County of Loudoun. Department of Planning and Zoning MEMORANDUM. SUBJECT: SPEX & SPMI , Egypt Farm Lot 6 Heliport Second Referral

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1 County of Loudoun Department of Planning and Zoning MEMORANDUM DATE: November 14, 2014 TO: FROM: Marchant Schneider, Project Manager Land Use Review Marie Genovese, AICP Planner III, Community Planning SUBJECT: SPEX & SPMI , Egypt Farm Lot 6 Heliport Second Referral BACKGROUND The applicant has responded to Community Planning s first referral comments dated August 18, Most of the issues raised in the first referral have been addressed; however, Staff continues to recommend mitigation of impacts by limiting the scope of the operations. Egypt Farm LLC requests a Special Exception and Minor Special Exception to allow a heliport on a 58 acre parcel, to be expanded to a minimum of 80 acres prior to the creation of the heliport. The property is part of the 540 acre Egypt Farm, located north of Snickersville Turnpike (Route 734), south of Egypt Farm Lane, east of Watermill Road (Route 731), and west of Shelburne Glebe Road (Route 729) (See Vicinity Map). The property is surrounded by agricultural and rural residential uses. Attachment 1a A-1

2 SPEX & SPMI , Egypt Farm Lot 6 Heliport Community Planning Second Referral November 14, 2014 Page 2 The owner of Egypt Farm proposes to designate a helicopter landing pad on an existing concrete pad on Lot 6 as well as use the existing 6,540 square foot barn foundation to construct a hangar for the helicopter. The heliport is intended to be used for personal use with no more than ten take-offs and ten landings per week. The owner plans to construct their primary residence on the farm property and would like to use a private helicopter to travel between the property, their business, and another farm located in Frederick County, Virginia. OUTSTANDING ISSUES The land use pattern and design strategy seeks to retain the rural area as an essential asset of Loudoun County. As such, the County promotes rural residential and rural economy uses within the Rural Policy Area (Revised General Plan, Chapter 7, Land Use Pattern and Design, Text). Development should promote opportunities for the expansion of rural economy uses, open space, farms, historic and natural areas, forests, the Green Infrastructure, while protecting the rural character of the landscape (Revised General Plan, Chapter 7, Land Use Pattern and Design Strategy Policies, Policy 8). While the proposed heliport will be for private use only, the mitigation of impacts can be compared to a nonagricultural commercial use. The Plan provides that these types of uses may be permitted by special exception in the Rural Policy Area if the use is compatible in scale and intensity; poses no threat to public health, safety, and welfare; and if the use helps to preserve farmland and open space and continue agricultural operations (Revised General Plan, Chapter 7, Rural Economy Policies, Policy 14). The applicant has agreed to expand Lot 6, where the helipad will be located to a minimum of 80 acres prior to the establishment of the use. In an effort to mitigate any impacts on surrounding properties the applicant has also agreed to place a restrictive covenant on the adjacent lots to ensure development of a residential structure will not be within a 650 foot radius of the heliport; adhere to the Fly Neighborly Program ; noise levels no greater than 65 db(a) at the Lot 6 property boundaries; and minimize the impacts of take-offs and landings by maintaining an altitude of 500 feet above the ground, until the helicopter is over the parcel before descending and reaching an altitude of 500 feet at the parcel boundary when taking off. Analysis Staff finds the use is appropriate provided the inclusion of the conditions of approval as discussed above. ZONING MODIFICATIONS The applicant is seeking a Minor Special Exception to modify the following Zoning Ordinance performance standards for an airport/landing strip. Scope of Aviation Operations: The applicant seeks to increase the hours for takeoffs and landings from between the hours of 6:00 a.m. to 6:00 p.m. to between the hours of 6:00 a.m. to 10:00 p.m. The justification for the modification is that the heliport is for personal use to access other farm properties outside of Loudoun County as well as for business travel outside of the County. The applicant provides that business meetings can last until 6:00 p.m. creating the need to arrive home at a later hour. The applicant provides that they will agree to a condition limiting the take-offs and landings between the hours of 6:00 p.m. and 10:00 A-2

3 SPEX & SPMI , Egypt Farm Lot 6 Heliport Community Planning Second Referral November 14, 2014 Page 3 p.m. to no more than one take-off and one landing. Based on the wording it appears the applicant is agreeing to one take-off and one landing between this 3 hour period. If the reasoning behind extending the hours of the operation is for the later arrival due to business purposes, it seems the operations could be limited to one take-off or one landing between 6:00 p.m. and 10:00 p.m. Analysis Staff requests the applicant limit the operations of the helipad to no more than one take-off or landing between 6:00 p.m. and 10:00 p.m. Runway Buffer Area: The regulations require a minimum buffer area equal to a 0.25 mile radius extending from the end of all runways or landing strips. The applicant seeks to eliminate this requirement as they will be using an existing concrete pad, which is located near existing farm structures, including the former barn to be converted to the hangar, an unoccupied dwelling (the former farmhouse), for takeoffs and landings. Additionally, the applicant provides helicopters use vertical takeoffs and landings and do not require the buffer area. Staff has no issue with the elimination of the buffer requirement provided the former farmhouse is not to be used as a permanent residential structure. RECOMMENDATIONS Staff has no issue with the proposed Special Exception and Minor Special Exception applications provided the commitments as referenced above are included with conditions of approval. cc: Julie Pastor, FAICP, Planning and Zoning Director Cynthia Keegan, AICP, Program Manager via A-3

4 County of Loudoun Department of Planning and Zoning MEMORANDUM DATE: August 18, 2014 TO: FROM: Marchant Schneider, Project Manager Land Use Review Marie Genovese, AICP Planner III, Community Planning SUBJECT: SPEX & SPMI , Egypt Farm Lot 6 Heliport BACKGROUND Egypt Farm LLC requests a Special Exception and Minor Special Exception to allow a heliport on a 58 acre parcel within the 540 acre Egypt Farm. The property is located north of Snickersville Turnpike (Route 734), south of Egypt Farm Lane, east of Watermill Road (Route 731), and west of Shelburne Glebe Road (Route 729) (See Vicinity Map). The property is surrounded by agricultural and rural residential uses. The owner of Egypt Farm would like to designate a helicopter landing pad on an existing concrete pad on Lot 6 as well as use the existing 6,540 square foot barn foundation to A-4

5 SPEX & SPMI , Egypt Farm Lot 6 Heliport Community Planning Referral August 18, 2014 Page 2 construct a hangar for the helicopter. The heliport is intended to be used for personal use with no more than one trip in and out per day. The owner plans to construct their primary residence on the farm property and would like to use a private helicopter to travel between the property, their business, and another farm located in Frederick County, Virginia. A review of County s GIS records and submission materials indicates river and stream corridor resources, drainageways, steep slopes, and tree cover are located on the subject site. COMPLIANCE WITH THE COMPREHENSIVE PLAN The subject property is governed under the policies of the Revised General Plan. The Revised General Plan places the property within the northern tier of the Rural Policy Area. The area is planned for rural economy uses and limited residential development at a density of 1 dwelling unit per 20 acres (Revised General Plan, Chapter 7, Rural Residential Policies, Policy 3). The application has been reviewed under the Revised General Plan Rural policies of Chapter 7 and the Green Infrastructure policies of Chapter 5. LAND USE ANALYSIS The Rural Policy Area contains large and small farms, producing a variety of products, vineyards, bed and breakfast lodging, home-based and other businesses (Revised General Plan, Chapter 7, General Characteristics, Text). The land use pattern and design strategy seeks to retain the rural area as an essential asset of Loudoun County. As such, the County promotes rural residential and rural economy uses within the Rural Policy Area (Revised General Plan, Chapter 7, Land Use Pattern and Design, Text). Development should promote opportunities for the expansion of rural economy uses, open space, farms, historic and natural areas, forests, the Green Infrastructure, while protecting the rural character of the landscape (Revised General Plan, Chapter 7, Land Use Pattern and Design Strategy Policies, Policy 8). While the proposed heliport will be for private use only, the mitigation of impacts can be compared to a non-agricultural commercial use. The Plan provides that these types of uses may be permitted by special exception in the Rural Policy Area if the use is compatible in scale and intensity; poses no threat to public health, safety, and welfare; and if the use helps to preserve farmland and open space and continue agricultural operations (Revised General Plan, Chapter 7, Rural Economy Policies, Policy 14). The Statement of Justification provides the proposed heliport is centrally located within the 540 acre Egypt Farm and discusses setbacks form the heliport to the edge of the farm property. Staff notes the entire 540 acre Egypt Farm is not the subject of the Special Exception application, but rather only the acre Lot 6. Analysis Staff recommends the applicant include the entire Egypt Farm property in the Special Exception application as referenced in the Statement of Justification to assess impacts to neighboring properties. A-5

6 SPEX & SPMI , Egypt Farm Lot 6 Heliport Community Planning Referral August 18, 2014 Page 3 COMPATIBILITY The use should meet site design standards (i.e., buffering, use intensity, siting) and pose no threat to public health, safety, and welfare (Revised General Plan, Chapter 7, Land Use Pattern and Design Strategy Policies, Policy 6). The Statement of Justification provides the applicant plans to use an existing 60 by 100 (6,000 square foot) concrete pad as the helicopter landing pad and the foundation of an existing barn to construct a hangar for the helicopter. The Statement of Justification further provides the heliport will be used for personal use only with at most one trip a day on average. To address any concerns on impacts to surrounding properties, the Statement of Justification provides the applicant will adhere to the internationally recognized Helicopter Association International Fly Neighborly Program. The Revised General Plan contains noise policies to protect noise-sensitive uses. The Noise Abatement Criteria (NAC) table in Chapter 5 of the Revised General Plan identifies residences as Activity Category E with a NAC of 52 decibels [interior] and outdoor areas such as residential yards as Activity Category B with a NAC of 67 decibels [exterior] (Revised General Plan, Chapter 5, Aural Environment, Text). The Fly Neighborly Program addresses noise abatement operations by establishing general guidelines, such as, maintaining an altitude as high as possible, observing low-noise speed and descent recommendations, and using steep takeoff and descent profiles. The Fly Neighborly Guide provides to be compatible with the generally accepted criterion of 65 db(a) max for flyover of noise-sensitive areas, light/small helicopters should fly at altitudes no less than 1,000 feet. Analysis Staff recommends the applicant commit to adherence to the Fly Neighborly Program as well as noise levels of no more than 65 db(a) at the property boundaries. Staff further recommends committing to no more than one takeoff and landing per day as a condition of approval. A fuel tank will be located adjacent to the proposed hangar facility. Please note if the applicant seeks to have a fuel tank on the property 660 gallons or greater, the Aboveground Storage Tank (AST) will need to be registered with the Virginia Department of Environmental Quality. ZONING MODIFICATIONS The applicant is seeking a Minor Special Exception to modify the following Zoning Ordinance performance standards for an airport/landing strip. Scope of Aviation Operations: The applicant seeks to increase the hours for takeoffs and landings from between the hours of 6:00 a.m. to 6:00 p.m. to between the hours of 6:00 a.m. to 10:00 p.m. The justification for the modification is that the modification is reasonable given the heliport is for personal use only and will be used by the applicant to access his business and other farm properties outside of Loudoun County. Staff notes the Zoning Ordinance performance standards call for the use to be for private aviation only and therefore, do not believe the justification is warranted based on the reasoning provided. A-6

7 SPEX & SPMI , Egypt Farm Lot 6 Heliport Community Planning Referral August 18, 2014 Page 4 Analysis Staff requests the applicant provide additional justification for the increase in operations to 10:00 p.m. Site Size: The applicant seeks to reduce the site size from a minimum of 80 acres to acres. The justification for the modification is that the parcel is a part of the larger 540 acre Egypt Farm. As stated above, the subject of the application is not the entire farm, but rather the 58.6 acre Lot 6. While the entire farm is under one ownership at this time, the lots surrounding the subject property could be sold to separate owners in the future. However, at a site visit on August 13, 2014, the applicant stated they intended to reconfigure the lots to create an 80 acre parcel for the heliport. If the applicant creates an 80 acre parcel for the heliport, this modification will no longer be needed. Dimensional Standards: The applicant seeks to modify the dimensional standards, which call for the runway or land strip to be a minimum of 650 feet from all lot lines. The heliport is proposed approximately 354 feet from Lot 3 of Egypt Farm and 534 feet from Lot 7 of Egypt Farm. While the applicant owns these lots at this time, since they are separate parcels they may be sold in the future under separate ownership. At the August 13, 2014 site visit, the applicant stated they would place a covenant on the adjacent lots restricting the development of a residential structure within a 650 foot radius of the heliport. If the applicant commits to restricting residential development within 650 feet of the heliport, the intent of this regulation would be met. Runway Buffer Area: The regulations require a minimum buffer area equal to a 0.25 mile radius extending from the end of all runways or landing strips. The applicant seeks to eliminate this requirement as they will be using an existing concrete pad, which is located near existing farm structures, including the former barn to be converted to the hangar an unoccupied dwelling (the former farmhouse) for takeoffs and landings. Additionally, the applicant provides helicopters use vertical takeoffs and landings and do not require the buffer area. Staff has no issue with the elimination of the buffer requirement provided the former farmhouse is not to be used as a permanent residential structure. RECOMMENDATIONS Staff has no issue with the proposed Special Exception and Minor Special Exception applications provided the commitments as referenced above are included with conditions of approval. Staff cannot support the request to increase the flight times to 10:00 p.m. as adequate justification for the increase has not been provided. Staff recommends the applicant consider including the entire 540 acre Egypt Farm property as part of the Special Exception application. Staff is available to meet with the applicant to discuss these issues. cc: Julie Pastor, FAICP, Planning and Zoning Director Cynthia Keegan, AICP, Program Manager via A-7

8 COUNTY OF LOUDOUN DEPARTMENT OF PLANNING AND ZONING ZONING ADMINISTRATION REFERRAL DATE: November 14, 2014 TO: CC: FROM: APPLICATION: Marchant Schneider, Project Manager Michelle Lohr, Deputy Zoning Administrator Mark A. Depo, Senior Planner, Zoning Administration SPEX SPMI , Egypt Farm Lot 6 Heliport TAX MAP/PARCEL: /56////////40A (the Property ) PLAN SUBMISSION: 2 nd Submission Referral Comments ZONING COMMENTS SPECIAL EXCEPTION PLAT 1. Section 5-633(B), of the Zoning Ordinance, requires a minimum lot size of 80 acres and the Property (Lot 6 of Egypt Farm) is acres. Per the Statement of Justification dated October 10, 2014, the applicant is proposing a boundary line adjustment (BLAD) between the Property and Lot 5 of Egypt Farm, which the applicant owns, to achieve the 80 acre minimum. If SPEX is approved, it should be conditioned upon 1) the BLAD being submitted and recorded resulting in Lot 6 revised being a minimum of 80 and 2) a revised SPEX/SPMI plan must be submitted and approved that reflects the final configuration of Lot 6 revised acres prior to establishing the heliport use. 2. Section 5-633(D)(1)(a) requires the helipad to be set back 650 feet from all lot lines, however, the heliport is located less than 650 from Lots 2, 3, and 7 of Egypt Farm. Per the Statement of Justification dated October 10, 2014, the applicant is proposing to place a restrictive covenant on the portions of Lots 2, 3, and 7 of Egypt Farm, which the applicant owns, preventing any habitable residential structure from locating within 650 of the edge of the helipad. Section 5-633(D)(1)(a) requires a 650 feet setback to a property line and not a residential structure. To be consistent with the actual distance a residential structure could be located to the helipad, both the helipad setback of 650 feet and the AR-1 minimum yard of 25 feet should be combined to provide a 675 feet restrictive covenant. 3. If the applicant accepts the 675 feet restrictive covenant, as described in comment 2 above, Attachment 1b A-8

9 SPMI , Egypt Farm Lot 6 Heliport DPZ, Zoning Administration 2 nd Referral November 14, 2014 Page 2 the restrictive covenant (buffer) on Sheets 2 and 3 and the Statement of Justification should be amended. 4. Provide a note on Sheets 2 and 3 that explain the purpose of the depicted buffer area. STATEMENT OF JUSTIFICATION 5. The Statement of Justification must be revised throughout the document to make a clear distinction between Lot 6 of Egypt Farm and the remaining portions of Egypt Farm. A redlined version of the Statement of Justification is attached that attempts to clarify this issue. 6. Zoning Modification 5-633(A)(1)(d). Include the condition of limiting the frequency of trips per week. A redlined version of the Statement of Justification is attached that attempts to clarify this issue. 7. Zoning Modification 5-633(A)(1)(d). Please clarify the period of time the one flight between the hours of 6 p.m. and 10 p.m. is occurring. Per week? Per day? A redlined version of the Statement of Justification is attached that attempts to clarify this issue. ATTACHMENT 1. Redlined version of the Statement of Justification. A-9

10 COUNTY OF LOUDOUN DEPARTMENT OF PLANNING AND ZONING ZONING ADMINISTRATION REFERRAL DATE: August 26, 2014 TO: CC: FROM: APPLICATION: Marchant Schneider, Project Manager Michelle Lohr, Deputy Zoning Administrator Mark A. Depo, Senior Planner, Zoning Administration SPEX SPMI , Egypt Farm Lot 6 Heliport TAX MAP/PARCEL: /56////////40A (the Property ) PLAN SUBMISSION: 1 st Submission Referral Comments The above referenced property (hereinafter referred to as the Property ) is zoned Agricultural Rural-1 (AR-1) under the Revised 1993 Loudoun County Zoning Ordinance (hereinafter referred to as the Zoning Ordinance ). The Property is located within and is subject to the regulations of the Floodplain Overlay District (Section ) and contains moderate to very steep slopes (Section ). The above referenced application has been submitted to establish a Heliport (Airport/landing strip) and modify the Additional Regulations of Section for an Airport/landing strip at the Property. Pursuant to Section 2-102, of the Zoning Ordinance, an Airport/landing strip is a special exception use in the AR-1 zoning district and is subject to the Additional Regulations for Specific Uses of Section 5-633, of the Zoning Ordinance. ZONING COMMENTS SPECIAL EXCEPTION PLAT 1. The Property is acres. Section 5-633(B) requires a minimum lot size of 80 acres. Staff understands that the applicant is requesting a modification to this standard. 2. Depict and denote the closest distances from the proposed helipad and hanger from Lot 5 on Sheet 2 of 2 of the Egypt Farm Lot 6 Helipad SPEX Plat. Currently, the plan depicts the proposed hanger and helipad set back feet and , respectively, from Lot 5. However, it appears that the closest distance to Lot 5 from the proposed helipad and hanger is approximately 530 feet and 575 feet, respectively. Please clarify and amend the SPEX plat, accordingly.[section 5-633(D)(1)(a)] 3. The helipad is located feet from Lot 3; approximately 530 feet from Lot 5; and A-10

11 SPMI , Egypt Farm Lot 6 Heliport DPZ, Zoning Administration 1 st Referral August 26, 2014 Page 2 feet from Lot 7. Section 5-633(D)(1)(a) requires the helipad to be set back 650 feet from all lot lines. Staff understands that the applicant is requesting a modification to this standard. 4. Be advised, the following requirements will be required and confirmed during the site plan review: a. The parking area for the helipad use shall comply with the landscaping and screening standards of Section 5-653(B). [Section 5-633(E)(2)] b. Parking shall be provided as required by Section and shall be constructed of a dust free surface as provided by the Facility Standards Manual. [Section 5-633(H)(1) and (2)] c. The proposed fuel tank shall be screened and landscaped consistent with the standards of Section 5-653(C). [Section (E)(3)] d. The helipad use shall comply with the road access standards of Section Section 5-633(F)] e. The helipad use shall comply with the exterior lighting standards of Section 5-652(A). [5-633(G)] 5. Are any storage yards proposed for the helipad use? If, so please depict and denote on the plan. [Section (C)(2)] 6. Is there any exterior lighting proposed for the helipad use? If, so please depict and denote on the plan. [5-633(G)] 7. Depict and denote the proposed parking area for the helipad use [Section 5-633(H)(1)] STATEMENT OF JUSTIFICATION 8. Introduction The Introduction refers to the Property as being part of a 540 acre farm. However, the helipad use Special Exception (SPEX) request is for a acres parcel. Update the Statement of Justification to remove references to the 540 acre farm and address the Property proposed for the heliport use. The several lots surrounding the Property are part of the Egypt Farm subdivision which may be sold and developed separately and are not subject to this SPEX request and therefore cannot be used to justify SPEX/Modification requests. 9. Project Proposal a. Remove the references to the 540 acre farm. See note 8 above. b. This Section states that the residence will be placed on the farm. Does the farm refer to the SPEX application property? If so, please state such. If not, please clarify further as to the location of the residence. c. This Section states that the heliport will be used 2-3 times per week, however, other sections of the statement of justification states the heliport will be used daily. Please clarify and provide a consistent range of use of the heliport throughout the Statement of Justification. d. This Section states that there will be no grading or other land disturbance. However, there does not appear to be an existing paved area that extends from the helipad to the hanger and a defined parking area. Is the helicopter to be towed from the helipad to the hanger over the existing unpaved/ungraded surface or is a paved surfaced proposed? A-11

12 SPMI , Egypt Farm Lot 6 Heliport DPZ, Zoning Administration 1 st Referral August 26, 2014 Page 3 The use requires parking spaces which are not shown on the plan and may require grading. Also, when comparing the site from 2013 aerials there appears to have been significant grading causing the loss of several trees adjacent to the helipad. 10. Justification a. Please clarify and provide a consistent range of use of the heliport throughout the Statement of Justification. See comment 9.c. above. b. Remove the references to the 540 acre farm. See comment 8 above. c. Provide setbacks and perimeter information for the SPEX application property and not of the 540 acre farm. d. This Section states that the helicopter can maintain a height of 500 feet until it reaches the perimeter of the Egypt Farm boundary. Is the Egypt Farm boundary the SPEX application property boundary? The Statement of Justification needs to refer to the SPEX application property and not of property that is not subject to the application (See comment 8 above). 11. Transportation a. Clarify the location of the residence on the farm. See notes 8 and 9.b. above. b. Please clarify and provide a consistent range of use of the heliport throughout the Statement of Justification. See comment 9.c. above. 12. Zoning Modification of Section Pursuant to Section a. The applicant states that the regulations of Section are designed to mitigate an airport for fixed-wing aircraft. However, the SPEX application has been submitted to establish an Airport/landing strip. Article 8 of the Zoning Ordinance defines an Airport/landing strip as, Any area designed and used for the takeoff and landing of small private aircraft, having no more than one air strip. Furthermore, Article 8 of the Zoning Ordinance defines an Airport (Including Air Park, Flight Strip, Airfield and Heliport) as A place where aircraft may take off or land, discharge or receive cargoes and/or passengers, be repaired, take on fuel, and be stored. b. Section 5-633(A)(1)(d). Staff does not support the request to extend prohibited hours of operation from 6:00 p.m. 6:00 a.m. to 10:00 p.m. 6:00 a.m. The existing regulations should give adequate time for the applicant to leave work and return home by the 6:00 p.m. timeframe. The applicant should provide additional justification why a 10:00 p.m. time is required and clarify whether there is a weekday and weekend preference or if the requested modification is for the entire week. Also, please clarify and provide a consistent range of use of the heliport throughout the Statement of Justification (See comment 9.c. above). c. Section 5-633(B). Staff does not support the reduction in minimum lot size from the required 80 acres to acres a reduction of acres or 27%. Also, the Statement of Justification needs to reference the SPEX application property (See note 8 above). If the applicant owns the surrounding properties, the applicant could adjust the property boundaries to achieve the required acreage. A-12

13 SPMI , Egypt Farm Lot 6 Heliport DPZ, Zoning Administration 1 st Referral August 26, 2014 Page 4 d. Section 5-633(D)(1)(d). Staff does not support the reduction in setback from the required 650 feet. The setback is intended to protect the health, safety, and welfare of the adjacent properties and surrounding community. If the applicant owns the surrounding properties, the applicant could adjust the property boundaries to achieve the required setbacks. Include the distance to Lot 5 in the Statement of Justification (See comment 3, above) ISSUES FOR CONSIDERATION In considering a minor special exception or special exception application, the Issues of Consideration in Section , of the Zoning Ordinance, shall be given reasonable consideration. The applicant shall address all the following in its statement of justification and plat unless not applicable, in addition to any other standards imposed by this Ordinance. Zoning Staff provided the following comments regarding the Issues of Consideration: Issues For Consideration (1) Whether the proposed minor special exception or special exception is consistent with the Comprehensive Plan. (2) Whether the level and impact of any noise, light, glare, odor or other emissions generated by the proposed use will negatively impact surrounding uses. (3) Whether the proposed use is compatible with other existing or proposed uses in the neighborhood, and on adjacent parcels. Zoning Staff Comments The applicant needs to reference the primary use of the 58 acres requesting the SPEX use and not the 540 acres that includes several lots surrounding the Property that are part of the Egypt Farm subdivision which may be sold and developed and are not subject to this SPEX request. Zoning Staff defers to Community Planning regarding Comprehensive Plan considerations. The applicant needs to reference the 58 acres requesting the SPEX use and not the 540 acres that includes several lots surrounding the Property that are part of the Egypt Farm subdivision which may be sold and developed and are not subject to this SPEX request. The applicant needs to explain how light and glare from the helicopter and helipad and emissions from the helicopter may or may not impact surrounding uses. The SPEX application must meet the Zoning Ordinance performance standards requirements for light (Sections 5-652(A) and ). The applicant needs to reference the 58 acres requesting the SPEX use and not the 540 acres that includes several lots surrounding the Property that are part of the Egypt Farm subdivision which may be sold and developed and are not subject to this SPEX request. The A-13

14 SPMI , Egypt Farm Lot 6 Heliport DPZ, Zoning Administration 1 st Referral August 26, 2014 Page 5 (4) Whether the proposed special exception or minor special exception adequately protects and mitigates impacts on the environmental or natural features including, but not limited to, wildlife habitat, vegetation, wetlands, water quality including groundwater), air quality, topographic, scenic, archaeological or historic features, and agricultural and forestal lands. (5) Whether the proposed special exception at the specified location will contribute to or promote the welfare or convenience of the public. (6) Whether the proposed special exception can be served adequately by public utilities and services, roads, pedestrian connections and other transportation services and, in rural areas, by adequate on-site utilities. applicant does not explain how the SPEX application addresses this issue. Zoning Staff defers to Community Planning regarding compatibility. The applicant does not explain how the SPEX application addresses this issue, particularly with wildlife habitat, vegetation, wetlands, water quality including groundwater), air quality, topographic, scenic, archaeological or historic features, and agricultural and forestal lands. Zoning Staff defers to Community Planning regarding environmental considerations. The applicant needs to reference the 58 acres requesting the SPEX use and not the 540 acres that includes several lots surrounding the Property that are part of the Egypt Farm subdivision which may be sold and developed and are not subject to this SPEX request. The applicant discusses how the use will not be inconvenient or be a nuisance to the public but does not address whether the use will contribute to or promote the welfare or convenience of the public. Zoning Staff defers to Community Planning, DTCI and/or VDOT regarding adequacy of public utilities and transportation services. A-14

15 County of Loudoun Department of Transportation and Capital Infrastructure MEMORANDUM DATE: November 17, 2014 TO: FROM: Marchant Schneider, Project Manager Department of Planning and Zoning Shweta Dixit, Senior Transportation Planner DTCI, Transportation Planning & Operations Division SUBJECT: SPEX & SPMI Egypt Farms Lot 6 Heliport Second Referral Background This referral updates the status of comments noted in the Department of Transportation and Capital Infrastructure s (DTCI) first referral on these Special Exception (SPEX) and Minor Special Exception (SPMI) applications, dated August 18, The special exception application seeks approval of a personal heliport on Lot 6 of site, for anticipated use of personal travel to and from the property. The minor special exception application was to seek increase in the hours of takeoffs and landings from between 6:00 am to 6:00 pm to between the hours of 6:00 am to 10:00 pm and also seek a reduction in the site size from a minimum of 80 acres to acres. The application has now been amended to expand Lot 6 to the 80- acre minimum lot size for the airport/landing strip use and continue to include Lot 6 as the special exception property. The expanded Lot 6 parcel is a part of the larger 540-acre Egypt Farm located north of Snickersville Turnpike (VA Route 734) between Shelburne Glebe Road (VA Route 729) and Watermill Road (VA Route 731). Access to the site is proposed via existing Egypt Farm Lane. The anticipated use of this heliport for personal travel to and from this property is about two to three times per week. In its consideration of the revised application, the Department of Transportation and Capital Infrastructure (DTCI) reviewed material received from the Department of Planning and Zoning on October 20, 2014, including (1) information sheet prepared by the Department of Planning, dated October 20, 2014; (2) a letter responding to first referral comments, dated October 10, 2014 (3) statement of justification, dated July 7, 2014 and revised through October 10, 2014; (4) a Traffic Statement (TIS), prepared by Walsh Colucci Lubeley Emrich & Walsh PC, dated May 30, 2014; and (5) a Special Exception Plat (plan set) prepared by Marsh & Legge Land Surveyors, dated June 6, 2014 and revised through October 8, Attachment 1c A-15

16 SPEX & SPMI Egypt Farms Lot 6 Heliport DTCI Second Referral Comments November 17, 2014 Page 2 Status of Transportation Comments and Recommendations Staff comments from the first DTCI referral (August 18, 2014), as well as the Applicant s responses from it October 10, 2014 response letter, and comment status are provided below. 1. Initial Staff Comment (First Referral, August 18, 2014): The helipad will generate no additional traffic beyond the traffic resulting from permitted residential and agricultural uses on the property. No transportation improvements are requested with these applications. Applicant s Response (October 10, 2014): The applicant concurs with the DTCI assessment. Comment Status: Comment addressed. 2. Initial Staff Comment (First Referral, August 18, 2014): Per the 2010 CTP, (Chapter 2, Private Street Policy #2) DTCI notes that upkeep and maintenance of private streets such as Egypt Farm Lane is not a County or a State responsibility. Applicant s Response (October 10, 2014): The Applicant acknowledges that maintenance of Egypt Farm Lane is not a county or state responsibility. Comment Status: Comment addressed. Conclusion DTCI has no objection to the approval of these applications. cc: Kathleen Leidich, AICP, Assistant Director, DTCI Lou Mosurak, AICP, Senior Coordinator, DTCI A-16

17 County of Loudoun Department of Transportation and Capital Infrastructure MEMORANDUM DATE: August 18, 2014 TO: FROM: Marchant Schneider, Project Manager Department of Planning and Zoning Shweta Dixit, Senior Transportation Planner DTCI, Transportation Planning & Operations Division SUBJECT: SPEX , SPMI Egypt Farm Lot 6 Heliport First Referral Background These Special Exception (SPEX) and Minor Special Exception (SPMI) applications seek approval of a personal heliport on Lot 6 of the Egypt Farm tract with modifications of Revised 1993 Zoning Ordinance Section in the AR-1 zoning district. The 58-acre parcel is a part of the larger 540-acre Egypt Farm located north of Snickersville Turnpike (VA Route 734) between Shelburne Glebe Road (VA Route 729) and Watermill Road (VA Route 731). Access to the site is proposed via existing Egypt Farm Lane. The anticipated use of this heliport is for personal travel to and from this property about two to three times per week. An existing 6,000 square-foot concrete pad is proposed to be used as the helicopter landing pad and an existing 6,450 square foot barn is proposed to be converted to a hangar for the helicopter. A vicinity map is provided as Attachment 1. In its consideration of these applications, the Department of Transportation and Capital Infrastructure (DTCI) reviewed materials received from the Department of Planning and Zoning on July 17, 2014, including (1) information sheet, dated July 17, 2014; (2) a statement of justification, dated July 7, 2014; (3) a Traffic Statement (TIS), prepared by Walsh Colucci Lubeley Emrich & Walsh PC, dated May 30, 2014; and (4) a Special Exception Plat (plan set) prepared by Marsh & Legge Land Surveyors, dated June 6, Compliance with Countywide Transportation Plan The Egypt Farm heliport site is located within the Rural Policy Area. The transportation network is specifically governed by the policies of the Countywide Transportation Plan (2010 CTP) and the Bicycle & Pedestrian Mobility Master Plan (2003 Bike & Ped Plan). A-17

18 SPEX Egypt Farm Lot 6 Heliport DTCI First Referral Comments August 18, 2014 Page 2 DTCI s assessment of the transportation network is based on review of existing, planned and programmed transportation facilities, review of the Applicant s traffic statement and applicable County policies. Existing, Planned and Programmed Transportation Facilities The proposed Egypt Farm heliport is located north of Snickersville Turnpike (VA Route 734) between Shelburne Glebe Road (VA Route 729) on the east and Watermill Road (VA Route 731) on the west. Roadways serving the site are described below. Descriptions for planned conditions of CTP roads are taken from Appendix 1 of the 2010 CTP. Snickersville Turnpike (VA Route 734) runs between John Mosby Highway (US Route 50) and Harry Byrd Highway (VA Route 7) and is a two-lane undivided major collector road is built to its ultimate condition per the 2010 CTP. Per Chapter 7 of the 2010 CTP, Snickersville Turnpike is classified as a Virginia Byway. According to 2012 VDOT traffic counts, Snickersville Turnpike carries about 1,400 vehicles per day in the vicinity of Watermill Road. Shelburne Glebe Road (VA Route 729) is a local secondary road on the eastern side of the Egypt Farm property and connects to North Fork Road (VA Route 728) on the north. Per 2012 VDOT published traffic data, Shelburne Glebe Road carries approximately 150 vehicles per day south of North Fork Road. The southernmost mile segment of Shelburne Glebe Road (north of Snickersville Turnpike) appeared to serve no public necessity and was discontinued as a part of the VDOT Secondary System for maintenance in Watermill Road (VA Route 731) is a local secondary road on the western side of the Egypt Farm property and runs between Snickersville Turnpike to the south and North Fork Road to the north. Watermill Road is designated as a Virginia Byway. Per 2012 VDOT published traffic data, Watermill Road carries approximately 590 vehicles per day. Egypt Farm Lane is a private roadway on the subject property which provides internal access to the property and connects to Shelburne Glebe Road on east and Watermill Road on the west. Trip Generation from Proposed Use The Applicant s traffic statement, provided as Attachment 2, indicates that the property owner plans to use a private helicopter to travel to and from this property approximately 2-3 times per week. The helipad will generate no additional vehicular traffic beyond the traffic resulting from permitted residential and agricultural uses on the property. A-18

19 Transportation Comments SPEX Egypt Farm Lot 6 Heliport DTCI First Referral Comments August 18, 2014 Page 3 DTCI staff has reviewed the Applicant s submitted materials and has the following comments: 1. The helipad will generate no additional traffic beyond the traffic resulting from permitted residential and agricultural uses on the property. No transportation improvements are requested with these applications. 2. Per the 2010 CTP, (Chapter 2, Private Street Policy #2) DTCI notes that upkeep and maintenance of private streets such as Egypt Farm Lane is not a County or a State responsibility. Conclusion DTCI has no objection to the approval of these applications. ATTACHMENTS 1. Site Vicinity Map 2. Applicant s Traffic Statement (May 30, 2014) cc: Kathleen Leidich, AICP, Assistant Director, DTCI Lou Mosurak, AICP, Senior Coordinator, DTCI A-19

20 ATTACHMENT 1 A-20

21 A-21

22 ATTACHMENT 2 A-22

23 A-23

24 A-24

25 Attachment 1d A-25

26 Attachment 1e A-26

27 I. Introduction Egypt Farm Lot 6 Special Exception Application for Airport/Landing Strip Minor Special Exception Application for Modifications of Section for an Airport/Landing Strip Statement of Justification PIN # November 20, 2014 Egypt Farm LLC is filing a special exception application for a heliport on an existing acre parcel known as Lot 6 of Egypt Farm pursuant to Table of the Loudoun County Zoning Ordinance. The 58-acre parcel is part of a 540 acre farm located north of Snickersville Turnpike between Shelburne Glebe Road and Watermill Road owned by the applicant. The property is zoned AR-1 (Agricultural Rural) and is located within the Blue Ridge election district. II. Project Proposal The Egypt Farm subdivision consists of 540 acres divided into seven parcels (Lots 1-7). The owner of Egypt Farm is requesting to designate a helicopter landing pad on Lot 6 of Egypt Farm. The property owner also leases to farm an additional 350 acres adjacent to the 540 acre landholding, all of which are active farming/agricultural operations. The property owner, who is a licensed helicopter pilot, plans to construct his primary residence on Lot 7 of Egypt Farm and would like to use a private helicopter to travel between Lot 6 and other property located outside of Loudoun County and for travel for his business outside of Loudoun County. The owner will use an existing 60 by 100 (6,000 square feet total) concrete pad as the helicopter landing pad and the foundation of an existing 6,540 square foot barn to construct a hangar for the helicopter. Since the existing barn foundation and concrete pad will be used, only minimal land disturbance will occur to pave the apron area between the existing concrete pad and the barn foundation. III. Justification The heliport will be used strictly for personal use for the owner to travel to property outside of the county and for business outside of the county. The helipad is located on Lot 6 of Egypt Farm, which will be expanded to a minimum 80-acre parcel resulting from a boundary line adjustment with Lot 5 of Egypt Farm. The applicant owns and actively farms the remaining 460 acres of Egypt Farm as well as leases and farms the adjacent 350-acre Jubilation Farm. Lot 6 is a heavily wooded parcel, providing a natural screen and buffer for the helipad. While there has been some recent clearing on Lot 6 for agricultural purposes, the majority of the parcel remains wooded. {L DOC / 1 soj } Attachment 2 A-27

28 Egypt Farm Lot 6 Heliport Special Exception Application Statement of Justification November 20, 2014 Page 2 of 7 In order to mitigate the impacts of the take-offs and landings, the applicant will maintain an altitude of 500 feet above the ground, unless the helicopter is over the prescribed approach or departure path, which falls entirely over Egypt Farm and Jubilation Farm, land owned and leased by the applicant, respectively. In addition, the applicant will subscribe to and operate under the guidelines of the internationally recognized Helicopter Association International Fly Neighborly Program. And while the applicant anticipates less frequent trips on average, the applicant will agree to limit the frequency of use of the helipad to a maximum of ten take-offs and ten landings per week to accommodate those times when more frequent travel is anticipated. The applicant has received permission from the FAA to operate a heliport at this location. The approval memorandum from the FAA is attached to this statement. The implementation of the heliport facility will follow the safety guidelines and recommended practices of the FAA Heliport Design Advisory Circular C. IV. Transportation The Office of Transportation and Capital Infrastructure has accepted a traffic statement in lieu of a transportation analysis for the helipad proposed on Lot 6 of Egypt Farm. The application is for a proposed helipad for private and personal use only; therefore, no additional vehicle trips will result from the proposed use. The property owner plans to construct his primary residence on Lot 7 of Egypt Farm, for which any traffic will result from by-right residential and agricultural uses of the landholdings. The property owner plans to use a private helicopter to travel between this property, another farm located in Frederick County, Virginia and for business travel outside of Loudoun County. The heliport, therefore, will generate no additional road traffic, and arguably will reduce road traffic, since he will be accessing the property at times by helicopter rather than by car. Lot 6 accesses State Route 731, Watermill Road via the private Egypt Farm Lane. Egypt Farm is served by rural roads appropriate to the location and the residential and agricultural use of the 540-acre tract. V. Zoning Modification of Section pursuant to Section The airport/landing strip use requires special exception approval pursuant to Table for the AR-1 zoning district. The airport/landing strip use is also subject to the additional regulations contained in Section The applicant can comply with these regulations with the exception of the ones listed below for which a modification is being requested. The applicant is requesting minor special exception approval for the following modifications of the regulations contained in Section pursuant to Section of the Zoning Ordinance: Section Airport/Landing Strip. {L DOC / 1 soj } A-28

29 Egypt Farm Lot 6 Heliport Special Exception Application Statement of Justification November 20, 2014 Page 3 of 7 (A) Intensity/Character. (1) Scope of Aviation Operations. (d) Takeoffs or landings are prohibited between the hours of 6:00 p.m. and 6:00 a.m. The applicant requests that takeoffs and landings be prohibited between the hours of 10:00 p.m. and 6:00 a.m. The helicopter is for personal use only and is being used as an alternative to the private car for the applicant to access other farm properties outside of Loudoun County and for business travel outside of Loudoun County. For a personal use basis, operating between 6 a.m. and 10 p.m. is a reasonable time for an owner to be arriving home in the evening from out-of town travel. Business meetings can last until 6 p.m., creating the need to arrive home after 6 p.m. The applicant will agree to a condition to limit the frequency of use of the helipad to a maximum of ten take-offs and ten landings per week. The applicant will agree to a condition of no more than one take-off or one landing per day between the hours of 6 p.m. and 10 p.m., to minimize flights occurring after 6 p.m. (D)Location on Site/Dimensional Standards. (1) Aviation Structures, Storage Yards and Runway or Landing Strip. All aviation structures, storage yards, and the runway or landing strip, shall be set back from lot lines as follows: (d) Runway or landing strip: 650 feet minimum from all lot lines. The helipad and associated hangar are being located on an existing concrete pad and the foundation of an existing barn. The proposed helipad is located 354 feet from Lot 3 of Egypt Farm and 534 feet from Lot 7 of Egypt Farm. The applicant owns both of these lots. The applicant will agree to a condition to place restrictive covenants on the adjoining parcels of Egypt Farm preventing any habitable residential structure from locating within 675 feet of the edge of the helipad. Furthermore, the helipad is located 1,480 feet from the nearest property boundary of a parcel not owned by the applicant, which means property not owned by the applicant falls far outside of the 650 buffer requirement. Additionally, the FAA s Heliport Design Advisroy Circular C does not presecribe any setback requirements, but recommends a Heliport Protection Zone (Section 210) which is an area extending from the helipad under the approach and departure surface for 280 feet. This area should be free of any assembly of people, flammable materials and occupied structures to the extent possible. This recommendation is met entirely. (E)Landscaping/Buffering/Screening. (1) Runway Buffer Area. A buffer area shall be provided extending from the end of all runways or landing strips. The size of the buffer shall encompass a minimum landing area equal to a one-quarter mile radius measured from the {L DOC / 1 soj } A-29

30 Egypt Farm Lot 6 Heliport Special Exception Application Statement of Justification November 20, 2014 Page 4 of 7 edge of the end of every runway. No uses shall be allowed within this runway buffer area. The heliport proposes to use an existing 6,000 square foot concrete pad for vertical takeoffs and landings. This pad is located near an existing cluster of farm buildings including the former barn to be converted to the hangar, an unoccupied dwelling (the former farmhouse), a garage used for farm equipment storage, a silo and several sheds. These buildings are not located in the FAA recommended Heliport Protection Zone. The FAA s Heliport Design Advisory Circular C recommends a Heliport Protection Zone (Section 210) which is an area extending from the helipad under the approach and departure surface for 280 feet. This area should be free of any assembly of people, flammable materials and occupied structures to the extent possible. This recommendation is met entirely. The advisory circular also recommends an 8:1 VFR approach and departure surface that begins at the heliport surface and extends horizontally for 4,000 feet to a vertical height of 500 feet above ground level. No obstacles may penetrate this surface. The proposed helipad site easily meets this requirement in multiple directions, thus exceeding the requirement of the runway buffer area. An analysis of the issues for consideration in reviewing proposed special exception use contained in Section of the Zoning Ordinance is included in Section VII, below VI. Special Exception Issues for Consideration Section of the Zoning Ordinance contains evaluation criteria for approval of SPEX applications and, in considering this application, the following enumerated factors shall be given reasonable consideration. The Zoning Ordinance specifies that an applicant is to address each factor in its statement of justification (unless any such criteria are deemed inapplicable to the application). (1) Whether the proposed special exception is consistent with the Comprehensive Plan. Lot 6 of Egypt Farm is located in the Rural Policy Area and is designated for agricultural use in the Revised General Plan. The 80-acre parcel on which the helipad will be located will continue to be used for agricultural purposes along with the remainder of the 540- acres of Egypt Farm. The heliport use will not interfere with the agricultural use of the property. The noise generated by the helicopter is similar to noise generated by farm equipment. (2) Whether the level and impact of any noise, light, glare, odor or other emissions generated by the proposed use will negatively impacts surrounding uses. {L DOC / 1 soj } A-30

31 Egypt Farm Lot 6 Heliport Special Exception Application Statement of Justification November 20, 2014 Page 5 of 7 The primary impact will be the noise generated by the helicopter. Lot 6 of Egypt Farm on which the heliport is located provides the necessary buffer to adjacent property owners from the noise impacts of the helicopter use. Additionally, the owner can remain at an altitude of 500 feet or higher, unless the helicopter is over the prescribed approach or departure path, which falls entirely over Egypt Farm and Jubilation Farm, land owned and leased, respectively, by the applicant. The helicopter noise is similar to the noise generated by farm equipment, which is a permitted use on Lot 6. The applicant s helicopter is an Airbus EC-130 B4 Eco-copter and is the helicopter of choice for helicopter tour operators in the Grand Canyon, Hawaii and New York City, where the preservation of natural quiet is an operational mandate. The name Eco-copter owes to its Quiet Technology in the form of a variable speed rotor system and advanced technology fenetron tail which makes the quietest helicopter in its class by a significant margin. Furthermore, the helicopter s Turbomeca engine is the most fuel efficient and clean burning engine produced today. The helicopter is equipped with LED position lights and a standard landing light that is roughly equivalent to an automobile headlight used only for its short landing and take-off phase of flight. Due to the location and orientation of flight paths the light emitted by the helicopter will likely go unobserved by people on the ground and will never be more disruptive than would be a passing car or motorcycle. (3) Whether the proposed use is compatible with other existing or proposed uses in the neighborhood and on adjacent parcels The application is mitigating its impacts to adjacent parcels by its location on the 80 acre parcel, which includes an extensive wooded buffer along the perimeter of the property. There will be no visual impacts to the adjacent parcels. The applicant can mitigate the noise effects by not flying below a minimum flying altitude of 500 feet unless the helicopter is over the prescribed approach or departure path, which falls entirely over Egypt Farm and Jubilation Farm, land owned and leased, respectively, by the applicant. (4) Whether the proposed special exception adequately protects and mitigates impacts on the environmental or natural features including, but not limited to, wildlife habitat, vegetation, wetlands, water quality including groundwater, air quality, topographic, scenic, archaeological or historic features, and agricultural and forestall lands. This use is being implemented with no impacts to the environmental and natural features, since it will be making use of existing structures on Lot 6 of Egypt Farm and {L DOC / 1 soj } A-31

32 Egypt Farm Lot 6 Heliport Special Exception Application Statement of Justification November 20, 2014 Page 6 of 7 will be doing only minimal disturbance to the land in order to pave the apron area between the existing concrete pad the barn floor to implement the use. (5) Whether the proposed special exception at the specified location will contribute to or promote the welfare or convenience of the public. The proposed use is to provide a facility for private use by the landowner. The use is being mitigated in a fashion that will not inconvenience the public. The use is not visible from public roads and from adjacent properties. The use is well-buffered within the 80 acre parcel. Additionally, the applicant will fly the aircraft in a manner that will result in the noise effects being less than those of helicopters that are currently permitted to fly over the area by right. This will be achieved by flying approaches and departures over the densely wooded Beaver Dam Creek valley and maintaining a minimum altitude of 500 unless the helicopter is over the prescribed approach or departure path, which falls entirely over Egypt Farm and Jubilation Farm, land owned and leased, respectively, by the applicant. Furthermore, the applicant will make the facility available to state, municipal and other public service agencies for the purposes of helicopter medical evacuation, lawenforcement and firefighting, which will provide a valuable public service in a rural area. Located centrally between Purcellville and Aldie along Route 734, this facility is ideally suited for helicopter positioning to provide such services. (6) Whether the proposed special exception can be served adequately by public utilities and services, roads, pedestrian connections and other transportation services and, in rural areas, by adequate on-site utilities. The heliport is for private use on a farm property that is served by existing on-site wells and drainfields. The heliport will enable the property owner to access the farm without using the surrounding rural road network. VII. Conclusion Since an airport/landing strip or heliport can be permitted in the AR-1 district, this application presents the circumstances where such a use can operate compatibly in a rural setting. The private use means infrequent use of the heliport as compared with a commercial facility. The helipad will be located on an 80-acre parcel that is part of a 540-acre farm owned by the applicant. The 80-acre parcel is well-buffered from adjacent property with substantial mature wooded buffers. The applicant will operate the aircraft to maintain the noise impacts of flying beneath a minimum altitude of 500 feet unless the helicopter is over the prescribed approach or departure path, which falls entirely over Egypt Farm and Jubilation Farm, land owned and leased, respectively, the applicant, and will limit the frequency of trips each week. The use is creating virtually no impact on the land, since existing structures are being used for the helipad and hangar. For these reasons, the applicant respectfully requests a {L DOC / 1 soj } A-32

33 Egypt Farm Lot 6 Heliport Special Exception Application Statement of Justification November 20, 2014 Page 7 of 7 favorable recommendation and approval of the proposed special exception application for the heliport and the minor special exception application for the modifications to Zoning Ordinance Section {L DOC / 1 soj } A-33

34 Attachment 3 A-34

35 A-35

36 A-36

37 A-37

38 Christine Gleckner, AICP Land Use Planner (571) October 10, 2014 Via Hand Delivery Marchant Schneider, Senior Planner Loudoun County Department of Planning 1 Harrison Street, S.E., 3rd Floor, Leesburg, Virginia Re: SPEX SPMI , Egypt Farm Lot 6 Heliport Dear Mr. Schneider: This letter addresses and provides you with a written response to the referral agency comments in the above referenced application. For your convenience, each of the staff comments are stated below and the Applicant's responses follow in bold italics. LOUDOUN COUNTY DEPARTMENT OF PLANNING & ZONING COMMUNITY PLANNING (MARIE GENOVESE, 8/18/204) LAND USE ANALYSIS The Rural Policy Area contains large and small farms, producing a variety of products, vineyards, bed and breakfast lodging, home-based and other businesses (Revised General Plan, Chapter 7, General Characteristics, Text). The land use pattern and design strategy seeks to retain the rural area as an essential asset of Loudoun County. As such, the County promotes rural residential and rural economy uses within the Rural Policy Area (Revised General Plan, Chapter 7, and Use Pattern and Design, Text). Development should promote opportunities for the expansion of rural economy uses, open space, farms, historic and natural areas, forests, the Green Infrastructure, while protecting the rural character of the landscape (Revised General Plan, Chapter 7, Land Use Pattern and Design Strategy Policies, Policy 8). While the proposed heliport will be for private use only, the mitigation of impacts can be compared to a non-agricultural commercial use. The Plan provides that these types of uses may be permitted by special exception in the Rural Policy Area if the use is compatible in scale and intensity; poses no threat to public health, safety, and welfare; and if the use helps to preserve farmland and open space and continue agricultural operations (Revised General Plan, Chapter 7, Rural Economy Policies, Policy 14). The Statement of Justification provides the proposed heliport is {L DOCX / 1 Responses to Referral Comments } A-38