Virginia Regulatory Town Hall
Agency
Department of General Services
 
Board
Department of General Services
 
chapter
Regulations for Public Use of the Robert E. Lee Monument in Richmond, VA [1 VAC 30 ‑ 150]
Action CH 0150 Promulgation of regulations for public use of the Robert E. Lee Monument, Richmond, VA
Stage Proposed
Comment Period Ended on 3/8/2019
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3/8/19  10:05 pm
Commenter: Katherine Jordan

Regulations for Lee Monument
 

The lawn around the Lee Monument is a public, green space that should be accessible to those that wish to use it within reasonable boundaries. I live two blocks from the circle, drive Monument Avenue daily and helped plan a public, permitted event at the statue prior to the emergency regulations. I do not believe rolling emergency regulations, written in response to horrific events in a different city, into permanent status here is appropriate. We have had several protests after Charlottesville at Lee Circle and none have erupted into a scenario that warrant the continuation of the emergency regulations as written. 

Those wishing to assemble should not be unduly hindered from utilizing or gathering in this very public green space, especially when the Governor can always create another emergency regulation if such a response is needed. Plus, it is written into the regulations that the director can deny a permit if: "Upon advisement from law enforcement, the director determines that approving the permit and allowing the event to occur would pose a significant threat to public safety."

Additionally, creating such strict standards does not stop public activity realted to the statue, it only pushes it onto city property. In the case of protesters, which triggered the emergency regulations in the first place, they will simply move to the sidewalks or across to one of the medians as we have seen. Protesters will still come, and it is not fair or appropriate that the city of Richmond should have to carry the full weight of responding to activities directed at a divisive state-owned asset. As was also noted at the public meeting, forcing protestors onto the sidewalks is a dangerous scenario both for proximity to traffic and because it lessens the amount of space groups of differing opinions have to stay away from each other. 

Speaking as a neighbor who believes in free speech and the right to assemble, the area around Lee Statue should be reasonably accessible to the public, especially in a part of the city with such limited public, green space. To this end, I would like to see the following changes: 

General public use:
1) allow people to sit on the steps of the statue as was intended
2) move the cut-off time to 9 pm instead of dusk (dusk is highly subjective plus neighbors/visitors frequent the space at night).
3) increase number that triggers a permit (a school group, walking tour, running club, and those wishing to exercise their freedom of assembly should not have to file for a permit to gather in the space)

Special/Permitted events:
1) allow tables, tents, stages (all three already occur safely -and without incident- for events that will be grandfathered-in)
2) allow food and beverages
3) increase the set-up and breakdown time from 30 min to 45 minutes 
4) increase the windows for events from 2 to 4 hours (regardless of street closures)
5) delete different time window for events that close streets
6) increase number that triggers a permit and increase maximum capacity (10 – 500 is too restrictive)
7) allow pets per the regular city rules (leashed, have to clean-up after them, and they can't destroy property or be a nuisance)

Above all, create outreach to the immediate neighbors, the relevant neighborhood associations, and other groups that recently, routinely or annually utilize the space (for whatever goal) so they can help create a successful final document. Thank you



 

CommentID: 70052