaining neighborhood character through sensitive design standards and community engagement.”

WRONG! - Many of the proposals in Code Refresh bypass, or directly contradict, key elements of the master plan. By making many of the zoning options “by right”, there are no guard rails in place to retain neighborhood character or design. There is no opportunity for community engagement as under the current plan where special use permits require notice and discussion.

Thanks,

Rich Souser

The Author: Rich Souser is a resident of Northside.

Oregon Hill Home Improvement Council (OHHIC) on Code Refresh, Draft 2

Dear Richmond City Council members, Richmond Planning Department staff, and the Zoning Advisory Council,

Thank you for the opportunity for the Oregon Hill Home Improvement Council (OHHIC) to comment on the DRAFT 2 of the proposed city rezoning of the Oregon Hill Historic District. 

Please find the attached 23-page detailed comment in response to the "Code Refresh" proposals. 

As detailed in the attached 23-page comment, we strongly object to the appalling zoning proposals in the Code Refresh Draft 2 that would impose inappropriate MX-5 and RM-A zoning within the Oregon Hill Historic District of two-story homes.  We strongly object to the Code Refresh proposals to allow “By Right” maximum lot coverages of 60%, 70% and even 80% with no required back yards and allow building heights as high as 75 feet on some blocks.

We are very concerned that these and other inappropriate rezoning proposals threaten to undo all of the progress that OHHIC has made in the last 30 years in combining the twin goals of providing affordable work-force housing while preserving the historic homes of Oregon Hill.

The “Code-Refresh” proposals are so lacking in respect for the Oregon Hill Historic District that we urge our elected City Council members to name a new Zoning Advisory Commission, as authorized by Section 4.02 of the City Charter, to advise City Council on equitable rezoning for our city. There is little representation from the preservation community, environmental advocates or neighborhood leadership on the current Zoning Advisory Council, which was appointed by the unelected chair of the Planning Commission.

Please respect the input from OHHIC, which has successfully worked for over 30 years to improve the affordable housing and historic resources of the Oregon Hill Historic District. OHHIC has renovated 20 affordable homes and has built 16 compatible infill affordable homes in Oregon Hill. We are undergoing a renaissance of young families with children moving to the relatively affordable homes of neighborhood. Please do not undermine our successful efforts with ill-advised and inappropriate zoning. 

Please make the zoning changes recommended for Oregon Hill Historic District as detailed in OHHIC's attached 23-page comment.

Thank you for your consideration.

Sincerely,

Charles Pool

For the Board of the Oregon Hill Home Improvement Council

Code Refresh Eliminated Family, to Bring Back Rooming Houses.

Remarks before the Zoning Advisory Committee – Wednesday, February 11, 2026

My name is Patty Merrill and I am the President of the Westhampton Citizens Association.

I want to briefly highlight a topic that is worthy of discussion by the Zoning Advisory Committee. Under our existing zoning, we achieve limitations on the occupancy of a dwelling unit, in part, through the definition of “family” which applies to “persons living together as a single housekeeping unit” and, among other things, limits the occupancy of a dwelling unit to 3 unrelated individuals.

Code Refresh has eliminated the definition of family and, in doing so, has eliminated both the requirement that the group of people are living together as a single housekeeping unit and any limitation on the number of unrelated people living together.

Under Code Refresh, “household living” means “residential occupancy of a dwelling unit by a household. A household is considered one or more persons living together in a dwelling unit, with common access to, and common use of, all living, kitchen, and eating areas within the dwelling unit. Tenancy is arranged for 30 days or more.”

As for a limitation on occupancy of unrelated people in such household, you have to go to the definition of group living which starts at 9 unrelated people. Accordingly, one can deduce that the limit for household living is 8 unrelated individuals.

To date, I have been primarily focused on the alleged incremental density generated by number of dwelling units on a lot, particularly in single family detached neighborhoods. However, this suggests we also need to be very focused on the potentially exponential additional density resulting from the permitted number of unrelated people living in each dwelling unit.

I have done some informal research of other Virginia jurisdictions with a focus on those jurisdictions who have recently revised their zoning. The standard appears to be approximately 3 to 4 unrelated individuals. I would strongly advocate that Richmond adopt something similar. I would also like for Richmond to reintroduce the concept of “living together as a housekeeping unit” to reduce the potential for dwelling units being converted into rentals where no one appears to be responsible for the property and it is difficult to identify, let alone reach, the landlord.

Thank you. 

Author Patty Merrill is a 25-year resident of Richmond’s First District and President of the Westhampton Citizens Association.