Comments at Arlington County Board Meeting, February 21, 2023.
Here are excerpts from Suzanne Sundburg’s review of the Chesapeake Bay Preservation Plan:
“Moreover, a recent FOIA response clarified that under current lot coverage rules, single-family home development for 6,000–8,000 sq ft lots covered LESS than what is currently allowed. Almost certainly, an 6 to 8-fold increase in allowable, by-right density incentivizes tear-downs, and the added density will almost certainly result in use of the full lot coverage allowance.
“Where is the planning for the so-called “missing middle” upzoning reflected in this “update” to the plan? Though CPHD staff claims that imperviousness would not increase more than current single-family home redevelopment, this type of development has already produced excessive runoff that carries more contaminants into our streams, the Potomac and the Bay. Staff has chosen not to further restrict lot coverage, which would serve to reduce imperviousness.
“Thus, we will see even more runoff volume along with more heat-trapping, water-shedding surfaces. More runoff volume means more contaminants entering our streams at increasing speed, which compromises “resilience” and flood-mitigation efforts. Why is there no planning in this document to prepare for what will be the GREATEST land-use planning change since Arlington implemented its Zoning Ordinance in the 1950s? Where are the proactive measures to offset this increase in environmental insult?
“Where are the mitigation planning and increased regulatory controls and land-use policy changes needed to reverse the trend of increasing imperviousness and runoff volume? I cannot find anything substantive in this plan, which seems odd, given that it is purportedly a planning tool for improving water quality and the Bay’s health.
“Existing state code allows Arlington the latitude to enact more stringent land-use and stormwater management regulations to reduce stormwater runoff volumes.[i] The question is why nothing new or more stringent is proposed in this document or in any other related document?
“Likewise, the county has repeatedly denied that increasing the number of allowable housing units in Arlington “single-family” neighborhoods will have a negative impact on Arlington’s tree canopy. These specious denials and absurd alternative proposals would be comical, except for the deadly serious consequences resulting from this massive deforestation effort.
“The bottom line: The hot, barren, treeless urban hellscape that the County has engineered will negatively impact the health of Arlington’s streams, the Potomac River, and, ultimately, the Chesapeake Bay. And it won’t be great for human health either.”
[i] “As evidence of the robust runoff regulation powers already given to localities, see the DEQ Guidance Memo Division of Water Permitting, dated Feb. 6, 2021:
with a BMP in Appendix VII, Table VI.1 for rainwater harvesting.
“See also Virginia State Code § 62.1-44.15:33. Authorization for more stringent ordinances:
and the Virginia Flood Damages Reduction Act (§ 10.1-600 et seq.) as amended in 1989. which indicates that localities are free to set more stringent standards for floodplain zoning and enforcement than the state’s minimum requirements.”