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 bos@loudoun.gov.

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.

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