gain an exception to the required link-node ratio with additional external connections, it seems to us that this process is not at all necessary as the focus should lay on external connections in the first place. Internal subdivision street layout should be based on consumer demand, not the regulatory whim of government, especially when the proposed designs could lead to more asphalt and additional maintenance costs.

With regard to stormwater management, the development industry is already subject to onerous regulation with regard to runoff. As such, it makes no sense whatsoever to foist a larger burden on their backs by enacting additional pedestrian access requirements that make no offsetting allowance for narrower streets to help reduce the impervious cover in a neighborhood. In and of themselves, sidewalks and other pedestrian access features are great, and they are part of what the General Assembly has directed the Commonwealth Transportation Board to consider. The problem is that sidewalk widths of five to eight feet are excessive; these widths create unnecessary expense and generate additional impervious cover. When combined with fact that there is no street width reduction that takes the sidewalk mandate into consideration and the additional pavement needed to comply with the prescribed link-node ratio, the result is additional runoff and added compliance costs for developers.

As written, these proposed regulations would yield a reduction in the number of buildable lots because more land would have to be used for either streets or sidewalks for the neighborhood to be in compliance for street acceptance.

To us, that is troublesome in three ways. First, a reduction in lots affects a project’s profitability, something that is quite disconcerting when it is for no other reason than to comply with a governmental diktat. This is crucial given the important role that housing-related economic activity plays in Virginia, especially in the current housing market where increased costs would further destabilize and crush an already depressed market.

Second, fewer lots means higher home prices for each home in the neighborhood at a time when we need a wider range of affordable housing choices near job centers, not lesser. In addition to being a quality of life issue, this is important from an economic development perspective. Employers want to know that their employees will be able to live near work.

Finally, policies that lead to lower lot yields do nothing to affect housing demand. Thus, more land must be developed in order to meet the demand for housing, leading to less efficient land use patterns, a phenomenon known to some by the pejorative term of “sprawl.” While the Chamber vigorously supports the notion that Virginians should be able to live where they choose, we do not believe it is sound policy to push development further from job centers simply to comply with government regulations.

In summary, we urge you to reject the proposed regulations and send them back to the drawing board with a clear mandate to focus the connectivity requirements on external connectivity to roads of minor arterial or greater status and to reexamine the proposal with regard to street widths and pedestrian access to address concerns about stormwater runoff management.

Again, thank you for the opportunity to comment on this proposal

With kind regards, I am

Sincerely,

Director of Government Affairs

Virginia Chamber of Commerce