The Loudoun County Board of Supervisors will be taking action on Item 8 Temple Baptist Church on Tuesday, January 19 during their Business Meeting. The updated item presented to the Board of Supervisors can be read here. The updated item contains answers to the Board of Supervisors’ questions they raised at last month’s public hearing. The developer has also updated the proffers which includes a modification to the proposed land swap designed to offset the destruction of wetlands and the wetlands’ buffer. However, all of our previous concerns about the proposed ballfields to be built in the major floodplain of Broad Run remain.
Your voice is needed, please reach out to your supervisor expressing your concerns. We have listed email addresses for each supervisor below. Speakers can participate in the Public Hearing remotely if they sign up before 12pm on January 19. Speakers can also attend the meeting in person following COVID-19 protocols and social distancing measures set forth by the county. For more information about how to participate in the Business Meeting, click here.
Board of Supervisors email addresses:
The updated proffers and the proposed land swap and cash payment do not adequately offset or mitigate the destruction of wetlands in the floodplain. Since there wasn’t comparable land of conservation value to appropriately offset the impacts to the floodplain, wetlands, and wetlands buffer, the developer now seeks to essentially purchase access to developing those areas for $150,000. The floodplains, wetlands, and riparian buffers of Loudoun County should not be for sale to development. They should be protected as was intended by the policies of the 2019 Comprehensive Plan. The Comprehensive Plan was approved by the Board of Supervisors representing the residents of Loudoun, and the public has entrusted the Board of Supervisors to adhere to those policies, which benefit every member of the public, not a private entity.
We recognize that the 1.16 acres offered in the proffer would provide an important linkage to the future Emerald Ribbons countywide linear parks and trails system, but we recommend the County seek alternate methods of acquiring this parcel rather than sacrificing approximately 4 acres of wetlands and wetlands buffer in a major floodplain.
Our previous concerns below regarding the environmental impacts of the proposed ballfields remain, and we concur with staff’s recommendation to not approve this application as it is currently proposed.
From staff: “The River and Stream Corridor Resources (RSCR) Policy in the 2019 GP states that the County shall protect natural ecosystems and restore quality. As called for in the 2019 GP, the Broad Run, its associated floodplain, and a 50-foot management buffer surrounding the floodplain are elements of the RSCR. The protection of RSCR in their entirety further County goals to protect and improve stream quality and watershed health. The 2019 GP also seeks to protect and enhance impaired streams, such as the Broad Run, in order to improve water quality and provide ecological benefits.”
“Also, the application does not meet Zoning Ordinance criteria for allowing floodplain alterations. Staff has determined that the requests would not conform to the criteria that requires compatibility with surrounding and existing uses and that the proposal would not be in conformance with the Comprehensive Plan.”
We would like to highlight additional concerns that have been brought to our attention.
- When the original Kincora development was approved, it proposed to impact wetlands. To offset those impacts, the developer had to create additional wetlands and provide reforestation at other locations on the property. This proposed application would destroy a portion of those created wetlands and reforested areas. If approved, Loudoun County would be giving permission to destroy wetlands and reforestation they previously required to be constructed.
- While staff notes there would be negative impacts to wildlife, there is a lack of specificity or detail on what the negative impacts would be to wildlife and wildlife habitat. Over 14 years ago, before the wetlands mitigation project was created, a habitat evaluation was completed to determine if any endangered or threatened species would be impacted. At that time, there were not any Wood Turtles, or any other threatened or endangered species, found. It is unclear at this time if species of conservation concern for the state of Virginia were evaluated. Since 2012, 109 bird species have been recorded in this vicinity by citizen scientists. The comments by staff underscore the need for more staff dedicated to studying and evaluating wildlife and wildlife habitat. For example, wildlife biologists and/or botanists would be able to study and provide concrete evidence and impacts on wildlife, information that is vital when considering the potential impacts of a project.
- In order to construct the ballfields, the topography would need to adjusted between 2 and 8 feet. It is unclear at this time how that would be achieved, but the construction of a berm or retaining wall could create channelization of runoff directly into the adjacent wetland, and degrade the wetland over time (which would not have an adequate buffer due to this project).
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ORIGINAL POST 12/9/20:
The Loudoun County Board of Supervisor’s December 9, 2020 Public Hearing is scheduled to hear comments on Item 7 Temple Baptist Church. The item presented to the Board of Supervisors can be read here. Speakers can participate in the Public Hearing remotely if they sign up before 12pm on December 9. Speakers can also attend the meeting in person following COVID-19 protocols and social distancing measures set forth by the county. For more information about how to participate in the Public Hearing, click here. Written comments can also be submitted by emailing firstname.lastname@example.org.
The purpose of this application is to consider a Zoning Concept Plan Amendment (ZCPA) and Special Exception (SPEX) applications to construct privately-owned ballfields (active recreation use) in an area of the Kincora Development that is within the major floodplain of Broad Run and subject to a County controlled open space easement.
Loudoun Wildlife Conservancy concurs with staff’s recommendation that the ZCPA and SPEX applications are not appropriate for this site as they are in direct conflict with the 2019 Comprehensive Plan and current Zoning Ordinance. This application as proposed should not have proceeded as far as it has, and the Board of Supervisors should make it clear to this applicant, and other future applicants, that Loudoun County values it’s wetlands, floodplains, forests, conservation easements, and the ecological services that these lands support not only for wildlife habitat, but to help combat climate change.
There are many reasons why active recreation development is not allowed in major floodplains including adverse impacts to our rivers, creeks, streams, and associated River and Stream Corridor Resources. In addition to the concerns raised by staff’s policy analysis, we would like to highlight some of the negative impacts proposed by the application.
- Destruction of wildlife habitat in a functional wetlands (wildlife recorded in the area include, but are not limited to: American Kestral (nesting in area for over a decade), Rusty Blackbird (at risk species in decline), sparrows (including uncommon in Loudoun Vesper and Savannah species), shorebirds (some rarely seen in Loudoun), ducks, woodpeckers, owls, foxes, coyotes, and river otters)
- Increased noise from active recreation uses would also negatively impact the existing wildlife habitat
- Turf ball fields would result in increased use of herbicides and pesticides to maintain the fields while simultaneously reducing the amount of vegetation that could filter run off of pollutants from the fields and adjacent impervious surfaces. This would potentially negatively impact the County’s MS4 permit, and water quality of the Broad Run, Potomac River, and Chesapeake Bay.
- While the staff notes that there would not be negative impacts downstream due to increased velocity of stormwater, we ask the Board to also consider the cumulative impacts of allowing special exceptions throughout the entire watershed. These cumulative impacts often do not get calculated in individual applications, and downstream neighborhoods from this site already have regular issues with flooding.
Furthermore, this application proposes to swap land currently under conservation easement. While the acreage of the land is similar, the conservation value and ecological services provided by the land are not. The value of contiguous land part of a functional wetlands in a major floodplain cannot be understated and should not be disturbed.
In short, these wetlands, combined with proffered parkland on the east and west side of Broad Run have the future potential to be a premier passive recreation greenspace in eastern Loudoun County if they are managed and maintained properly. This application as proposed is in direct conflict with that idea, the policies of the Comprehensive Plan and Zoning Ordinance, and should not be approved.