[From the U.S. Government Printing Office, www.gpo.gov]





























                         PROPOSED PROGRAM FOR PREPARATION OF


                          AN ENVIRONMENTAL ELEMENT FOR THE
                           CCITY OF RICHMOND MASTER PLAN




                 The preparation of this document was financed in part'
               through funds provided by the Coastal Zone Management Act
               of 1972, as amended, administered by the Office of Ocean
                  and Coastal Resources Management, National Oceanic
                            and Atmospheric Administration
                                 No. NA89AA-D CZ-134



                                                     COASTAL ZONE

                                                  INFORMATION CENTER





                                   Prepared by the
                    Richmond Regional.Planning District Commission

                                     October, 1990













                          PROPOSED PROGRAM FOR PREPARATION OF


                            AN ENVIRONMENTAL ELEMENT FOR THE


                              CITY OF RICHMOND MASTER PLAN



                In the spring of this year, the City submitted a request for
           coastal resource management planning funds from the Virginia
           Council an the Environment. These funds were requested to aid in
           the preparation of an Environmental Plan. In July, the Council on
           the Environment notified the City that its request had been
           approved.    At the request of the City, the Richmond Regional
           Planning District Commission (RRPDC) has prepared a 'proposal
           outlining an approach that could be used in the preparation of an
           Environmental Element for the Master Plan.

                The purpose of this document is to:

                      discuss reasons for preparing an Environmental Plan at
                      this time,

                      describe the elements of an Environmental Plan, and

                      present a program for preparing an Environmental Plan.

                For purposes of this proposal, the environment encompasses the
           land, the air and the water.        The environment also includes
           potential threats to people and to the natural environment due to
           man-made and natural actions.@    Man-made actions range from the
           clearing of land to spills of toxic materials.       Natural actions
           include such features as floods and earth quakes.

           REASONS FOR PREPARING AN ENVIRONMENTAL ELEMENT FOR THE MASTER PLAN

                Section 15.1-446.1 of the Code of Virginia requires that all
           localities adopt a comprehensive plan for physical development.
           This section also states that the plan may include the designation
           of areas for 11 ... conservation, recreation, public service, flood
           plain and drainage (and) the implementation of reasonable
           groundwater protection measures...".     Furthermore, Section 15.1-
           447 states that during the preparation of the plan, localities
           "shall survey and study such matters as       ...  use of land, . . .
           natural    resources,   groundwater,    surface    water,    geologic
           factors .... drainage, f lood control and f lood damage prevention
           measures, ... and any other matters relating to the subject matter
           and general purposes of the comprehensive plan."

                The City of Richmond adopted its current Master Plan on April
           25, 1983.    This document provides direction concerning future
           development in the City. The Plan contains broad environmental

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           policies, but does not identify specific environmentally sensitive
           areas within the City. Furthermore, the environmental polices set
           forth in the Plan are not explicitly a part of the plans for each
           district.

                There is another, perhaps more important, reason for
           developing an environmental element. This reason deals with the
           benefits derived from preserving and protecting the natural
           environment. Clean air and a safe and adequate supply of potable
           water are necessary to retain and attract investment and jobs in
           the City. The retention of wetlands and other vegetation can help
           reduce flooding,, soil erosion and the flow of pollutants into the
           James River and, ultimately, the Chesapeake Bay.

                Environmental planning should not be thought of in a vacuum,
           however. The incorporation of environmental protection measures
           into the Master Plan will allow the City to blend ef forts to
           protect and enhance the natural environment with development and
           redevelopment activities.      Clear policies and standards that
           encourage the retention of green spaces as part of redevelopment
           along the James could serve to improve access to the river as well
           as filter pollutants from urban runoff. The protection of wetlands
           and other vegetation aids in the retention of habitat for wildlife
           as well as aiding water quality. All these factors contribute to
           maintaining the quality of life in Richmond.

                As discussed below the City is now or will be facing a variety
           of environmental mandates and issues. These mandates and issues
           are now or will be addressed by several different City departments.
           A comprehensive analysis of these mandates and issues will help
           insure consistency in programs and implementation activities. This
           approach will also allow the environment and City development to
           be viewed as a whole instead of as individual pieces without
           relationship to one another.

           ENVIRONMENTAL ISSUES CURRENTLY FACING THE CITY

                Apart from the general planning requirements set forth in the
           Code of Virginia, the City is subject to a variety of federal and
           state laws, regulations and standards concerning the environment.
           In addition, the City has taken or is considering action which will
           impact the environment and surrounding land uses. Following is a
           brief synopsis of some of these laws or actions.

                0     The City is now in the midst of efforts to implement the
                      Chesapeake Bay Preservation Act. The purpose of the Act
                      is to protect and improve water quality in the Chesapeake
                      Bay and its tributaries. one requirement of the Act's
                      implementing regulations is that by September, 1991, all
                      localities must review, and where necessary, amend local
                      comprehensive plans to incorporate, actions aimed at
                      protecting water quality from non-point source pollution.

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                      The regulations which implement the Preservation Act
                      suggest several studies that a locality should consider
                      undertaking during this review process. (These studies
                      are enumerated later in this document.)        While the
                      implementing regulations address storm water management
                      and erosion and sediment control, these requirements will
                      only apply to portions of the City designated Chesapeake
                      Bay Preservation Areas.

                0     In 1989, the General Assembly enacted legislation
                      establishing a cooperative state and local stormwater
                      management program. (Ref: Section 10.1-603.1, Code of
                      Virginia) This legislation allows local governments the
                      option of adopting a storm water management program
                      dealing with runoff from development sites. Regulations
                      implementing the Act are now being finalized.          The
                      federal Environmental Protection Agency will issue
                      .regulations in the near future dealing with point source
                      management of storm water. The net effect of these two
                      actions, plus the Chesapeake Bay Preservation Act, will
                      be,to increase the ability and the need for the City to
                      address the issue of managing storm water, both in a
                      qualitative and quantitative manner.

                0     The City is part of the National Flood Insurance Program.
                      This gives the City responsibility for regulating
                      development in a manner that preserves the floodplains
                      of streams and rivers.    In a similar manner, Section
                      15.1-466 of the Code of Virginia requires that "a
                      subdivision   ordinance    shall    include     reasonable
                      regulations and provisions    ... for drainage and flood
                      control. The City has plans to construct a flood wall
                      in the downtown area. Construction of the flood wall may
                      stimulate additional development or redevelopment.      At
                      the same time, other floodplain areas need to be
                      carefully monitored due to the presence of wetlands or
                      other environmentally sensitive areas. Both actions may
                      require a rethinking of appropriate land uses in these
                      designated flood prone areas. .

                0     The City is continuing to address the combined sewer
                      overflow situation. A plan has been prepared outlining
                      a phased attack on the problem.    The City may want to
                      consider how the construction of these facilities will
                      impact adjacent land uses as well as river use and
                      development.

                0     The State has recently adopted several requirements
                      dealing with solid waste management.       One of these
                      requirements is that by 1995, 25% of the City's solid
                      waste must be recycled. The City is working with other
                      localities to create the new Central Virginia Waste

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                       Management Authority to address these solid waste issues.
                       At the same time the City has recently instituted a pilot
                       program for curb-side pickup of recyclables. There may
                       be additional actions the City 'may want to consider in
                       the area of solid waste management.

                 0     The City contains one or more sites that may be placed
                       on the federal superfund list. The designation of these
                       sites may cause the City to reconsider appropriate land
                       uses on and near these areas.

                 0     Plans have been developed and partially implemented to
                       breach some dams along the James River, improving the
                       ability of f ish to travel upstream.      This will offer
                       increased recreational opportunities and 'may call for
                       additionally access points to the river. The Department
                       of Conservation and Recreation is currently assessing
                       river access throughout the tidal portion of the State.
                       The City should coordinate its efforts at improving river
                       access with this State project.

                 0     The National Ambient Air Quality Standards establish
                       maximum allowable levels of air pollution for six
                       pollutants. Currently the City is classified as a non-
                       attainment area for one of these pollutants--ozone. The
                       City may want to consider the impact              of this
                       classification in relationship to the Master Plan and to
                       future development possibilities.

            ELEMENTS OF AN ENVIRONMENTAL PLAN

                  Several approaches can be used to prepare an Environmental
            Plan.   These approaches all share certain steps in the process,
            however.

                 The first step is to establish certain broad statements, or
            goals, about the desired environment for the community, now and in
            the future. These goal statements are then used as bench-marks to
            determine what actions are necessary to maintain or improve the
            environment.

                 The second step is to analyze the existing environment and the
            opportunities and threats facing the environment. Included in this
            step is an analysis of the causes of the threats to the environment
            and the effectiveness of existing systems, ordinances and polices
            aimed at protecting the environment.         Existing and proposed
            mandates to protect the environment are examined.

                 The third step is to develop a plan of action to protect and
            conserve the environment.     This plan of action is composed of a
            series of objectives, policies and implementation strategies
            developed to address the opportunities and threats that surfaced

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           in step two. One or more maps are often prepared which identify
           critical environmental areas that need to be protected as well as
           areas when environmental conditions limit or prohibit development.

                      one more step is necessary, although it is not actually
           a part of the plan. That additional step is the monitoring of plan
           implementation. The community must continually assess efforts to
           implement the plan.    It may be necessary to modify the plan of
           action from time to time as objectives are reached or to react to
           unforseen events, such as new mandates.

           CRITERIA FOR PLAN DEVELOPMENT

                RRPDC staff met with Department of Community Development
           personnel on several occasions to discuss the City's needs relative
           to an Environmental Plan. During these meeting, several "criteria"
           for a recommended planning program became apparent.

                1.    The process must be inclusive. The proposed process must
                      provide opportunity for participation from a wide cross
                      section of the Richmond community.

                2.    The process must be designed with two deadlines in mind.
                      The aforementioned Chesapeake Bay Preservation Act
                      requires modification to local plans by September 20,
                      1991. (This date may change due to the slippage that has
                      occurred in meeting this year's deadlines.) The second
                      deadline is established by the grant from the Council on
                      the Environment. Funds from this grant cannot be used
                      prior to October 1, 1990 and a final draft document must
                      be ready for Planning Commission review by October, 1991.

                3.    The process must be capable of bringing a wide variety
                      of resources to bear.       The complexity of certain
                      environmental issues and the press of other City business
                      may hinder staff efforts to meet the above mentioned
                      deadlines. The proposal must be designed so that work
                      can be distributed among various City departments and,
                      where necessary, outside resources incorporated into the
                      process.


           PROPOSAL FOR PREPARATION OF AN ENVIRONMENTAL PLAN

                With the above in mind, the RRPDC staff has prepared the
           following proposal for the preparation of-an Environmental Plan.
           Key features of this proposal are:

                1.    A Staff Committee to bring together representatives of
                      the various City departments involved in monitoring and
                      regulating environmental matters.   This committee will
                      have primary responsibility for preparation of the
                      document.


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                2.   An Advisory Committee to aid in development of goals,
                     identification     and    analysis    of     environmental
                     opportunities and threats and to assist the Staff
                     Committee in the preparation of a plan of action. This
                     committee, composed of citizens representing various
                     backgrounds, will broaden the knowledge and experience
                     brought to the table regarding environmental issues
                     facing the City.

                3.   A work scope that examines the key environmental issues
                     and mandates facing the City, but also investigates
                     several important, though not necessarily, high profile
                     environmental issues.

                3.   A list of environmental issues for consideration by City
                     staff and the Advisory Committee in establishing the
                     areas to be investigated.

                4.   A list of resources available to assist the City in this
                     effort.


           Recommended Process And Timetable

                The following process and timetable have been developed to
           meet the October    1, 1991, deadline of the Council on the
           Environment grant.   If the Chesapeake Bay Local Assistance Board
           takes a firm stand on plan amendments being in place by September,
           1991, the City may want to revise portions  of this timetable.

           Task      Activity

            1.       Approval of Work Program and Selection of Advisory
                     Committee.   Planning Commission reviews proposed work
                     program and list of environmental issuesl modifies where
                     necessary, and approves.    Planning Commission appoints
                     Advisory Committee to work with City staff.

                     Schedule: Complete by mid-November, 1990

            2.       PreParation of Briefing Paper.      City staff prepares
                     briefing paper for Technical Committee. This briefing
                     paper should cover the purpose of this project,@'
                     responsibilities of the Advisory Committee, possible
                     resources to aid in the process and include the initial
                     list of environmental issues to be investigated.

                     Schedule: Distribute to Committee in late November, 1990

            4.       Formation of Advisory Committee.      Advisory Committee
                     holds   orientation   meeting   to   discuss   role    and
                     responsibility and review list of environmental issues
                     to be analyzed. This list may be modified based on input

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                      f rom Advisory Committee members.    Advisory and Staf f
                      Committees develop list of groups and/or individuals that
                      may be helpful in analysis of environmental issues.

                      Schedule: Early December, 1990

            5.        Development of Environmental Goals. Advisory Committee,
                      working with the Staff Committee, develops draft
                      environmental goals. These goals should be general in
                      nature and set the tone for the work to follow. One or
                      more additional meetings may be necessary.

                      Schedule: January, 1991

            6.        -Research and Analysis of Environment Issues, Needs and
                      Opportunities. Staf f Committee researches environmental
                      issues in accordance with Work Scope and prepares a
                      briefing paper covering the existing and projected status
                      of various elements of the City's environment and
                      associated federal, state and local mandates.        These
                      briefing papers will be presented to the Advisory
                      Committee at a series of meetings for review and comment.

                      Schedule: January through March, 1991

            7.        Public Review of Issues, Needs and opportunities

                      The Advisory Committee holds a public meeting to discuss
                      the conclusions reached during the environmental analysis
                      phases and to obtain public input regarding environmental
                      issues, needs and opportunities facing the City. Prior
                      to the meeting, the environmental analysis will be
                      distributed to special interest groups and the media as
                      well as be made available to the general public.

                      Schedule: March, 1991

            8.        Development of Oblectives, Policies and Implementation
                      Program. Advisory Committee reviews previously submitted
                      information and suggests appropriate city role in dealing
                      with issues.    Staff and Advisory Committees develop
                      objectives, polices and implementation actions to deal
                      with issues.

                      Schedule: April through May, 1991

            9.        Preparation of Draft Environmental Plan.       The Staf f
                      Committee prepares a draft Environmental Plan. This draft
                      will incorporate the previous briefing papers as well
                      objectives, policies and implementation program.      This
                      information will be presented to the Advisory Committee
                      for review and comment at a series of meetings.

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                     Schedule: May through August,, 1991
           10.       Public Review of Draft Environmental Plan

                     The Advisory Committee holds a public meeting to discuss
                     the draft plan and to obtain public input regarding the
                     plan. Prior to the meeting, the plan will be distributed
                     to special interest groups and the media as well as be
                     made available to the general public.

                     Schedule: August, 1991

           12.'      Preparation of Final Draft. Advisory Committee reviews
                     final draft and recommends Environmental Element to
                     Planning Commission for action.

                     Schedule:       September, 1991.

           Committee Structure

                The need to be inclusive, to act in a timely manner and to use
           a variety of resources played an important role in developing this
           proposal. The establishment of a Staff Committee and an Advisory
           Committee to actively work on Plan preparation is recommended.
           Following is a description of the suggested composition and role
           of each committee.

                Staff Committee. The bulk of the research and analysis work
           will be done by the Staff Committee.      This group, chaired by a
           representative from the Department of Community Development, should
           include representatives from the Law, Public Works, Public
           Utilities, Public Safety (Fire Bureau) and Recreation and Parks
           departments.

                overall project management and coordination should be the
           responsibility of the Department of Community Development. It is
           important, however, that each department involved in the protection
           or regulation of the issues under investigation be a full partner
           and share in the responsibility for creating this Environmental
           Element.

                The Staff Committee will be responsible for:

                a.   gathering and analyzing information related to the
                     preparation of the Environmental Element,

                b.   securing and coordinating technical input from outside
                     resources,

                C.   preparing staff reports and recommendations, and

                d.   communicating information on this project to interest
                     groups, the media and the general public.

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                Advisory Committee.    This committee will assist the Staff
           committee in preparing the Environmental Element for Planning
           Commission review and action. The purpose of this committee is to
           provide additional technical expertise and policy guidance.
           Therefore, this group is envisioned as a working group rather than
           ï¿½ review committee. The Advisory Committee will bring to the table
           ï¿½ wide variety of interests and specialized backgrounds necessary
           for a comprehensive review of the environment. Advisory Committee
           members will also act as liaisons, keeping various sectors of the
           community informed on progress in developing the Plan.

                The Advisory Committee will be responsible for:

                a.   defining issues to be investigated   during this process
                     and preparing a set of draft environmental goals.

                b.   evaluating technical reports prepared by the Staff
                     Committee and other experts,

                C.   evaluating Staff recommendations regarding the issues,
                     needs and opportunities facing the City,

                d.   developing a consensus on recommended objectives and
                     policies regarding the City's environment,

                e.   assisting in the development of a draft Environmental
                     Element for review by the Planning Commission, and

                f.   meeting with the Planning Commission to assist in the
                     presentation and explanation of the draft.

                Three possible approaches to the preparation of the Plan were
           considered.   Following is a discussion of each approach and the
           pros and cons associated with each.

                1.   One approach is for all work to be done by City staff,
                     with or without assistance from outside resources. This
                     technique may be the fastest, but involves the least
                     amount of direct input from those effected or
                     knowledgeable in the various areas to be investigated.
                     This technique also places a tremendous burden on the
                     staff as far as evaluating its own proposals.         This
                     approach was rejected as too limited in participation by
                     the public in the preparation of the Plan.

                2.   Another technique is the formation of a large Task Force
                     with multiple subcommittees to investigate each issue.
                     While this technique.allows the broadest representation
                     and level of expertise, it also can be cumbersome.
                     Finding a place for 50-150 individuals to meet is not
                     easy, nor is maintaining a quorum for action of various

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                     proposals. Groups of this size may inhibit the face to
                     face communications needed to discuss controversial
                     issues such as the environment.        The subcommittees
                     normally used in a process such as this also place large
                     demands on staff time. The time limitation factor and
                     logistical factors resulted in this- process being
                     rejected.

                3.   A third technique is to appoint a small advisory
                     committee of 15 to 25 individuals to evaluate staff work.
                     This committee should include representatives f rom the
                     various sectors of the community that will be impacted
                     by the Plan.      This committee should also include
                     individuals who can act as technical resources to the
                     staff and other committee members when discussing
                     environmental and development issues.     The relatively
                     small size of such a committee also facilitates
                     discussion and consensus building. Being a small group,
                     this technique permits fairly rapid review and action.
                     The most difficult issue faced in using this technique
                     is the selection of members that adequately represents
                     the broad viewpoints found in a City like Richmond. Even
                     with this potential limitation, the RRPDC staff
                     recommends the City appoint this type of committee to
                     assist with the Plan.

                The  RRPDC recommends that the City consider appointing
           individuals with the following interests or positions. The exact
           size and membership of the committee should be left to the Planning
           commission, with advise from Staff and the City Manager.

                1.   Planning Commission.    To provide insight into current
                     planning and environmental issues facing the City as well
                     as keep the Commission abreast of progress on the Plan.

                2.   Local Environmental Interest.    To provide insight into
                     the environmental concerns of the City's residents and
                     to act as liaison to the numerous environmental groups
                     in the City.

                3.   Real Estate and Development Interest. Discussions on the
                     environment eventually impact land and its development.
                     Issues such as compliance with the Chesapeake Bay
                     Preservation Act will attract the interest of the
                     development community.

                4.   Industrial Interest.      Issues under discussion will
                     include the improvement of water quality, air and noise
                     pollution and the handling of solid waste and hazardous
                     materials. These interest will be able to contribute to
                     these discussions.



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                 5.   Transportation Interests.        Transportation involves
                      numerous modes which carry or    use hazardous materials,
                      create noises and own land throughout the City, some of
                      which is along streams.

                 6.   Local Environmental Experts. The City is fortunate to
                      be the residence of several individuals with extensive
                      experience in dealing with the environment.            This
                      resource should be tapped.

                 7.   Representatives of Professional Organizations. There are
                      several professions, such as engineering, architecture,
                      landscape architecture, geologists, soil scientists and
                      the like, which can add to the deliberations of this
                      committee.


           Work Scope

                 The proposed work scope is found at the end of this document.

           Issues

                 There are numerous issues that could be investigated in
           preparation of this Environmental Element.         The following is
           offered as a starting point for determining issues to be
           investigated in this ef fort. A quick review of this list will also
           point out that many issues are inter-related.          For instance,
           wetlands provide habitat for wildlife, filter pollutants from
           surface water and can help in flood control. The process should
           investigate these inter-relations.       The    process should also
           examine both the local and regional implications related to these
           issues.

            1.   Chesapeake Bay Preservation Act.          The Chesapeake Bay
                 Preservation Act addresses several issues including storm
                 water management, the protection of environmentally sensitive
                 areas and public access to streams. The latest information
                 available from the Local Assistance Department indicates that
                 the following information should be considered while
                 evaluating the Master Plan as required by the Act.          This
                 guidance is subject to change and/or clarification, therefore,
                 close contact should be maintained with the Local Assistance
                 Department liaison during the planning process.

                 A.   Chesapeake Bay Preservation Areas:

                      1.   Purpose and benefit,
                      2.   Information used for designation, and
                      3.   Description and map.

                 B.   shoreline erosion problems and location of erosion











                     structures.
                C.   Conflict between existing and proposed land uses and
                     water quality protection.

                D.   Local policy on land use issues relative to water quality
                     protection.

                E.   Discussion of each CBPA component in relation to the
                     types of land uses considered appropriate and consistent
                     with the goals and objectives of the Act, regulations and
                     local program.

                F.   Policy statements on:

                     1.    Physical constraints to development, including soil
                           limitation, with explicit discussion of soil
                           suitability for septic tank use.

                     2.    Protection of potable water supply, including
                           groundwater resources.

                     3.    Relationship of land use to commercial and
                           recreational fisheries.

                     4.    Appropriate density for docks and piers.

                     5.    Pub lic and private access to water-front areas and
                           effect on water quality.

                     6.    Existing pollution sources.

                     7.    Potential water quality improvements through the
                           redevelopment of intensely developed areas.

                     For  each of the policy issues listed above, the plan
                     should contain a discussion of the scope and importance
                     of the issue, alternative policies considered, the policy
                     adopted by the local government for that issue and a
                     description of how the local policy will be implemented.

                     With the policy discussion, local governments should
                     address consistency between the plan and all adopted land
                     use, public service, land use value taxation ordinances
                     and policies, and capital improvement plans and budgets.

            2.  Combined Sever overflow Situation. The City has a program for
                addressing the issue of periodic overflow of the combined
                sewer into the James. The alleviation of this problem will
                make a positive contribution to water quality in the James.
                This project will also require large scale construction along
                the river.    The Environmental Element should address the
                impacts of this project of the river, those areas where

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                construction will take place and on adjoining lands.         The
                contribution of this project toward meeting the storm water
                management requirements of the Chesapeake Bay Preservation Act
                should also be investigated.

            3.  Storm Water Management.     This issue will be investigated as
                part of items 1 and 2.     However, there are portions of the
                City that are not covered by the Preservation Act and/or not
                served by a combined sewer. Therefore, this project should
                investigate the effectiveness of existing policies and
                ordinances in dealing with storm water, both from a
                qualitative and quantitative prospective.      The impacts of
                proposed federal and state regulations dealing with storm
                water should also be included in this investigation.

            6.  Protection of Ground Water. In addition to work done under
                the Preservation Act, the Plan should examine existing ground
                water resources, areas of the City which are dependent on
                ground water and any threats to ground water.          Potential
                threats include underground storage tanks, past and present
                users of hazardous materials, pesticides, herbicides and land
                fills.


            7.  Protection of Surface Water. In addition to the Preservation
                Act activities, the Plan should examine existing and potential
                threats to surface water quality from surface runoff and point
                sources. (This investigation would include the threats listed
                above under ground water.) An analysis should also be made
                of any threats to the use of the James River as the City water
                supply due to either, low flows or pollution.     The need for
                water conservation should also be examined.

            8.  Protection of Environmentally Sensitive Areas. The protection
                of areas that are considered environmentally sensitive to
                development or misuse should be examined.       Areas commonly
                classified as such are:

                1.    Flood plains and flood prone areas
                2.    Wetlands, both tidal and non-tidal
                3.    Steep slopes (those in excess of 20%)
                4.    Highly permeable and highly erodible soils

                Threats to these lands come in two forms. First   is the threat
                from actual development or use of the lands or adjacent
                property. Development on or adjacent to these environmentally
                sensitive lands can reduce or eliminate the beneficial effects
                of flood plains and wetlands. A second threat to these lands
                is the result of development, that is, storm water runoff from
                parking lots, foot or automobile traffic and so forth.

                This analysis should examine threats to these areas due to
                erosion, pesticides, herbicides, fertilizers,       ground and

                                            13









                  surface water pollution, and improper land development.
                  Fortunately, many of these environmentally sensitive areas
                  have been located, at least in a preliminary manner, as part
                  of the City's effort to implement the Preservation Act.

              4.  Utilization of the James River Waterfront. The James River
                  is a valuable resource to the City. It offers a variety of
                  passive and active recreational opportunities as well as a
                  variety of views and vistas . The river is home to the full
                  range of development within the City; residential, commercial
                  and industrial uses line the river as do parks and other open
                  spaces. There is also vacant land along the river that the
                  City would like to see develop.

                  The river is also the major environmental element of the City.
                  It provides drinking water, accepts the runoff from yards and
                  parking lots and receives the waste water from the sewage
                  treatment plant.       For all of the above reasons, the
                  Environmental Element must consider the impacts on the James
                  and its tributaries in a variety of ways.

             10.  Geology.    The Geology that underlies the City should be
                  examined.   This work should highlight potential threats to
                  existing and future development due to geological features
                  such as fault lines.        The presence of radon should be
                  examined.

             11.  Mineral Extraction.      The City should examine existing and
                  potential mining operations. If possible, the projected life
                  span and future uses of existing mines should be investigated.
                  The City may want to consult Sand and Gravel Resources: Local
                  options for Protection and Regulation, prepared by the RRPDC,
                  regarding this issue.

              5.  Solid Waste Management. This analysis should encompass the
                  existing waste management system and projected needs in the
                  future.    Waste materials that should be examined include
                  household    and   commercial     garbage,    industrial      waste,
                  construction materials, infectious and other medical waste,
                  sludge and septage, hazardous household waste as well as the
                  disposal of motor vehicles, oil, tires and batteries.            The
                  problem of litter should also be examined. This examination
                  should look at waste reduction and recycling as well as
                  disposal.    (Note:   The soon to be formed Central Virginia
                  Waste Management Authority should be helpful with this
                  effort.)

              9.  Hazardous Materials Handling.      This analysis should examine
                  the existing and past location of hazardous materials within
                  the City and what efforts are underway to protect the
                  environment from these materials.        This examination should
                  also look at the City's plans and policies regarding accidents

                                                14









                involving hazardous materials, including those in transport.
                .As operator of the Port of Richmond, the City may want to
                examine the handling of any hazardous materials that flow
                through the port.

           12.  Air Quality. The Plan should assess existing air quality and
                identify any existing or potential threats to air quality.
                This examination should investigate appropriate actions needed
                to mitigate these threats and maintain or improve air quality.

           13.  Noise Pollution.    This analysis should site the source and
                location of any noise generators that may threaten or limit
                development and methods of mitigating these threats.

           14.  Views and vistas. Important views and vistas as they relate
                to other environmental features should be located and
                considered. Existing and potential threats to these views and
                vistas should be cited.

           15.  Habitat Protection.    This analysis should locate Important
                habitat areas and existing and potential threats to these
                areas. A starting point for this investigation could be the
                Department   of    Conservation   and   Recreation.        Local
                organizations should also be of assistance.

           16.  Rare and Endangered Species. This analysis should investigate
                the presence of any rare or endangered species and potential
                threats to these species.

           Resources

                There are a variety of individuals that are available and
           willing to assist with this project. The RRPDC is compiling a list
           of resources, by subject matter, for use by the City.

                The RRPDC has already set aside technical assistance time to
           aid the City with this project. At the same time this project is
           underway, the RRPDC will be conducting an environmental analysis
           of the region. Any information gathered will be made available to
           the City.













                                            15











                                                                   Attachment 1


                                     CITY OF RICHMOND


                                  ENVIRONMENTAL ELEMENT


                                        WORK SCOPE


                      Environmental Issues and Goals Identification


                      A.   Define environmental issues to be addressed
                      B.   Identify environmental goals for City

                      Environmental Assessment

                      A.   Identify and assess the following environmental
                           features.. This assessment should include a thorough
                           analysis of the factors that may positively or
                           negatively impact each feature., Such factors may
                           include land uses, the environment or other factors.

                           1.   Surface water, including both quality and
                                sufficiency to meet the City's existing and
                                projected needs. Locate existing and proposed
                                water intake and outfall points.        Identify
                                existing and potential point and nonpoint
                                sources of pollution to surface water.

                           2.   Ground water, including both quality and
                                quantity.     Identify portions of the City
                                dependent on ground water for drinking water
                                and areas served by septic tanks.       Identify
                                potential point and nonpoint sources of
                                pollution to ground water and soil.

                           3.   Environmentally sensitive areas including:

                                a.    Flood plains and flood prone areas
                                b.    Wetlands, tidal and nontidal
                                C.    Highly permeable and highly erodible soils
                                d.    soils  classified    as  unsuitable     for
                                      building
                                e.    Slopes in excess of 20%
                                f.    Geologically sensitive areas
                                g.    Shorelines, noting areas of erosion and
                                      areas with erosion control, areas of
                                      public and private access and water
                                      dependent uses.

                           4.   Air quality, including fixed and nonpoint
                                sources of air pollution as well as radon.










    A,
                           5.   Noise generators, including noise associated
                                with aircraft and transportation corridors as
                                well as fixed sources.

                           6.   Minerals and other minable materials, including
                                the quantity and economic feasibility of mining
                                these materials.

                           7.   Important wildlife habitat

                           8.   Rare and endangered species locations.

                           9.   Important views and vistas related to other
                                issues address in the Environmental Element

                      B.   Assess the potential impacts of the following on
                           existing and potential land uses and other elements
                           within the City's environment.

                           1.   The plan for addressing the combined sewer
                                overflow situation.

                           2.   Storm water management program and facilities,
                                including the effectiveness of such programs
                                and facilities in managing the quality and the
                                quantity of storm water runoff on individual
                                properties and within drainage basins.

                           3.   Solid waste management program and facilities,
                                including the handling of various types of
                                waste such as household, industrial, hazardous
                                including household, infectious waste, and the
                                disposal of automobiles, tires, batteries and
                                waste oils and lubricants.

                           4.   Hazardous materials transportation and storage
                                requirements and spill clean-up programs.

                           5.   Proposed flood wall project.

                      C.   Identify existing conditions and/or projected trends
                           that could threaten or enhance items identified in
                           Sections A and B.

                      D.   Identify existing and projected development trends,
                           either local or regional, that could threaten or
                           enhance the environment of the City.






                                             17









                     Regulatory Assessment

                     A.    Identify existing and proposed state and f ederal
                           regulations and mandates related to the protection
                           or management of items identified in Section II.

                     B.    Determine actions needed by the City to address the
                           issues identified in A above.

                     C.    Assess the strengths and weaknesses of existing city
                           regulations, programs, staff and facilities to
                           adequately., address the environmental concerns
                           discussed in Section II.

              IV.    Land  Use Compatibility Assessment

                     A.    Prepare a composite map indicating environmental
                           features or concerns determined in Section II.

                     B     Identify potential environmental impacts associated
                           with particular land use types and development
                           patterns as well as environmental limitations to
                           development.

                     C.    compare existing and future land uses with the
                           composite map prepare in A above.

                     D.    Determine existing and potential conflicts and
                           compatibilities between environment features in the
                           City and existing and potential land uses in and
                           adjacent to the City.

                     E.    Prepare a map that highlights existing and potential
                           conflicts and compatibilities between environmental
                           features and land uses.   This map should indicate
                           city owned land for reference.

                V.   Development Objectives and Policies

                     A.    Develop environmental objectives based on City goals
                           and land use compatibility assessment.

                     B.    Prepare overall development concept for the City.
                           This concept should define and delineate areas
                           suitable for development by generalized land use
                           category as well      as areas    appropriate     for
                           conservation, that is, where development should be
                           discouraged due to environmental considerations or
                           development limitations. Prepare one or more maps
                           to illustrate this development concept.         This
                           development concept should also address the
                           following issues:

                                            is









                           1.   Locations of Chesapeake Bay Preservation Areas
                           2.   Appropriate development patterns for the James
                                River shoreline.
                           3.   Public and private access to rivers and
                                streams.
                           4.   Appropriate locations for water dependent uses,
                                including commercial and recreational fishing.

                      C.   Prepare policies for guiding development and other
                           decisions regarding environmental features and
                           programs within the city.

                      D.   Prepare a development suitability matrix - for
                           specific land use types and intensities with regard
                           to various environmental features.

              VII.    Implementation Program

                      A.   Identify specific actions for implementing the plan
                           with associated manpower and/or cost estimates
                           including:

                           1.   Actions to guide or regulate development, and
                           2.   Actions to prevent or mitigate environmental
                                impacts through specific projects or other
                                intervention.

                      B.   Develop a recommended implementation program that
                           places the actions identified in A within some
                           priority or phasing framework.






















                                             19












                             RICHMOND TECHNICAL ASSISTANCE
                             RESOURCE AND INFORMATION LIST




          Council on the Environment:

          John Marling    786-4500

          John will be able to help identify individuals who could provide
          information who might otherwise be difficult to identify or
          contact.    Additionally, he may be able to coax and prod those
          agencies which might not otherwise be willing to cooperate with the
          data collection and planning efforts.


          Virginia Water control Board:

          Curt Linderman 367-6435

          The Water Control Board will be able to provide information
          regarding VPDES permits and VPA permits issued within the region.
          The Water Control Board will also provide copies of the water
          Quality Management Plans for the James River which are required by
          the Clean Water Act.

          In addition to data being supplied regarding water quality, the
          board will also provide information concerning stream flow,
          groundwater quality and its relationship to surface water quality,
          dredge and fill operations and water intake points. Lastly, Mr.
          Linderman suggested we examine sections 205-J, 208, 303-E and 1251
          of the Clean Water Act. Apparently these sections detail the type
          of data and analysis which raust be included in water. quality
          management plans. These sections should be reviewed for reference
          purposes only, but they may prove to be a valuable source for
          policy development.


          Virginia Department of Health:

          Morris Brown    662-9552

          After speaking with Mr. Brown, it was revealed that his area of
          expertise was limited to water supply and waste water treatment.
          He indicated that this is the area in which his division could be
          of most help in providing informational assistance. Mr. Brown said
          he did not think he would be able to provide information regarding
          threats to the public health resulting from full body contact
          recreation within the James River (This could be associated with
          the public access issue) . He also expressed an interest in serving
          on an advisory committee during the planning process.










           Air Pollution Control Board:

           Region Five State Capitol Region
           Bob Beasly      371-3067

           Mr. Beasly is the Region Five director. His of f ice will probably
           be able to provide technical data concerning air quality within the
           region.   Mr. Beasly provided information regarding three major
           issues confronted by this region.

           1 .  All new major permit applications require the APCB to make
                pollution emission estimates for the applicant's particular
                ty-pe of industry. These projections are made using pollution
                models based on the maximum amount of emissions that could
                ever be expected from the industry. As such, the projections
                regularly indicate that pollution levels will exceed the
                limits established for the region. Additionally, many of the
                pollutants are caused by the industry burning high sulfur
                content oil and coal.      There are currently no regulations
                controlling the amount of sulfur which can be present in the
                fuel.

           2.   Richmond City, Henrico and Chesterfield Counties are all non-
                attainment areas for ozone (organic) pollutants.       In short,
                organic pollutants can not exceed the amounts currently
                present.     Industries can, however, purchase from other
                industries, emission allowances which will allow them to
                increase the amount of  pollutants being released. The credits
                offset the increased    amounts.   The concept is the same as
                transfer development    rights.    Apparently it has not been
                tested in the courts.

           3.   The APCB anticipates changes in the regulation of automobile
                emissions. These emissions appear to be one of the leading
                contributors to the air pollution problems being experienced
                by the region.

           Bureau of Planning and Resource Management
           Nancy Saylor    786-1249

           Ms. Saylor indicated that there is no state agency with authority
           to address the noise pollution issue.      She did, however, confirm
           that her department does receive numerous public inquiries
           regarding this topic. Because of state budget restrictions, she
           questioned the amount of assistance the APCB can provide to this
           project.

           Ms. Saylor insinuated that the issue of air pollution may be one
           of the most difficult issues to address. The     reason this is so is
           that all forms of air pollution can not be evaluated, and
           subsequently regulated, in the same manner.      There are currently
           a variety of regulating methods in place on      both the state and
           f ederal levels. Researching and analyzing all   of these regulations
           could easily overshadow the other aspects of the plan. In short,








           difficulties in addressing this issue in a meaningful manner should
           be expected in the scope of this particular project.
           Lastly, Ms. Saylor provided the names of two individuals within the
           department which she feels can provide further assistance. They
           are:


           Kirit Chaudhari
           Computer Services
           786-0174


           Bill Parks
           Director, Division of Monitoring
           786-3356

           Department of Mines, Minerals and Energy:

           Rick Berquist 804-221-2448

           Mr. Berquist suggested the primary sources for the geologic data
           should be the already published USGS Map 1-2033 geologic map of the
           Coastal Plain Region and the soon to be published Department of
           Mines, Minerals and Energy geologic @map of the Piedmont Region.
           The Piedmont Region map will contain several layers.     One layer
           will delineate economic mineral resources throughout the region.
           Both the Coastal Plain and Piedmont maps will also delineate
           groundwater recharge zones. Mr. Berquist mentioned that many of
           these zones currently run a significant risk of serious
           contamination because of incompatible activities occurring in and
           around them.

           Furthermore, there is a problem of radon within the Coastal Plain,
           however, there is not proper documentation to sufficiently address
           this issue in a responsible manner. The problem of rad.o.n has not
           been extensively studied in the Piedmont Region so Mr. Berquist
           suggested that those individuals who may be concerned about it
           begin testing their homes and documenting any problems identified.
           The Virginia Department of Health is the lead agency for the state
           dealing with radon.

           Lastly, the subsidence and sinkhole issue is present within the
           region. Subsidence problems are usually located in Chesterfield
           County in the vicinity of Midlothian Village and other areas where
           extensive coal mining has occurred. Areas susceptible to sinkholes
           have not been clearly identified nor have they presented any major
           threats within the region. The problem is, however, present to one
           degree or another.








          Virginia marine Resources Commission:

          Tony Watkinson       804-247-2255

          VMRC has control over tidal wetlands and state owned submerged
          lands. VMRC can help to identify some likely tidal wetland areas,
          however, because these areas are defined by state code, they must
          be classified on a case by case basis. VMRC must issue permits for
          land disturbing activities in tidal wetlands and activities which
          will encroach upon state waterways (this includes both tidal and
          non-tidal waters) . Additionally, VMRC has published informational
          guidelines concerning the above activities and Mr. Watkinson will
          send the RRPDC copies of these publications.

          Lastly, VMRC is not in a position to define areas for public access
          and so forth, but is rather better able to react to any specific

          Virginia Department of Conservation and Recreation:

          Division of Plannincr and Recreation Resources
          John R. Davy
          203 Governor St.
          Richmond, VA 23219
          786-1119

          Mr. Davy's office will soon be distributing base line maps which
          will delineate existing and potential public access points for many
          of the localities within the region. The City of Richmond is one
          of the jurisdictions for which this information has been collected
          and mapped. These maps will also delineate natural and cultural
          heritage sites located within 1/4 mile of the James River.
          Planning and Recreation is also about to publish a technical
          assistance report which   will offer guidelines for siting public
          access facilities.

          To obtain assistance from the department, it would be best to send
          Mr. Davy a letter of request which will briefly explain the project
          and outline the issues to be addressed by the department.       Upon
          receipt of the letter, Mr. Davy will distribute the request among
          all the divisions within the Department of Conservation and
          Recreation so that all divisions will have the opportunity to
          respond to the request in a coordinated effort.


          Division of Natural Heritage
          Katie Perry
          786-7951

          Ms. Perry's office is the repository for information about
          threatened and endangered species, unique natural communities and
          unique geologic formations. Ms. Perry said that information may
          be limited to park lands due to the intense development in the
          City, but is very willing to assist in this project.      It may be
          appropriate to check with her before contacting Game and Inland









           Fisheries or the Bureau of Plant Protection and Control because of
           the overlap of information on threatened and endangered species
           and habitat.


           Virginia Department of Game and Inland Fisheries:

           Division of Planning and'Environmental Services
           Bill Neal      367-8998
           Becky Wajea- (pronounced Vida)     367-8351
           4010 West Broad Street
           Richmond, VA 23230

           This office maintains the Fish and Wildlife Information System.
           This system identifies habitat characteristics and lists all
           species which are normally associated with the particular
           characteristic.    The office also maintains locational maps
           pinpointing known nesting and breeding sites for endangered
           species. Lastly, the fish division will also be able to provide
           information concerning the location of fish habitats. Again, it
          .would be best if a formal informational request to the Department
           was made through Ms. Wajea.
           proposals.

           Department of Agriculture and Consumer Services

           Bureau of Plant Protection and Control
           Marshall Trammell   786-3516

           Mr. Trammell indicated there are no threatened or endangered plant
           species within the Richmond region. His department could, however,
           provide general guidelines which will help to identify the factors
           and activities within this region that have the potential to harm
           threatened or endangered species found in locations downstream.





                                  hmond Regional Plannincr District Commission
                                                          2104 I'Vest Laburnurn Avenue, Suite 101
                                                                 Richmond, \7irginia 2' )227
                                             (804) 358-3684 - SCATS (804) 367-1546 * FAX (804) 358-5386

          To  of
            h1and

         Counties of
            Charles City                                                   August 9, 1990
            Chestrrfieid.
            Coochland
            Hanover
            Henrico
            New Kent  Mr. Keith Bull
            Powhalay? Executive Director
         Citv of
            R.ichmond Chesapeake Bay Local Assistance Department
                      805 East Broad Street, Suite 701
                      Richmond, VA 23219

                      Dear Mr. Bull:

                          'ne RRPDC staff has reviewed the latest Local Assistance Department quarterly
                      reportand   finds several misleading and inaccurate statements in the report.

                          1.      On Page 20, the quarterly report states that each Tidewater planning
                                  district conunission "will receive S40,000 (in coastal zone management
                                  funds) as part of the state's ongoing commitment to staff an environmental
                                  planner in" each planning district. We are unaware of any ongoing State
                                  commitment to fund an environmental planner. These funds are allocated
                                  for coastal planning activities, not specifically to fund staff members.
                                  Richmond Regional PDC is using these funds for a host of coastal
                                  activities, including local technical assistance, environmental reviews and
                                  regional environmental planning, all part of our multi-vear coastal planning
                                  program.

                          2.      The latest written guidance from the COE states that NOAA has
                                  determined that FY 1991 coastal funds cannot be used to implement the
                                  Preservation Act. This makes anv discussion of FY 1991 coastal zone
                                  manac,ement funds as a tool to implement the Preservation Act inap-
                                  propriate. While there are efforts underway to integrate the Preservation
                                  Act into the Virginia Coastal Program, as discussed on page 19, we do not
                                  see how these efforts will affect the use of FY 1991 coastal funds.

                          3.      We are puzzled over the display of funding information in the Appendix.
                                  First, all tasks for which funds were requested from the Department are
                                  not shown; onlv tasks the Department decided to fund, in whole or in part,
                                  are shown. A quick survev of the Richmond region shows that over one
                                  half million dollars in additional funds were requested from the Depart-
                             Ric




            As

















































                                  ment in this region alone. The ty
                                                                    pical reader would not be aware of this
                                  discrepanc@,.









                     Mr. Keith Bull
                     Page 2
                     August 9, 1990




                                Second, the Department included coastal zone management funds with
                                Preservation Act funds in the Appendix. As stated before, coastal funds
                                cannot be used to implement the Preservation Act. In addition, the
                                Department included coastal funds received without including the amount
                                requested. nc result of these actions is to greatly understate the true
                                funding needs of each locality while overstating the funds available.
                                The information presented for Chesterfield County illustrates how
                                misleading the report is. The typical reader would assume that the County
                                requested $28,750 in assistance and received $40,500, over 40 percent more
                                than requested. In actuality, the county requested approximately $228,000
                                from the Department and $40,000 from the coastal program. Total funding
                                from both sources is $40,500, 17 percent of the total requested. We are
                                concerned that misinformation such as this will be used by some to assert
                                that the State is meeting the financial needs of local governments.

                         Based on the above comments, the RRPDC would like to request an amendment
                     to the quarterly report be prepared and distributed to each individual or organization
                     which receive the report. This amendment should address the following:

                         L      A new appendix should be prepared which correctly indicates all funds
                                requested from the Local Assistance Department ani deletes references to
                                coastal zone management funds.

                         2.     A clarification should be issued regarding the federal determination that
                                FY 1991 coastal zone management funds are not to be used to implement
                                the Preserv2tion Act. If coastal funds are discussed, then reference should
                                be made to all funds requested as well as funds received.

                         3.     The comment regarding the State's commitment to using coastal funds to
                                                t@     t:p                               M
                                place an environmental planner in each PDC should be checked and if
                                found to be invalid, it should be retracted.

                         The Commission's Chesapeake Bay Regional Advisory Committee has reviewed
                     the above recommendations. The committee believes that action should be taken now
                     to correct the misinformation presented in the quarterly report. In addition, the
                     Committee desires to meet with You to discuss other issues related to Your new
                     position and the Department. Larry McCarty, on my staff, will be conta'cuna You
                     shortly regarding such a meetinle.








                     Mr. Keith Bull
                     Page 3
                     August 9, 1990




                         We look forward to working with you in the future. Please feel free to call on
                     this agency if you need any assistance.


                                                                   er



                                                                  hn P. Kidd, AICP
                                                                  ecutive Director

                     JPK/rf

                     PC:       Chesapeake Bay Local Assistance Board
                               Chesapeake Bay Regional Advisory Committee
                               Mr. Rudolph V. Jones, Chairman
                                Richmond Regional Planning District Commission
                               Mr. Larry McCarty, Director of Planning
                                Richmond Regional Planning District Commission
                                                           Y
                                                                   er




                                                                     P.
                                                                  hn
                                                                  ecutivi



                                                                                                           JOAA COASTAL SERVICES CTR LIBRARY
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