When advocates argue for zoning reform, skeptics often ask: "Has this been done before? Do we have evidence it works?" In Norfolk's case, we don't have to look at Portland or Minneapolis or some other city's planning experiment. We just have to look four blocks west.
Norfolk's Pedestrian Commercial Overlay — PCO — districts are the direct precedent for what we're asking in HC-G2. They exist. They're in the zoning ordinance. They work by every measure the city uses to evaluate commercial corridors. And the mechanism by which they were created is exactly the same mechanism we're proposing to use here.
What a PCO is
A Pedestrian Commercial Overlay is a designation layered on top of a base zoning district. The base district — residential, historic, whatever — continues to govern the overall character and use of the area. The PCO adds a supplemental permission: ground-floor commercial uses are permitted by right along designated street frontages.
Norfolk currently has five PCO designations, each named for the corridor they govern: PCO-Colley, PCO-21st Street, PCO-Riverview, PCO-35th Street, and PCO-Lafayette. Each was created by a zoning text amendment — exactly the same type of amendment this campaign is seeking for HC-G2.
Under Table 3.9.21 of the Zoning Ordinance — the PCO use table — eating and drinking establishments, retail sales, personal services, professional services, and similar neighborhood-commercial uses are marked P in the PCO column. Permitted by right. No CUP. A business license, a zoning certificate, and the keys to the space.
What Colley Avenue looks like because of its PCO
Walk down Colley between 21st and 26th Street on a Wednesday evening. You will pass: independent restaurants, a wine bar, coffee shops, a bookstore, salons, a yoga studio, specialty retail, and gallery spaces. The sidewalks have foot traffic. The lights are on. People are sitting outside. Neighbors who have never met are sharing the same block at the same time.
That is not the result of Colley Avenue having better architecture than Colonial Avenue. It's not because Colley residents are more social or more entrepreneurial. It is because the zoning code permits those uses to exist on Colley and prohibits them on Colonial. The physical neighborhoods are comparable. The regulatory treatment is entirely different.
Why a straight PCO overlay isn't enough for HC-G2
We've considered two approaches: adding a PCO overlay to specific corridors within HC-G2, or amending Table 3.6.11 directly to permit commercial uses district-wide. Both achieve the goal on the corridors. The distinction matters for scope and ambition.
A corridor PCO overlay — say, a PCO-Colonial or PCO-Ghent designation on Colonial Avenue — would activate that specific street. It would leave the rest of HC-G2 unchanged. This is the narrower, politically safer path, and it is a genuine option if the broader amendment faces resistance.
Amending Table 3.6.11 directly treats HC-G2 as what it actually is: a dense urban residential district where the entire street grid is walkable, not just selected corridors. It says that any ground-floor street-facing space in the district can activate commercially, subject to performance standards, without the city pre-selecting winners and losers among streets. This is more ambitious. It also makes the more complete argument — that the prohibition is wrong for the whole district, not just the most visible blocks.
Our position: pursue the Table 3.6.11 amendment as the primary ask. Identify PCO corridor designations on Colonial and other specific streets as a fallback that we will accept and build on. Don't give up the table amendment without a fight, but don't lose the campaign over tactics.
The process Norfolk has already walked through
Every existing PCO designation required: a text amendment application, an ARB recommendation (for those overlapping with historic districts), a City Planning Commission public hearing, and a City Council vote. In each case where a PCO was approved, staff cited plaNorfolk2030's Land Use Strategies chapter and the economic benefits of pedestrian-scale commercial activity in residential neighborhoods.
That's the same staff report language we need. The same plan consistency finding. The same process. We're not asking Norfolk to invent something new or take a regulatory risk it hasn't already taken five times. We are asking it to extend a model it created, deployed, and has observed working for years.
The hearing room argument is simple: You've done this before. Do it here.
For the ARB presentation
The ARB's role in the PCO districts is instructive. When PCO overlays were added to corridors in or near historic districts, the ARB weighed in on the physical implications of increased commercial activity — particularly signage, awnings, facade modifications, and the introduction of outdoor seating infrastructure. In each case, the ARB's response was not to oppose the overlay but to ensure that the performance standards governing exterior modifications were sufficiently protective.
That's the right framing for our ARB presentation too. We're not asking the ARB to approve commercial uses — use permissions are a Planning Commission and Council matter. We're asking the ARB to weigh in on whether the performance standards we've proposed (described in Policy Brief No. 1) adequately protect the physical character of the HC-G2 district. We believe they do. We want the ARB to agree, and we should come to that meeting prepared to revise the standards in response to their concerns rather than defending every word.
Bring precedents from the other PCO presentations. Bring photographs of what activated ground floors look like in HC-G1 corridors that already operate commercially. Make the visual case that commercial use and architectural integrity are not in conflict.
SOURCES: Norfolk Zoning Ordinance Table 3.9.21 (PCO Use Table); Norfolk Zoning Ordinance § 3.9 (Overlay Districts); Day Care Home Text Amendment staff report (Dec. 2023), demonstrating standard process for HC district text amendments; vacation rental text amendment staff reports (2020, 2023), demonstrating ARB role in HC district amendments.