I previously published with permission the OHNA letter on Victory Rug. Here is a different letter from the volunteer executive director of the Oregon Hill Home Improvement Council:

Dear Historic Tax Credit Reviewers:

It is our understanding that an application for historic tax credits is being submitted for the Victory Rug building at 407 South Cherry Street within the Oregon Hill Historic District in Richmond, Virginia. From a review of the plans that the owner has submitted to the City of Richmond, we have concerns regarding the adverse effects that the project as submitted would have upon the characteristics of the building and the historic district.

We are particularly concerned about the parking lot that has been proposed for the lot at 811 Albemarle Street. The 800 block of Albemarle Street is an intact historic block with five structures contributing to the Oregon Hill Historic District. This block is at the entrance of the Hollywood Cemetery, also listed on the National Register and of national historical importance. In the plans submitted as a Special Use Permit to the to the City of Richmond, the owner has proposed a new parking lot wedged between two of the contributing structures at 809 and 815 Albemarle Street. According to the proposed plans, cars would be parked within inches from the contributing frame structure at 815 Albemarle Street. Parking is not a permitted primary use for this lot according to the current R7 zoning, and parking has never been a primary use of this lot. A metal fence is currently on the lot that would prevent an automobile from parking next to the frame structure at 815 Albemarle Street.

Also of great concern is the owner’s proposal to cut through the granite curb to create an inappropriate driveway from Albemarle Street between these two contributing structures. A parking lot and driveway in the middle of a block is grossly out of character for the Oregon Hill Historic District.

According to the Rehabilitation Standards and Guidelines, “Placing parking facilities directly adjacent to historic buildings where automobiles may cause damage to the buildings or to important landscape features,” is not recommended.

Also according to the Rehabilitation Standards and Guidelines, care should be given to not damage the historical setting: “Destroying the relationship between the buildings and landscape features within the setting by widening existing streets, changing landscape materials or constructing inappropriately located new streets or parking,” is not recommended.

The introduction of the proposed parking lot on the small lot between the small contributing structures at 809 and 815 Albemarle Street, the proposed parking of cars within inches of the contributing structure at 815 Albemarle Street, and the introduction of a driveway from Albemarle Street between 809 and 815 Albemarle Street would all have a profound adverse effect upon this intact historic block and the Oregon Hill Historic District.

Additionally, we have serious concerns regarding the use and treatment of the interior of the building. According to Sec. 67.7 (b) (1) of the Standards for Rehabilitation, “A property shall be used for its historic purpose or be placed in a new use that requires minimal changes in the defining characteristics of the building and its site and environment.”

The Victory Rug building is unique in the historic district in that it has been continually used without interruption for commercial purpose since it was constructed, until the point that it was purchased this year by the new owner who is now applying for the historic tax credits. Because the commercial use of the building has been continuous, commercial zoning of the building is automatically “grandfathered” in by city zoning regulations. There are over a dozen storefronts in the Oregon Hill Historic District that are now successfully being used for commercial use on the first floor, for such businesses as a restaurant, bicycle shop, grocery, barber shop, gallery, print studio, ice cream parlor, and coffee shop. We are aware that other bidders on the property had plans for commercial use of the building. The neighborhood civic association requested commercial use of the first floor of the building. Yet, the new owner has made no attempt to continue to use the building for the historic commercial use of the building.

The plans submitted by the new owner to the City of Richmond for a Special Use Permit call for the building to be subdivided into 18 small apartment units, including six apartment units on the first floor where commercial use is the defining character of the building. The maze of new walls proposed for the first floor will adversely effect the defining character of the building. The owner has even proposed new little exterior residential decks off of the south side of the first floor of the building, that are not in keeping with the building’s character. A commercial use for the first floor of the building is practical and feasible and could be successfully accomplished with a minimal change to the interior lay-out and character of the building.

Our non-profit organization, the Oregon Hill Home Improvement Council, is committed to the preservation of the Oregon Hill neighborhood. We’ve renovated over two dozen historic homes in the neighborhood, placing preservation easements on these properties in perpetuity through the Virginia Department of Historic Resources. Six of these easement properties 402 Laurel Street, 406 Laurel Street, 808 Spring Street, 810 Spring Street, 816 Spring Street, and 818 Spring Street are on the same square block as the Victory Rug building and will be impacted by the project. One of the easement properties, 406 Laurel, is directly across the alley from the proposed project at 407 Cherry Street.

We request that the Virginia Department of Historic Resources and the National Park Service carefully review the plans submitted for the historic tax credits for 407 South Cherry Street and not approve historic tax credits for any project that causes a serious adverse effect to the character of this building or upon the Oregon Hill Historic District.

Thank you for your attention to this request.

Sincerely,

Charles Todd Woodson
Executive Director
Oregon Hill Home Improvement Council