The Honorable Danny Avula, Mayor
The Honorable Katherine Jordan, Richmond City Council
900 E. Broad Street, Suite 305
Richmond, VA 23219
BY HAND DELIVERY AND EMAIL
October 9, 2026
RE: Code Refresh Version 3 (“CR .v3”) - FDA Procedural Objections
Dear Mayor Avula and Councilwoman Jordan:
As you are aware, the Fan District Association (“FDA”) has been carefully reviewing Code Refresh (“CR”) since its inception. We have spent hundreds of hours trying to understand the policy implications of CR and trying to educate our community on CR. As examples of these efforts:
- We have hosted several meetings and zoning “office hours” in order to provide our community with multiple opportunities to ask questions and share their opinions on Code Refresh;
- We updated our website to include information about Code Refresh;
- We provided written comments to the City, in the form of resolutions and position papers, copies of which are attached hereto as Exhibits A, B, and C;
- We included CR as a topic in most FDA newsletters;
- We participated in many joint neighborhood association meetings about CR;
- I served as a late citizen appointee to the Zoning Advisory Council (“ZAC”) and have kept the FDA Board informed of all conversations around CR; and
- Members of the Board participated in dozens of City meetings on CR and related topics.
The FDA has been thoughtful and measured throughout the CR process. This review has taken immense amounts of time, energy and effort.
We are writing today with grave concerns about the process for review of the “final” version of CR. Before CR .v3 was released on August 17, 2026, an interim “version” was released to the public in June 2026. At that point the City represented that there were only three (3) open issues to be resolved: (1) the definition of “family;” (2) the treatment of churches and places of worship; and (3) the “2+1” rubric of one (1) duplex plus an accessory dwelling unit (“ADU”) on every residential lot in the City. The FDA at that time released a Position Paper (Exhibit B) and a Resolution (Exhibit C). The very first point in that resolution is that the FDA disagrees that those three (3) issues are the only three (3) issues in dispute.
We do not intend to raise the substantive issues of CR .v3 today. The purpose of this letter is to point out the significant flaws in the proposed process for review and adoption of CR .v3. In the interest of brevity, we will list these as bullet points, in no particular order of importance.
- While we appreciate that the City has opened the CR .v3 map for three (3) weeks of public comment, this is inadequate.
- There is no methodology for public comment on the formal CR .v3 ordinance, other than “come to your Councilperson’s CR meeting” or “send an email.” The CR .v3 ordinance is a legal document that exceeds 350 pages and covers all 77,000+ parcels of land in the City. Having no formal channel for review is inadequate and unacceptable.
- There is no central repository for the public comments being received by the Administration, Council, and PDR, as was provided for CR .v1 and CR .v2. The Administration should document all comments in a public place in the interest of transparency.
- CR .v3 introduces brand new zoning categories such as “Campus” and “Multifamily - Suburban” and major changes to controversial issues such as the size of ADUs and zoning for houses of worship.
- ZAC was prematurely dissolved as of September 9, with no formal discussion of CR .v3, and with no notice to ZAC members.
- There have been no independent studies provided to the public of the demolition potential under the CR .v3 regime, particularly in corridors with existing affordable housing or the many neighborhoods in the City on the National Register of Historic Places, but without “Old and Historic District” designations. The RKG Analysis provided to the City to address legitimate concerns about the feasibility of demolition (Exhibit D) is wholly inadequate, especially when compared to the RKG analysis provided to the City of Charlottesville during their rezoning process (Exhibit E).
- There have been no independent studies of the impact of additional development under the CR .v3 regime on the infrastructure capacity of the City.
These are not insignificant issues. Any one of these is a fatal flaw in process and procedure.
As you know, the Fan District is one of the, if not the, MOST densely populated neighborhoods in the City. The Fan District is an example of the kind of mixed-use development the Richmond Master Plan (“RVA300”) encourages. We want to be crystal clear: We do not oppose reasonable and thoughtful density. We do not oppose reasonable mixed-use and multifamily development. In fact, in the seven (7)+ years that I have been on the FDA Zoning Committee, I cannot recall a mixed-use or infill development which was formally opposed by the FDA. As examples, the following infill projects have not been opposed¹ by the FDA during my tenure on the FDA Zoning Committee:
- 1516 Rear Plum (conversion of historic commercial building into residence);
- 2516 Rear Stuart (conversion of historic building into apartments);
- 2618 Rear Main (infill for-sale townhome project, number of units negotiated down from initial proposal);
- Robinson Parking Lot infill project (multiple apartments over retail on Starbucks parking lot);
- 2602-2606 Grove (conversion of 21 existing units to larger luxury units, although we will oppose if no steps are taken to protect Rick’s Garden) and
- Multiple ADUs².
¹ Note, the FDA’s formal position is we do not “support” any Special Use Permit (“SUP”) project, we either “oppose” or “do not oppose” any SUP project.
² In fact, in at least one instance we favored more flexibility for the homeowner building an ADU than Councilwoman Jordan ultimately supported.
The Fan District has accommodated, and will continue to accommodate, reasonable infill development. However, we remain concerned about how unfettered development could impact the significant and immensely valuable historic character of our neighborhood. A zoning code that encourages the tear down of viable historic structures, be they in the Fan, Carver, Jackson Ward, Oregon Hill, or any one of a multitude of other historic communities in the City, in favor of just “more” is not good policy. In fact, a zoning code that encourages the tear down of viable historic structures is contrary to the goals of RVA300, the Cultural Heritage Stewardship Plan, and multiple climate goals formally adopted by the City.
We trust the City will reconsider their approach to CR .v3. The public deserves the right to weigh in on this critical piece of legislation in a thoughtful and measured way, after an appropriate amount of time and education. The current proposed approach is rushed and inadequate for a proposal of this significance.
We stand ready to work with the City’s elected officials to achieve the laudable goals of RVA300. A transparent, documented, and legally defensible CR .v3 outreach process is required. With appropriate care and citizen input, we know we can achieve the objectives of RVA300 while preserving what makes Richmond, Richmond.
Sincerely,
Melissa L. Savenko 10/09/26
Melissa L. Savenko
Chair, FDA Zoning Committee
Cc: The Honorable Andrew Breton
The Honorable Kenya Gibson
The Honorable Sarah Abubaker
The Honorable Stephanie A. Lynch
The Honorable Ellen Robertson
The Honorable Cynthia Newbile
The Honorable Reva Trammel
The Honorable Nicole Jones
Attachments:
Exhibit A: FDA Position Paper No. 1
Exhibit B: FDA Position Paper No. 2
Exhibit C: FDA Resolution
Exhibit D: RKG Analysis for the City of Richmond
Exhibit E: RKG Analysis for the City of Charlottesville








