The Board of Supervisors has initiated the process for a Comprehensive Plan Amendment (CPAM-2021-0002) to widen Route 15 north of Montressor Road to the Maryland State Line. One component of this project includes potential bypass options (eastern or western) of the Village of Lucketts.  The potential western bypass option would go through JK Black Oak Wildlife Sanctuary and negatively impact the sensitive environmental resources of the property.

Speak Up to Oppose the Western Bypass Option

Indigo Bunting

This item is currently scheduled to be heard at 6:00 pm on November 30, 2021 at the Planning Commission’s public hearing. Staff will recommend that the Planning Commission provide a recommendation on the conceptual bypass location. Click here to sign up to speak either in-person or remotely. This item will subsequently be forwarded to the Board of Supervisors for action, likely in early 2022. Your voice is needed now and at future meetings to speak up to protect the unique natural assets that make JK Black Oak Wildlife Sanctuary a globally rare wetland.

In addition to speaking at the public hearing, we encourage people to submit written comments to the full Planning Commission by emailing loudounpc@loudoun.gov. The Planning Commission will receive a preliminary briefing on this item at their November 8 work session at 6:00 pm.

Here are some tips to craft a compelling message to the Planning Commission:

1. Introduce – Briefly describe your position on the topic.
2. Persuade – Tell your personal story, and how the topic relates to you. Your story is impactful.
3. Inform – Provide background information and data on the topic.
4. Conclude – Restate your message with a call to action.

Why It Matters

In March 2020, Loudoun Wildlife purchased the 87-acre globally rare wetland now known as JK Black Oak Wildlife Sanctuary from Chuck and Stacy Kuhn with support from The Nature Conservancy, Virginia Aquatic Resources Trust Fund and individual donors.  The Sanctuary is one of Loudoun’s special places, and it should be protected. Loudoun Wildlife Conservancy’s vision for the JK Black Oak Wildlife Sanctuary is to forever preserve and enhance its globally rare wetlands by protecting the sensitive vernal pools, unique geological setting, and its rich amphibian and wildlife populations. Additionally, to serve as a model and catalyst to conserve adjacent lands and to create an ecologically significant sanctuary for the conservation and study of native wildlife and flora there and to educate others in their value.

Vernal pool at JK Black Oak Wildlife Sanctuary.
Photo by SA Ferguson

Negative impacts from a western bypass option and key facts about JK Black Oak Wildlife Sanctuary:

• Loudoun Wildlife engages members of the public to restore habitat, provides educational opportunities for adults and students, and conducts citizen science monitoring on the property.
• The vernal pool wetlands are critical habitat for rare amphibians. Six of the 7 obligate vernal pool species found in Virginia, including the Jefferson Salamander, a state species of concern with Tier IV status of “Moderate Conservation Need,” have been identified on the property.
• The Land Trust of Virginia holds a conservation easement, recorded in 2019, to protect the conservation values of the property in perpetuity. The impacts of the western bypass option would be contrary to the purposes and terms of the easement.
• JK Black Oak Wildlife Sanctuary is located within the Limestone Overlay District, adopted by the Loudoun County, to regulate development and protect the sensitive karst geology.
• The western bypass option would impact the floodplain of an unnamed tributary to Limestone Branch, which runs parallel to Route 15. Loudoun Wildlife is collaborating with The Nature Conservancy on a large wetland restoration project to be constructed within the floodplain in summer 2022. The restored wetlands will serve as habitat for rare species and replace vernal pool habitat that has already been destroyed by development in the immediate area. In addition to the existing conservation easement, a future overlay easement will include additional protections for the area including, and surrounding this project.
• The Nature Conservancy is currently under a $1.5 million contract with Wetland Studies and Solutions, Inc. for engineering and construction of the project, and there would be considerable economic and financial ramifications if the mitigation project was terminated as a result of a western bypass alignment. This project is worth approximately $4 million through wetlands mitigation credits and will be used to offset impacts by developers within the Potomac watershed.
• Loudoun County has been working for years to obtain wetland mitigation projects within the county, and eliminating this project would be in direct conflict with mitigation policies the County is trying to implement.
• The western bypass option, by impacting the existing floodplain, would require mitigation, and grading required to elevate the proposed road would increase potential runoff and flooding in the neighboring trailer park.

Other Considerations

Variegated Fritillary butterfly.
Photo by Gerco Hoogeweg

The Loudoun County Natural Resources Team noted in their referral comments that:

• Staff recommends exploring alternative bypass alignments to minimize floodplain impacts, particularly if a western bypass alignment is pursued.
• Staff notes that the location of the western bypass would greatly impact the JK Black Oak Wildlife Sanctuary through habitat fragmentation and habitat loss which is inconsistent with Strategy 6.2 Action A which encourages the protection of natural resources, including streams, wetlands and floodplain, to prevent habitat fragmentation and foster biodiversity. In addition to the western bypass alignment being located within the Sanctuary, the currently proposed alignment bisects the floodplain across its entirety through the parcel.
• Staff recommends exploring alternative routes to avoid impacts to the JK Black Oak Wildlife Sanctuary and the floodplain.

Additionally, as part of the Natural Resources Team referral, the County Urban Forester noted:

• Staff supports the potential eastern bypass option for the following reasons. First, in the proposed layout, there is less of an impact to the Floodplain Overlay District. Second, the western option would impact a parcel under a conservation easement that contains a wildlife sanctuary committed to the protection of unique habitats and public education.

Community Support

We want to thank the members of the public who spoke up and overwhelming responded to protect JK Black Oak Wildlife Sanctuary during a survey in June 2021.

• Read the full survey results here
• Documents and other materials for the Public Information Meeting on June 23, 2021 on the CPAM project website.
• Read Loudoun Wildlife’s previously submitted comments on the potential bypass options.
• Journey Through Hallowed Ground’s additional concerns impacting the National Scenic Byway and Village of Lucketts