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.

Does Code Refresh's “Preservation Bonus” Incentivize Mansionization?

Does Code Refresh's “Preservation Bonus” Incentivize Mansionization?

Many neighborhood lots (like Southside's Woodland Heights, pictured) allow gentle density while protecting their irreplaceable existing tree canopy, their soil for food resilience, and sunlight to allow sustainable solar opportunities that thoughtfully enhances a thriving (not snuffed-out) community.

The Preservation Bonus Promotes Affordable Local Housing, NOT Mansionization. But Before We Consider Duplexes, FIRST: Remove Illegal Airbnbs And Co-Hosts, Returning Those Rentals To Richmond. Second, Keeping ADUs 500 Square Feet Keeps Those Units Affordable!

A critic complains Richmond's proposed Preservation Bonus will lead to Mansionization: replacing modest homes with oversized mansions, as “that’s the only way developers can make money.” This concern fundamentally misunderstands how the Preservation Bonus works. The Preservation Bonus incentivizes multi-unit development, not larger single-family homes, while protecting Richmond’s authenticity. To receive the Preservation Bonus to add density, property owners must preserve existing structures rather than demolish them.

But before we explore this, look around YOUR dense neighborhood: block after block now teems with Airbnbs that used to be affordable rentals. Overwhelmingly, they are owned by illegal out-of-town investors, and operated by illegal co-hosts. SHUT DOWN this overwhelmingly illegal business that removes affordable housing FIRST before considering adding more illegal rental fuel to the luxury profiteering fire! 

When zoning shuts down illegal co-hosts, it is suddenly extremely difficult for far-away property owners to manage their illegal, revolving-door, short-term rentals. They are then incentivized to return the rental to local, annual leases.

Zoning must keep ADUs to 500 sf for an added local benefit: when rented, those units remain affordable… permanently! Keeping ADUs to 500 sf is a barrier to illegal short-term profiteering, as the majority of luxury short-term rental bookings are for 2-4 people. ADUs at 500 sf adds more housing opportunities for tenants who aren’t families, yet can still accommodate two bedrooms for those who are.

Mansionization is enabled when zoning removes size, setback, and lot coverage constraints. Out-of-town large investors prefer new builds with more units. Preservation requirements favor locals!

The Preservation Bonus explicitly rewards keeping neighborhoods intact while adding housing, creating smaller, thus more affordable units. 

Ask instead: Why has zoning not shut down the infiltration of illegal Airbnbs choking our city? Why does zoning staff support the profiteers who removed over 1,000 of Richmond’s affordable apartments to become illegal luxury rentals?

Loosening Zoning Does NOT Lessen Our Affordable Housing Crisis.

Above: This rancher, an example of existing affordable housing (in Richmond's historic Frederick Douglass Court neighborhood) is zoned RD-C in Code Refresh's Draft 2 to densely carve up lots to 25' (about the size of a food garden) and allow higher lot coverage (up to 75% paved over) in the name of "solving the housing crisis." Communities' resilience and sustainability opportunities are more valuable than concrete.

Loosened zoning does not lessen our affordable housing crisis.

The authors of a study on whether (and how fast) density brings more affordable housing to cities are Michael Storper (Distinguished Professor of Regional and International Development in Urban Planning and Director, Global Public Affairs at UCLA Luskin School of Public Affairs), Gregory Randolph (World Bank consultant and writes on Southeastern urban policy), Tom Kemeny (has held positions at the University of Southampton, the London School of Economics, and the University of North Carolina at Chapel Hill with a PhD in Urban Planning from UCLA) and Maximilian Buchholz of UC Berkley.

I do not have their expertise, so I will not paraphrase, but let them tell you what they found:

"A popular view holds that declining housing affordability stems from regulations that restrict new supply, and that deregulation will spur sufficient market-rate construction to meaningfully improve affordability."

"Part of the appeal of the deregulationist narrative is that it suggests we can achieve affordability without major changes to labor market structure or significant public investment in the housing sector."

The study then proves density INCREASES housing costs:

"... increased access to jobs and amenities will make those same locations more expensive; they will not make desirable locations affordable to households facing onerous cost-burdens, and may in fact worsen their outcomes..."

Housing costs track income, even in cities with no zoning like Houston.

San Francisco's 48 Hills expounds further:

"The study looks at the reality of housing construction, as opposed to the Yimby fantasy.  

Eliminating 'constraints' is not going to lead to much more new housing, certainly not affordable housing, as long as the market is driven by for-profit developers..."

Yet C3 Climate Collaborative continues the constraint narrative, stating, "Multiple advocates C3 interviewed referenced zoning as a key contributing factor to unaffordability in the area..." to push blanket density.

What if we completely removed zoning constraints and built tens of thousands of units a year as C3 Climate Collaborative, Homes for All Our Neighbors, and RVA YIMBY want? We would crush Richmond communities' resilience and sustainability opportunities that exist on residential lots.

But even with unrestricted upzoning and wildly unrealistic construction, housing prices would NOT lessen for 20-100 YEARS.

Why would anyone allow density to jeopardize communities' sustainability just for developers to profit?

"In the San Francisco Bay Area, where the mismatch between prices and non-college wages is the largest, even under the highly optimistic lower bound scenario it would take about 20 years for house prices to become widely affordable; under the upper bound scenario, it would take over 100 years."

By now, you know that RICHMOND does not need 39,000 new units of housing. That figure was for the Richmond REGION, over 2,000 square miles, not the city's 62. (Read the report! "Richmond Regional Housing Framework 2020-22 Data Update” p. 2, TinyUrl.com/RVAhousingNeeds)

Now you know that concreting over our communities' soil and trees will NOT lower housing costs. Even in 20-100 years. 

Our existing affordable housing, sustainability, and resilience matter more than developers' income.

Above: This existing affordable home in Richmond's Peter Paul neighborhood is enjoying solar opportunities that benefit residents' utility costs and health. Code Refresh will allow density to wipe out resilience in favor of developer/YIMBY interests. This historically under-resourced neighborhood is part of a larger community with high socio-economic challenges, including nearby Creighton Court. They should not have density wipe them out!

Below: Richmonders enjoying a food garden and urban coop tour. We value soil and resilience!

For existing communities, resiliency is more important than density. Resiliency opportunities on residential lots must not be paved in the name of density.

Author: Richmonder Copeland Casati volunteers for resilience and sustainability initiatives from cleaning up public parks, legalizing urban hens (with her fellow CHICKUNZ volunteers, a group she founded to allow urban hens in Richmond), was a past host of Green Drinks, and, to increase her community's resilience further, founded a free babysitting co-op. When not in the city, she lives in an affordable, energy-efficient, passive solar, off-grid home.