26 Sept. 2003
Commissioner Joan M. DuBois
Planning Commission
12000 Government Center Parkway
Suite 330
Fairfax, VA 22035
Supervisor Stuart Mendelsohn
McLean Governmental Center
1437 Balls Hill Road
McLean, VA 22101
Dear Commissioner DuBois and Supervisor Mendelsohn,
We write to express our concern with the density of Winchester
Homes’ proposed development on the Haycock-Longfellow block
(RZ/FDP 2003-DR-031). We urge you to reject the proposed rezoning
to PDH-5, and to encourage the developer and landowners to instead
submit a plan with an overall density of no more than 2 dwellings
per acre.
The proposed development would be located on 21 acres in an environmentally
sensitive area of the Burke’s Spring Branch/Pimmit Run watershed,
land which in its current forested state not only provides habitat
for a variety of plants and animals, but also protects downstream
properties and the habitat they contain by slowing and filtering
stormwater runoff and facilitating its gradual return, via groundwater
recharge, to local streams. While Winchester Homes maintains that
the section of Burke’s Spring Branch running through the proposed
development is not perennial, we believe that the continued activity
of the spring for which the stream is named, located a few hundred
feet to the northeast of the foot of Crutchfield Street, and the
regular presence of water in the stream at the point where it flows
under Hutchinson St., even during the recent drought, indicate that
it is. Perhaps some confusion was created by the timing of Winchester
Homes’ feasibility study toward the end of a record drought;
in any case, this issue will be definitely settled by the work of
the County’s Stream Survey Team. Whether or not the land surrounding
Burke’s Spring Branch is an RPA, it is unquestionably part
of the Chesapeake Bay RMA, and, because of its contiguity with already-protected
land, potentially part of an EQC, factors which need to be taken
into account when evaluating any development proposal (see Enclosure
1). Burke’s Spring Branch is also, for better or worse, part
of the County’s stormwater management system; a drainage ditch
channeling runoff from storm drains in much of the southwest section
of the Burke’s Spring watershed enters the stream at the foot
of Crutchfield Street. Erosion of the stream in the area of the
proposed development and additional erosion and flooding downstream
indicate that the stream is already severely stressed by this role;
increased impervious surface in the watershed will only exacerbate
these problems.
The actual density of Winchester Homes’ proposed development
(the result of taking affordable housing allowances into account)
is over 5.6 dwellings per acre, well above the 4-dwelling-per-acre
density at which, according to the Chesapeake Bay Preservation Ordinance,
“intense” development begins and “little of the
natural environment remains” (118-1-6-l). In addition to destroying
the environmental integrity of the land involved, such intensity
would unquestionably exacerbate erosion and flooding downstream.
It would also place considerable additional stress on already-overburdened
streets and schools, and result in lot sizes incompatible with surrounding
existing housing. By contrast, a density of 1-2 dwellings per acre
would place significantly less stress on the environment and public
services, and, once cluster development principles and affordable
housing allowances were taken into account, would allow for lot
sizes more compatible with adjacent R-3-zoned neighborhoods.
A density of 1-2 dwellings per acre is already recommended for
a nearby, topographically very similar part of the Kirby Planning
Sector, the Franklin Park portion of the Little Pimmit Run watershed
(see Enclosure 2). In the words of the Area Plan, Franklin Park
is characterized by “steep slopes and sensitive stream valleys
and heavily treed areas.” These “environmental constraints,”
the Plan concludes, dictate that “infill development is appropriate
only at the lower end of the 1-2 dwelling units per acre density
range” (Kirby Community Area Plan, land use recommendation
#7). Since the Area Plan’s discussion of the Haycock/Longfellow
block fails to take into account the environmental sensitivity of
the affected land, a discussion of a similarly sensitive nearby
area seems a logical place to turn for guidance in implementing
the Comprehensive Plan’s Environment and Land Use Objectives
during the rezoning process. The lower end of the 1-2 dwellings
per acre range may be too low a goal given the current 4-5 dwelling
per acre recommendation in the Area Plan, but the upper end of the
1-2 dwelling per acre range seems like a reasonable compromise.
As the discussion of Land Use Compatibility in the Policy Plan notes,
“every parcel is not necessarily entitled to the use or intensity
indicated” on the Land Use Map or in the Area Plans; “implementation
of the recommendations of the Plan will occur through the zoning
process which requires the satisfactory resolution of basic development-related
issues,” including “buffering and screening of adjacent
uses” and “protection of sensitive environmental areas”
(p. 9). In this case, a lower density is necessary to fulfill the
Land Use and Environment Objectives and Policies of the Comprehensive
Plan, including those specifically mentioned in the Kirby Sector
Area Plan. As Policy a of Land Use Objective 8, which is referenced
at the beginning of the Kirby Area Plan, states, Fairfax County,
through the planning process, has a responsibility to “protect
and enhance existing neighborhoods by ensuring that infill development
is of compatible use, and density/intensity, and that adverse impacts
on public facility and transportation systems, the environment,
and the surrounding community will not occur” (p. 5).
In addition to prescribing an overall density of no more than 2
dwellings per acre, we urge you to take the following steps to ensure
that any plan of development for all or part of these 21 acres fully
meets the goals of the Comprehensive Plan:
• Take no action on any proposed rezoning or development
plan until the County Stream Survey Team has completed its work
in the area, and made a final determination about which sections
of Burke’s Spring Branch are perennial.
• Require that any planned development meet all provisions
of the Chesapeake Bay Protection Ordinance, and all requirements
of the Zoning Ordinance, Public Facilities Manual, and other applicable
laws and guidelines for design and location of stormwater management
facilities, without waivers or other exceptions.
• Ensure that all Residential Development Criteria for respecting
the environment are met, especially those for “protecting,
enhancing, and/or restoring the habitat value and pollution reduction
potential of floodplains, stream valleys, EQCs, RPAs, woodlands,
wetlands, and other environmentally sensitive areas,” for
“minimiz[ing] offsite impacts on water quality by commitments
to state of the art best management practices for stormwater management
and low-impact site design techniques,” and for “manag[ing]”
“the volume and velocity of stormwater runoff from new development.
. .in order to avoid impacts on downstream properties” (p.
27). A Water Quality Impact Assessment will certainly be necessary,
and other studies may be needed, to assess the ability of proposed
stormwater management measures to manage runoff not only from the
developed property, but also from the upstream storm sewers that
empty into Burke’s Spring Branch.
• Apply strictly the Environment and Tree Preservation and
Tree Cover requirements of the Residential Development Criteria,
reminding developers that “if quality tree cover exists on
site as determined by the County, it is highly desirable that developments
meet most or all of their tree cover requirement by preserving and,
where feasible and appropriate, transplanting existing trees”
and that “tree cover in excess of ordinance requirements is
highly desirable” (p. 28). In the case of this particular
property, devoting as much of the required open space as possible
to preserving existing quality tree cover would maximize the continued
ability of the land to filter and slow stormwater runoff, and minimize
adverse impacts from fertilization and other lawn care practices.
• In keeping with Objective 9 of the Policy Plan’s
Environment section, encourage developers to locate open space,
especially that containing preserved tree cover, in such a way as
to extend and enhance the EQC along Burke’s Spring Branch
and Pimmit Run, including land protected by Haycock-Longfellow,
Kirby, and the Pimmit Run Stream Valley parks, and held as open
space by the McLean Greens/Montivideo Square, McLean Province, Brooks
Square, and L’Ambiance of McLean homeowners’ associations,
and to provide screening between new construction and Haycock/Longfellow
Park. Such placement would be in keeping with several provisions
of Policy a, Objective 9 of the Environment section of the Comprehensive
Plan, including those stressing the desirability of “connectedness”
between habitats that “could become part of a corridor to
facilitate the movement of wildlife” and encouraging the use
of open space to “separat[e] land uses” (p. 13). Haycock-Longfellow
Park has benefited by the placement of open space in adjoining communities
so as to provide connectedness with and screening of parkland; in
order to preserve the character of the neighborhood and the park,
Winchester Homes should be encouraged to follow the same practice.
• In keeping with Land Use Objective 14, Policies c, d, and
j, and the Neighborhood Context section of the Residential Development
Criteria, ensure that sufficient screening is provided between areas
of compatible use but very different density/intensity, e.g. between
single family homes built on lots of significantly different size.
• To avoid adverse impacts on neighbors living on or near
Crutchfield, Montour, and Hutchinson Streets, review the Winchester
plan carefully to ensure that on-street parking adequate to meet
the demands of both daily life and special events is provided within
the new development. As a May 19, 2003 article in the Washington
Post relates, recent dense developments that make extensive use
of private streets with little or no room for on-street parking
– features integral to the Winchester plan – have experienced
serious shortages of parking for both private and commercial vehicles
(“Packing in the Houses, But Not the Parking; Dense Developments
Skimp on Spaces,” p. A01). While the Winchester plan attributes
4 off-street spaces to each of the single-family and market-rate
attached houses – two in a garage and two in a driveway –
it is unlikely that, in practice, residents will use more than two
of these spaces simultaneously, either because all or part of the
garage is used for storage, or because residents and guests do not
wish to block the garage by parking in the driveway. In addition,
the proposed minimum 18-foot driveway length is insufficient to
accommodate some of the large private vehicles popular today, let
alone many service and delivery vehicles. Unless sufficient on-street
parking is provided within the Winchester development, residents,
guests, and service providers will inevitably seek parking on nearby
streets outside the development. This problem will only be exacerbated
by close vehicular and pedestrian connections between the Winchester
development and surrounding existing neighborhoods, and by the fact
that the homes in the proposed development are of a size to encourage
large gatherings. According to the Washington Post article, a County
review of regulations regarding parking requirements for new development
is currently underway; given the Winchester proposal’s extensive
use of private streets and its requested waiver of the 600-ft. maximum
length for private streets, it would seem wise to defer any decision
on the proposal until that study is complete. It also seems obvious
that, to avoid adverse impacts on existing neighborhoods, the development
will need to incorporate public as well as private streets. According
to the Residential Development Criteria, “public streets are
preferred,” and “convenience and safety issues such
as parking on private streets should be considered during the review
process” (p. 29). In this case, the convenience and safety
of residents in surrounding neighborhoods require that the Winchester
development provide onstreet parking opportunities equivalent to
those on older streets nearby.
• In fulfillment of the County’s Heritage Resource
Objectives and associated portions of the Residential Development
Criteria, direct the developer, county staff, or both to “conduct
archeological, architectural, and/or historical research to determine
the presence and significance of heritage resources” and “potential
heritage resources” (pp. 31, 32) in the area slated for development,
including those associated with historic and prehistoric uses of
Burke’s Spring, and with activities in the area during the
Civil War. Encourage the developer to “preserve and rehabilitate”
any “heritage resources” identified, especially the
c.1807 Dye/Burke house, located at 6718 Montour Drive and currently
owned by the Frase family, for “continued adaptive use [if]
feasible.” Whether or not such preservation and rehabilitation
is feasible, direct the developer to take steps to “document”
(p. 32) any evidence of the historic uses of the property –
including its relationship to the spring and other surrounding natural
features, and the use of slave labor on the land -- and to make
such information, with its potential to “put[] residents in
touch with their heritage, provid[e] residents and property owners
with a sense of temporal stability and continuity, and instill[]
in both young and old a loyalty and commitment to place and community”
(Heritage Resources, p. 1), available to the public. As the Heritage
Resources Section of the Comprehensive Plan notes, “unprotected
heritage resources – resources whose significance has not
yet been evaluated and unrecorded resources on unsurveyed lands
– are particularly vulnerable to loss” due to “inadequate
survey or assessment of heritage resources during the earliest stages
of project planning” and “construction on unsurveyed
lands” (p. 1). Since planning for this development is approaching
the middle stages, immediate implementation of these recommendations
is essential.
• Encourage the developer and landowner
to preserve the c.1910 McConvey house, located at 2119 Great Falls
St., originally built by a descendent of the Burke family, and currently
owned by Harold H. Saunders. While this house may be neither old
nor distinctive enough to qualify for heritage status, its location
on a hill above Great Falls St. has made it a local landmark for
almost 100 years, and, along with other farmhouses scattered along
Great Falls St. between route 123 and Falls Church, it provides
County residents with a reminder of the County’s agricultural
past. Such ordinary dwellings, which are increasingly scarce thanks
to the pressures of development, have the tendency to slip under
the radar of heritage preservation criteria which focus on “significant”
persons and events (Heritage Resources, p. 4). Nevertheless, they
are important to understanding the fabric of everyday life in the
past, and clearly contribute to the County’s overall Heritage
Resource goals of “enhancing the quality of life through aesthetic
diversity in the landscape” and “providing a sense of
continuity with the County’s historic and prehistoric past”
(p. 3).
• Encourage the developer and involved landowners to make
use of conservation and, if appropriate, historic easements to achieve
the goals outlined above.
Thank you for your consideration of these concerns and suggestions.
If you wish to discuss them further, we can be contacted at the
addresses and phone numbers below.
Sincerely,
[signed by Cathy Saunders of Great Falls St. and Kevin and Janet
Zerussen, Daline Gregory, Mary Dougherty, and Joel and Len Clark
of Crutchfield St.]
Enc.
cc: John Foust
P.O. Box 1013
McLean, VA 22101
Supervisor Sharon S. Bulova
9002 Burke Lake Road
Burke, VA 22015
Enclosure 1
Aerial photo of Burke’s Spring Branch watershed and adjacent
areas of Pimmit Run, taken from the Fairfax County aerial viewer.
The streams are drawn in blue, and the proposed Winchester development
is outlined in red. Green shading indicates currently protected
land (parks and open space held by homeowners’ associations)
that meets at least two of the EQC criteria in Objective 9, policy
a of the Environment section of the Comprehensive Plan (i.e. the
land is a protected stream valley, exhibits “connectedness”
with protected stream valleys, forms “part of a green belt
separating land uses,” and/or helps to reduce nonpoint source
pollution). Yellow shading indicates unprotected land that meets
two or more of these criteria. In short, all of the land in the
planned Winchester development has the potential to form part of
the county EQC system; how much of it actually serves this function
will depend on the extent to which the development is designed to
preserve the connectedness of remaining habitat and the pollution
reduction potential of the land.
Enclosure 2
Comparison of Franklin Park area (zoned 1-2 dwellings per acre)
with area of proposed Winchester Development, based on attached
Chesapeake Bay Interim Guidance Maps, Topographic Maps, and Aerial
Photographs
|
Franklin Park |
Proposed Winchester Development |
Streams |
Estimated to be a combination of perennial & intermittent |
Estimated to be a combination of perennial & intermittent |
Distance of land from nearest stream |
0-800+ feet |
0-600 feet |
Slope within 100 feet of stream |
5%-40% |
5%-10% |
Slope within 600 feet of stream |
6.6%-15% |
6.6%- 8.3% |
Tree cover |
variable; considerably interrrupted by houses, lawns, driveways,
and streets |
nearly continuous; even “developed” parcels are
primarily wooded |
Connectivity with existing EQC |
spotty |
complete |
Conclusions: The Franklin Park area contains some considerably steeper
slopes than the area of the proposed Winchester Development. However,
much of the Franklin Park land described in the Kirby Area Plan
as characterized by “predominantly steep slopes and sensitive
stream valleys and heavily treed areas” and therefore “appropriate”
for “infill development. . .only at the lower end of the 1-2
dwelling units per acre density range” (p. 101) is very similar
to that in the area of the Winchester Development: the streams into
which the land drains may be perennial or intermittent, and slopes
are in the 5-10% range. In addition, some of the Franklin Park land
included in the 1-2 dwelling per acre zoning recommendation is considerably
further away from a stream, and/or less densely and continuously
treed, than the area of the proposed Winchester development, and
the Franklin Park area as a whole, by virtue of its already-developed
state, exhibits notably less connectivity with existing EQC than
does the area of the proposed Winchester development. Since the
same or greater “environmental constraints” are present
in the area of the proposed Winchester development as in much of
the Franklin Park area, the same 1-2 dwelling per acre zoning recommendation
should apply.
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