There is a table in the Norfolk Zoning Ordinance called Table 3.6.11. It is not a famous table. It has never been in the news. Most of the people who live inside the district it governs have never heard of it. But if you have ever stood on a Ghent sidewalk at 9pm wondering where everyone is, this table is a large part of the reason.
Table 3.6.11 is the principal use table for Norfolk's Historic and Cultural Conservation districts. It lists every category of land use — residential, commercial, institutional, industrial — and marks each one with a symbol for each HC sub-district. P means the use is permitted by right. C means you can apply for a Conditional Use Permit and maybe get approved. A blank cell means the use is prohibited. Full stop.
In the HC-G2 column — the Ghent district, the one that covers Colonial Avenue and the surrounding residential blocks — most commercial uses are blank. Not C. Not subject to conditions. Blank.
What "blank" actually means
A blank cell in the use table is not a suggestion or a default. It is a prohibition. It means that use cannot legally operate on that land. A property owner who wants to convert a ground floor to retail cannot do so — not with a permit, not with an appeal, not by posting a bond. The use is simply not available in that district.
For HC-G2, the blanks cover eating and drinking establishments of all types, retail sales of virtually all kinds, personal services (hair salons, tailors, dry cleaners), fitness studios, art galleries operating as commercial uses, and professional service offices in street-facing ground-floor positions. All of it: blank.
There are two existing commercial uses in HC-G2 that operate as nonconforming uses — a 7-Eleven and a Harris Teeter — because they predate the current ordinance. They are grandfathered. No new business operating in that category could open today.
The C column is nearly as bad
Some uses in HC-G2 are marked C rather than blank, which sounds more promising. A C means you can apply for a Conditional Use Permit. But follow what that actually requires.
Under Norfolk's zoning procedures, a CUP application involves: a completed application with site plan and use description; a city application fee of $1,080 (Norfolk Planning Fee Schedule, effective July 1, 2024), plus legal and planning consultant costs that typically range from $2,000–$8,000 for a complete CUP application in a historic district; a referral to the Architectural Review Board for a recommendation (because this is a historic district); a public hearing before the City Planning Commission with legally required notice in The Virginian-Pilot; a Planning Commission vote to recommend approval or denial; and a final vote by City Council at a subsequent public hearing.
From application to Council vote: approximately four to eight months under normal circumstances. The outcome is not guaranteed. Two votes, two bodies, one ARB recommendation, one Virginian-Pilot notice.
For a neighborhood coffee shop or a yoga studio, this is not a regulation. It is a deterrent. The rational response for most small business owners is to locate somewhere else — Colley Avenue, 21st Street, Granby Street — where the permitting is straightforward. Which is exactly what they do.
This was a design choice, not an accident
The current Norfolk Zoning Ordinance was adopted in 2018, replacing a 1950-era code. The HC districts were written to emphasize preservation of residential character above all else. That instinct is defensible. Ghent's housing stock is genuinely worth protecting.
But the drafters conflated two distinct things: the physical character of structures (which historic preservation legitimately protects) and the commercial use of ground floors (which has nothing to do with whether a building looks like it belongs in 1905). A café in an existing building changes neither the facade nor the massing nor the materials. The ARB — the body that actually exists to protect those things — has no authority to stop a change of use absent an exterior alteration. The use table does that work instead, bluntly and comprehensively.
The result is a district frozen not architecturally — buildings can be renovated, modernized, even badly altered — but commercially. The ground floors of Ghent are legally stranded in a residential-only paradigm while every indicator of urban health — walkability, social cohesion, small business formation, tax base — suffers for it.
Compare: the districts that work
Drive six blocks. Walk four minutes. You are on Colley Avenue, which has a PCO — Pedestrian Commercial Overlay — designation layered on top of its residential base zoning. That overlay permits eating and drinking establishments, retail, personal services, and professional offices by right at the ground floor. No CUP. No hearing. A zoning certificate and a business license and you open your doors.
The result is visible: Colley Avenue is one of the most commercially vital streets in Norfolk. It has the kind of street life that urbanists write about and economists study and city councils point to when they want to show that Norfolk is a good place to do business.
HC-G2 has the same density as the blocks behind Colley Avenue. It has better architecture. It has shorter blocks. It has more residential population within walking distance. What it doesn't have is the PCO. And so it doesn't have the street life.
What the fix looks like
The fix is not complicated. It requires amending Table 3.6.11 to change specific blank cells to P — permitted by right — for a defined list of neighborhood-scale commercial uses on ground floors. That's a text amendment. It doesn't rezone anything. It doesn't remove the ARB. It doesn't override the architectural protections that make HC designation meaningful.
It just fills in the blanks.
The specific language is in Policy Brief No. 1. The performance standards that would accompany it — hours, size limits, activation requirements — are there too. This is not an untested idea. It is what Norfolk did on Colley Avenue, what it did on 21st Street, and what it has done on every pedestrian commercial corridor that actually works. The only question is whether the political will exists to do it in Ghent.
We think it does. That's what this campaign is for.
SOURCES: Norfolk Zoning Ordinance Table 3.6.11 (2018, amended 2023); Norfolk Zoning Procedures Manual (December 2023); Norfolk Ghent Business District Market Study, Department of Planning and Community Development; plaNorfolk2030 Land Use Strategies chapter.