Loudoun County, Protect Wood Turtle Habitat

We, the undersigned residents of Loudoun County, Virginia, request that you deny the developer’s request to construct 22 houses in the area called “Shadowbrook Farm” located on Harpers Ferry Road on the old Arnold Farm.  Loudoun Wildlife Conservancy has conducted bird and butterfly counts in the area for the last 10 years and recognizes it as one of Loudoun’s critical habitat areas.  In addition to the negative impact that this development will have on the water quality of Piney Run, of particular concern is that this development will result in destruction of the upper third section of known wood turtle habitat on Piney Run, resulting in further decline of this State threatened species.  We ask that you act in appropriate response to the Virginia Department of Game and Inland Fisheries’ recommendation that “small waterways with [wood turtle] species should be preserved and development near them restricted.  All known colonies should be protected.” 
 
Because this is such sensitive natural habitat, we request a complete ecological analysis of the Piney Run watershed and an environmental impact assessment prior to approval of any proposed development in and/or impacting the watershed.  We further request that land delineated by VDGIF as wood turtle habitat be protected and deemed un-developable so that this species can be protected.  We request that official public hearings be held on the development before any decision is made by the County to approve this development and/or any other preliminary approvals, waivers, variances and/or special exceptions in this matter.
The Situation:
A 114 acre development has been proposed for land adjacent to the Blue Ridge Center for Environmental Stewardship. This development will include 22 parcels (18 in densely packed hamlets) as well as the requisite infrastructure: roads, utilities and sewer systems to support the 22 homes. In addition to farmland and habitat destruction, the development proposes to construct a bridge across Piney Run, install a sewer line for two of the houses across visible wetlands and allow drainage into Piney Run.  It also has house sites, drain fields and driveways on Mountain Overlay steep slope areas that encroach the floodplain.

 
Originally, this development was planned for 11 houses.  When the Virginia Supreme Court overturned the Loudoun County zoning plan on an advertising technicality, the developer doubled his approval request to the 22 houses. The developer also requested a waiver from the required floodplain study, claiming no crossings or encroachments into the floodplain. This waiver was denied. The Board of Supervisors is expected to re-zone the land to 1 house per 10 acres this summer under the Clem-Burton zoning proposal.  The developer is attempting to take advantage of this temporary window when the old 1 house per 3 acres (A-3) zoning is back in place but the effects of this action will be devastating to the environment. 

 
Why this development is of concern:
This area is one of the richest habitats of Loudoun where a great diversity of animals and plants still thrive.  Loudoun Wildlife Conservancy (LWC) has conducted bird and butterfly counts in the area for the last 10 years and we recognize it as one of Loudoun’s critical habitat areas.  Piney Run currently has excellent forest and wetland habitat. This development threatens the water quality of this stream and watershed by increasing sediment and run-off that will result from disruption of soil and forested areas.

 
In addition, of particular concern, is that this development is likely to result in destruction and/or degradation of the upper third section of known wood turtle habitat on Piney Run. The Virginia Department of Game and Inland Fisheries (VDGIF) delineated this area as wood turtle habitat.  Development of this habitat will result in further decline of the wood turtle through elimination of protective habitat, introduction of more wood turtle predators (raccoons, foxes) that occurs with urbanization, and increased road mortality.

 
The wood turtle is listed as a State of Virginia threatened species and the VDGIF recommends that it be listed as an endangered species because of its rapidly declining status. VDGIF also recommends that “small waterways with this species should be preserved and development near them restricted.  All known colonies should be protected.” 

 
Our position:
We strongly oppose the development as planned.  Because this is such sensitive habitat, we request a complete ecological analysis of the Piney Run watershed and an environmental impact assessment prior to approval of any proposed development in and/or impacting the watershed.  We further request that land delineated by VDGIF as wood turtle habitat be protected and deemed un-developable so that this species can be protected.  We request that official public hearings be held on the development before any decision is made by the County to approve this development and/or any other waivers, variances and/or special exceptions in this matter.
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