Advocacy News - Letter to Charlottesville Planning Commission on the Comprehensive Plan
A version of this letter was recently shared with the Charlottesville Planning Commission and City Council.
On October 12, 2021, the Planning Commission and City Council held a Joint Public Hearing on the Comprehensive Plan (Future Land Use Map and chapters). The Planning Commission is hoping to have the Comprehensive Plan and FLUM approved by Council by the end of the year. You can download the full draft Comprehensive Plan here.
Dear Charlottesville Planning Commission,
Following on our statement from July 2021 on the draft Future Land Use Map (FLUM), Preservation Piedmont sends these comments and concerns and asks that you please consider the following during the proposed development of changes to Charlottesville’s land use.
Our FLUM should encompass the narrative goals of the Comprehensive Plan, including protection of historic and natural resources, neighborhood preservation, and efforts to decrease the impacts of climate change. Our viewpoint is that preservation is about managing change — not about freezing our city in time. To that end, we request:
Change management and regular evaluations as implementation goals of the Comprehensive Plan, which is initiating dramatic changes in land use and building types,
An invitation to the Board of Architectural Review (BAR) for inclusion in the planning process to assess the anticipated outcomes of this plan on the city’s historic resources and Design Control Districts,
No rollbacks of environmental protections in the city for critical slopes, flood plains, specimen trees, concentrated tree canopy and other environmental resources, and
The addition of at least one voice for preservation to the C’ville Plans Together steering committee. Preservationists know how to rehabilitate, sensitively develop through infill, and when to preserve or replace historic building materials.
On commercial and business areas: Preservation Piedmont supports continued
preservation policies and adaptive uses for the Downtown Mall and its adjacent and nearby
streets. We support continued growth and mixed-use redevelopment at higher intensities for
Barracks Road, Seminole Square, the 5th St Shopping Center, and Carlton Avenue to strengthen our local economy and increase housing supply.
Research shows that the most affordable and greenest structures are those already built, and
so we urge the Planning Commission, Consultants, and City Council to prioritize the
preservation of our historic areas and buildings and support their upkeep and rehabilitation.
On housing: We are encouraged to see some safeguards proposed for several neighborhoods sensitive to displacement, like Rose Hill and 10th & Page and other areas with concentrations of low-income residents. This plan should provide more details and reassurance that preservation and affordability are implementable in such areas if their residents support it. Historic Conservation Districts (HCD) might be an effective tool if the effort is organized and led by neighbors.
Removing the R-1 designation in our zoning ordinance is a big step in the quest for affordability and greater equity. If that is the goal, it must be done carefully; the current height designation is encouraging, and the latest map appears to focus intense development in smaller, defined areas rather than distributing the highest density throughout the city.
To ensure this change does indeed promote affordable and livable neighborhoods all over our city, and to gain community buy-in, removing the R-1 zoning will require detailed assistance for homeowners in financing, site planning, building design, and rehabilitation guidance. The plan would be strengthened with incentives to develop greater density in an additive manner (with ADUs, new additions, and subdividing existing structures into multiple units) and/or disincentives for demolition. Existing housing, especially in once affordable areas with historic resources (whether designated as historic or not), should not be vulnerable to demolition, but should be rehabilitated using best environmental and design practices. The Cville Plans Together consultants have estimated that the possible rezoning from this plan will produce only 42 new affordable ADUs and multiplex units per year — approximately 420 new units over the next decade out of the 4,000 affordable units currently needed.
Medium Intensity Residential: Preservation Piedmont, like many others who are examining the draft FLUM, is concerned about current descriptions and corridors for the Medium Intensity Residential land use category. It is worrisome that there are no requirements for affordable units in a 12-unit structure. This would be a gift to developers but would not assist with the city’s goal of increasing our supply of truly affordable housing. Please consider allowing a smaller number (perhaps 4) units in Medium Intensity Residential areas, with 5-12 units permitted only if the developer includes a certain number of affordable units in their plans.
Design Control Districts: While we hope to see even more details addressing how all areas with historic buildings will be protected from demolition, we are especially waiting to see details for those that are Architectural Design Control Districts (ADCs), contributing properties for the National Register of Historic Places, and other significant but undesignated areas and buildings. The relationship between the FLUM and these districts is still unclear, so we ask that the city provide the Board of Architectural Review (BAR) an opportunity to assess the anticipated outcomes of this map on the city’s historic resources. The BAR is extremely knowledgeable about new development in the city and often addresses development at a more detailed level than even City Council or the Planning Commission. They are one of the most qualified such boards in the state and have a range of design and planning talent and experience that could inform and refine this plan before it gets to the stage of zoning development. A disproportionate number of the higher intensity development corridors in the draft FLUM are drawn in designated ADC and HCD areas and areas with pedestrian, cyclist, and traffic conflicts and constraints.
The environment: We do not support the rollback of hard-won environmental protections. We expect the plan to retain environmental protection for critical slopes, flood plains, specimen trees, stream corridors, concentrated tree canopy and other environmental resources. Furthermore, we need a plan that is cognizant of actual on-the-ground conditions: historic buildings, distinctive cultural areas, narrow streets with narrow or even no sidewalks, and the relationship between development potentials and current lot sizes, parcelization, and adjacency characteristics. We have expected that each iteration of the land use map would arrive at an analysis phase that would justify the plan. To this point, the plan does not reflect this type of deep knowledge and understanding of our city. A localized analysis process is essential to explain, refine and finalize a plan that is environmentally responsible.
Our current critical slopes ordinance, reviewed and revised within the last decade, should remain a vital part of the development process because it is an important construction parameter that protects our streams, creeks, and rivers against the impacts of erosion and pollution. While developers seek exemption from its provisions and substitute engineered solutions, experience has shown that natural buffers are the best way to protect water resources.
City increases in density should not be at the expense of our tree canopy that helps mitigate the effects of climate change and provides health benefits in shade and natural beauty. Charlottesville is one of the densest jurisdictions in Virginia, but density is only one climate change tool. As a community, we value our tree canopy and open spaces. Trees buffer the visual and auditory impacts of intensive development. Decreasing our city’s heat islands, concentrated in our poorest communities, should be an environmental justice goal and included in all new and re-developed areas. Street tree canopy should remain a high priority despite developer calls for street tree removal.
Official inclusion of preservation voices: The consultant team continues to say that a lot of the details will get worked out in the zoning code update, and we are looking ahead to that process. We volunteer and ask that the City add at least one representative of our core advocacy committee to the steering committee. Preservationists know how to rehabilitate, sensitively develop through infill, and when to preserve or replace historic building materials.
Neighbor against neighbor: We are concerned that this planning process--that was intended to be reparative of historic harms and exclusions--is now pitting neighbors against neighbors, and people who own homes against people who rent homes. This result is against every precept of community engagement.
Preservation Piedmont’s members and supporters come from our entire region. They include the young and the old, people of different backgrounds, people of different races, the homeowner and the renter, old-timers, newcomers, and those along a whole spectrum of incomes. Most importantly, we all share a love and concern for the Piedmont region and for the City of Charlottesville — the region’s largest city; major employment, medical, and educational center; and visitor destination. We care about how we plan and grow. We ask that you complete this process while remaining attentive to all considerations.
Future communication: Preservation Piedmont will continue to examine the plan revisions and any new version of the FLUM, and we will continue to make additional comments and recommendations as the process continues.
Thank you for your attention,
Rebecca L. Deeds
President, Preservation Piedmont