Mr. Mark Olinger, Director
Planning and Development Review
5th Floor, City Hall
900 E. Broad Street
Richmond, VA 23219
July 28, 2012
Dear Mr. Olinger,
The Oregon Hill Neighborhood Association (OHNA), a neighborhood association lawfully incorporated in the Commonwealth of Virginia since 2001, has received the July 13, 2012 comment letter from the city staff regarding the Victory Apartments Special Use Permit (SUP) application for 407 S. Cherry Street and 811 Albemarle Street. Its contents were discussed by our membership in a meeting on July 24, 2012. We are troubled by the disregard of various ordinances and regulations of the City and Commonwealth by certain city agencies included in the response. These city agencies are ignoring or misapplying city zoning ordinances in order to make the current proposal for development of the Victory Rug Cleaning building work. The developer proposes a density three to four times what would be permitted under the current zoning, and this would result in a public safety and access risk if the project is allowed to rely on on-street parking on both sides of the 400 block of South Cherry at Victory Rug.
It is our belief that the lives and property of the inhabitants of the Oregon Hill neighborhood will incur dangerous risks should the SUP be granted with the noncompliant features that are included in the July 13, 2012 city commentary on the proposed project. We request that all applicable laws, parking ordinances and regulations be enforced as written. The R-7 zoning would allow 4-6 apartments in the Victory Rug building, and require a minimum of one off-street parking space for each unit in the development.
Please provide answers why the following regulations were disregarded:
1). In our correspondence dated June 27, 2012, we emphasized that none of the eight off-street parking spaces proposed for the SUP have the required 25 foot aisle width needed for 90 degree parking spaces for full sized vehicles as required in City Ordinance Section 114-710.3:1. Please explain why the July 13, 2012 city comment letter did not disqualify the proposed SUP’s planned 8 off-street parking spaces because they do not have the 25’ aisle width as required by law.
2). In our correspondence dated June 27, 2012, we stated that OHNA objects to on-street parking being used to satisfy the off-street parking required under the relevant city ordinance. Our residential neighborhood has serious parking problems because of Oregon Hill’s proximity to VCU; yet the city comment letter of July 13, 2012 cites the “methodology specified in the Zoning Ordinance for RF-1 or RF-2 districts, in which on-street parking spaces provided within portions of the public right-of-way abutting the street frontage of the property shall be credited as though they were off-street parking spaces located on the premises.” Oregon Hill is not within the RF-1 or RF-2 zoning districts, and even if the property was in the RF zoning district, the staff misapplied Sec. 114-710.2:3 by allowing three 22 foot parking spaces (66 feet in total) abutting the 45 foot street frontage of the Victory Rug building, and by attributing an equal number of parking spaces on the opposite side of the street – not abutting the building’s street frontage. Since the Oregon Hill neighborhood is not within the Riverfront 1 or Riverfront 2 (RF-1or RF-2) zoning districts, we must insist on knowing why staff is arbitrarily applying the parking and zoning “methodology” of another district to our district, which is within the R-7 zoning.
3). In our correspondence dated June 27, 2012, we brought to staff’s attention that the 400 block of Cherry Street is too narrow to safely support parking on both sides of the street at the location of the Victory Rug building, where the street is 25’-9” wide and narrows to 23’-3” wide at it’s intersection with Albemarle Street. The width of the 400 block of Cherry is significantly less than the VDOT minimum 28’ width design standard for residential streets with parallel parking on both sides of the street. We also pointed out that emergency vehicles would be unable to pass if vehicles were parked on both sides of the street, and that buses routinely park on the west side of the block to visit Hollywood Cemetery. We are dismayed that the city comment letter of July 13, 2012 states that, “… Cherry St. and Laurel St. between Spring St. and Idlewood Ave. are one-way streets with allowable parking on both sides of the street…” and allows the parking spaces on both sides of the 400 block of Cherry to satisfy the parking requirements of the Victory Apartment project. Since the 400 block of Cherry at the Victory Rug building is too narrow to safely park vehicles on both sides of the street and allow emergency access, please explain why the city commentary allows on-street parking on both sides of the street.
4). The city devoted much energy on developing the appropriate R-7 zoning designation for the Oregon Hill Historic District. This is exactly the type of development that should be guided by the existing zoning regulations in the best interest of the community. Under the R-7 zoning, 4-6 units would be permitted in the Victory Rug building. Against firm, united, and reasonable neighborhood objection, the developer continues to propose an excessive density which is 3 to 4 times the number of units allowed under the current zoning. No mention of the existing R-7 zoning is found in the city comment letter of July 13, 2012. OHNA would like to know why the city planning staff is not taking into consideration density permitted under the R-7 zoning, which the community has relied upon to help preserve the historic and residential character of the Oregon Hill Historic District since 2002.
Please note that our neighborhood association, as well as the immediate neighbors of the Victory Rug building, is overwhelmingly in favor of the responsible development of this parcel as permitted under the R-7 zoning. We are, and always have been, in full support of the R-7 zoning. We request an opportunity to meet with you at your earliest convenience and we will look forward to your response to the questions presented in this letter.
Thank you for your consideration.
Sincerely,
Jennifer Hancock,
OHNA, President
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