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Thursday, September 17, 2026

Kenya Gibson has questions.


Re: Code Refresh From Gibson, Kenya J. - City Council
Date: Thu 9/17/2026 4:30 PM
To: Drewry, Laura K. - City Attorney
Cc: Avula, Danny - Mayor ; Breton, Andrew S. - City Council ; Jones, Nicole - City Council Office ; Robertson, Ellen F. - City Council ; Lynch, Stephanie A. - City Council Office ; Donald, Odie - CAO ; Vonck, Kevin J. - PDR ; Warren, RJ A. - Council Chief of Staff ; Wijesooriya, Lawson - Mayor's Office ; Newbille, Cynthia I. - City Council ; Jordan, Katherine - City Council ; Abubaker, Sarah M. - City Council ; Trammell, Reva M. - City Council ; Elliott, Sarandon C. - City Council 

Hello,
Thank you for this update. I appreciate your interest in ensuring your team has sufficient time to conduct a robust review of the Code Refresh ordinance. This code will have a sizable impact on our city far beyond our terms in office and needs to be thoroughly vetted. 

There are several aspects of the proposal and process that I think need to be clarified from a legal standpoint, so I’m seeking your guidance. 

First, how does the Administration consider the Code Refresh to align with the Planning Commission’s obligation under Va. Code § 15.2-2230 to review the Comprehensive Plan at least once every five years? 

Second, given that Council Resolution 2025-R039 expressly directed the Planning Commission to prepare and adopt a Richmond 300 amendment establishing the Five Points Neighborhood Node as part of that required Master Plan review, and that amendment is not reflected in Draft 3, what is the legal basis for adopting a comprehensive zoning rewrite before that Council-directed Master Plan work has been completed? 

Finally, the Planning Department has commissioned studies showing that the increased development projections driven by Code Refresh significantly overlaps with the City’s combined sewer area. Given the City’s obligations under the CSO Consent Order, Council Resolution 2022-R025, and planned development in the Diamond District, what documentation or analysis is legally required to establish that the Code Refresh will not interfere with the City’s compliance with those obligations? 

I recognize a written analysis/opinion on even these specific components may take time to put together, so let me know when you think this would be feasible. 

Kenya Gibson
Councilmember, Richmond City Council
Richmond Northside 3rd Voter District
900 E. Broad Street, Suite 305
Richmond, VA 23219
Office: (804) 646-6055 kenya.gibson@rva.gov