HomeMy WebLinkAboutZMA201900003 Review Comments Zoning Map Amendment 2019-05-06COUNTY OF ALBEMARLE
Department of Community Development
401 McIntire Road, North Wing
Charlottesville, Virginia 22902-4596
Phone (434) 296-5832 Fax (434) 972-4176
May 3, 2019
Kelsey Schlein
Shimp Engineering
912 E. High St.
Charlottesville, VA 22903
kelseykshimp-en ig neerin com / 434-227-5140
RE: ZMA201900003 Royal Fern
Dear Ms. Schlein:
Staff has reviewed your initial submittal for the zoning map amendment, ZMA201900003, Royal Fern. We have a number
of questions and comments which we believe should be addressed before we can recommend favorably on your ZMA
request. We would be glad to meet with you to discuss these issues.
Review comments are provided below, organized by Department, Division, or agency. Our comments are provided below:
Planning — General Application Comments
1. Revise the project materials with the application number provided for this project.
2. This property is potentially within the Monticello Viewshed. It is recommended that you contact Liz Russell at
Monticello to discuss this proposed project and any concerns that Monticello may have.
3. TMP 76-54 falls within a rezoning ZMA199400020 that was approved in 1995. Please provide information in the
narrative as to whether the conditions of this rezoning affect the proposed Royal Fern project.
4. A portion of this property — the eastern -most parts of TMPs 46A and 54 — falls within a state dam break
inundation zone. Revise the project narrative to indicate this situation, and show the outline of this area on the
concept plans so that staff may have a better idea of where the proposed development is in relation to the
inundation zone.
5. As mentioned in the narrative, the COB — 5t' Street is designated as a "Center" in the comprehensive plan. Are
there any proposed connections, such as bike or pedestrian, that will help to facilitate interaction across 5t' Street
between this designated center and the proposed Royal Fern development?
6. Provide an updated project narrative stating the proposed impacts to schools, as Cale Elementary School is
currently over -capacity and further residential development would increase this over -capacity issue. School
capacity was also brought up as a concern among the public at the community meeting.
Also, provide additional information on the impacts to the transportation infrastructure in this area. Transportation
and traffic issues were raised repeatedly during the community meeting held on April 18t' by neighbors and other
stakeholders and appear to be one of the major concerns among the public regarding this proposal.
7. There is a discrepancy in the acreage between the project narrative and the plat provided for the portion of
TMP76-46F included in this proposal. Please clarify this discrepancy.
8. Update the project narrative to provide information on how this proposal meets the intent of the PUD, Planned
Unit Development, district as stated in 20.1 of the Zoning Ordinance. As there are special exceptions requested
for size and the process of commercial development, it is important to establish why PUD would be the
appropriate proposed zoning district for this project. Commercial and industrial uses in PUDs are generally
supposed to serve the residential portions of the PUD, with additional activity only if the area is not adequately
served by those uses. Provide additional information on whether the 5' St. and Old Lynchburg area is already
served by such uses, or why the proposed commercial development is appropriate, especially with 5t' St. Station,
which includes many commercial uses, approximately a mile away.
9. Are there any proposed uses for which a Special Use Permit is required? If so, it is recommended that an
application for these SUPs be requested simultaneously with the ZMA application.
10. In the narrative, provide the gross and net density proposed, as well as on the application plan, as these are
required by 20.8.1.
11. According to 20.8.2, not less than 25% of the residential areas shall be in open space. Open space cannot be
within street right-of-way. Provide the calculations on the application plan and show where the proposed open
space will be. It does not appear that this requirement is currently met by what is shown on the application plan.
12. Recreational facilities are required for a PUD per 4.16 and 20.8.3. Identify where these recreational facilities are
proposed to be within the residential areas. For example, facilities such as tot lots are required for attached single-
family units.
13. The intent of commercial and service areas in PUDs (Seciont 20.9.1) are to be internally oriented, with external
vehicular access discouraged. Provide more information in the project narrative how this proposal meets the intent
of the commercial and service areas in PUDs.
14. A shopping center area is shown on the application plan. Provide additional information in the project narrative
regarding this proposed use (see 25.1 of the Zoning Ordinance), including the PD-SC district's intent to serve
areas not adequately provided by commercial and service facilities, as the 5t' Street Station development is
approximately a mile away from the proposed Royal Fern. In addition, keep in mind that shopping center areas
should have direct access to public streets that are adequate to accommodate the generated traffic. Provide more
information on how a shopping center use conforms with the intent of the PUD district to serve the community
and be internally oriented. In addition, provide more information explaining how a shopping center area conforms
with the Community Mixed Use land use designation for this area.
15. The application plan shows this development using Wahoo Way. Provide documentation where the applicant has
the right of access on Wahoo Way, as it is designated as a private street.
16. In the application plan on sheet 2, provide the following additional information for site details and data:
a. Include Magisterial District, and add Samuel Miller, as this proposal crosses the line between Scottsville
and Samuel Miller.
b. Add CO to the existing zoning
c. Add the zoning overlay districts
d. What is the proposed gross and net density of the development as a whole, and each block individually?
e. Indicate what the land use designation in the Comprehensive Plan is for this property, as well as what is
allowed within this land use designation.
f. Include what both the gross and net density would be, to clearly illustrate whether this proposal meets the
intent of the comprehensive plan land use designation.
g. Whether this property is within a water supply watershed.
17. Add a line to the Use Table on the Cover Sheet stating the proposed maximum density per block based on each
blocks acreage.
18. The Use Table states there is a proposed maximum number of units. Is there also a proposed minimum number of
units?
19. Clarify the proposed number of residential units. The table on sheet 2 and what is stated in the project narrative do
not appear to match.
20. A hotel is one of the proposed uses as shown on sheet 2. However, the intent of the Community Mixed Use land
use designation in the comprehensive plan is to serve community needs. Clarify how a hotel would be community
serving?
21. There is a maximum square footage of 80,000 proposed for a hotel/self-storage use in Block 4. In the Community
Mixed Use land use designation, no single -building footprint should be greater than 60,000 square feet. Would
such structures be in multiple buildings, less than 60,000 square feet? Or are such uses proposed to be in one large
building? Please clarify.
22. Is there a proposal to incorporate the exsting stormwater detention facility located within the VDOT right-of-way
in the corner of TMP76-46A along Old Lynchburg Road. This facility creates a uniquely shaped lot.
23. On sheet 6 of the application plan, open space is shown extending into the roadway. Required open space cannot
be within the streets. Please revise.
24. Include calculations of open space on sheet 2 with the site date. Open space/recreational areas must be at least
25% within PUDs.
25. Provide more information on the hatched areas labelled "no parking" shown on sheet 6 and sheet 8. Are these
areas supposed to be for buildings, to create a more pedestrian friendly area with relegated parking?
26. On sheet 7 and sheet 9, provide a greater color gradiant between sidewalks and multi -use paths. Looking at the
plan, they appear to be the same color and it is difficult to distinguish between the two.
27. On sheet 7, the proposed sidewalk is shown only along a portion of Country Green Road. Is it not proposed to be
extended for the full length of the parcel's frontage on this road?
28. Similarly, are there sidewalks or multi -use paths proposed for the parcel's frontage on Old Lynchburg Road and
Mountainwood Road? Traffic, transportation, and pedestrian safety and connections were topics repeatedly
brought up by community members at the community meeting. On sheet 9, are there sidewalks or multi -use paths
proposed for the frontage along Wahoo Way and Old Lynchburg Road southeast of the Region 10 building?
29. On sheet 7, there is an arrow pointing to an existing multi -use path. However, the color is different from that
shown in the legend. Please clarify.
30. Is there any open space/recreational areas proposed in Blocks 2-5 on sheet 8? Such areas are required for PUD
districts and multi-family/single-family attached housing.
31. Is the proposed street going through Blocks 2-5 going to be public or private? Are there sidewalks proposed along
this street?
32. Provide more information on the existing stormwater facility mentioned on sheet 8? Does the applicant have the
right to use such an existing stormwater facility?
33. Are there any proposed facilities to help access COB — 5` Street across the street, as that is a designated center in
the comprehensive plan?
34. Please clarify whether any proposed open space will be privately owned or dedicated to public use. See section
8.3 for requriements of planned developments.
35. Are pedestrian interconnections with adjacent properties proposed?
36. Is any on -street parking proposed?
37. Please be advised that site plans and VSMP plans, as well as subdivision plats, are required for townhouse -style,
attached single-family developments.
Comments regarding Special Exceptions
1. In reviewing this proposal, it appears that special exceptions for the requirements of 20.9.1 may also be needed
regarding the permitted gross floor area and the chronology of the issuance of building permits. See 20.9.3 and
20.9.4. Be aware of 20.9.2 and the perimeter of a PUD district, where the character of adjoining development
should be taken into account by the commission when reviewing such a proposal. There is more commercial
proposed than what is allowed; however, a special exception can be applied for.
2. With the shopping center area, a special exception to requirements found in section 25 may be needed depending
on the additional information provided in the narrative (refer to comment #14 above).
3. In the narrative for the special exception requested for the size of a PUD district, explain how granting this special
exception would conform with the vision laid out in the comprehensive plan for this area. The PUD would be
appropriate where the establishment of a new nucleus exists. Provide more information on how a new village or
nucleus would be appropriate in this area.
4. Please be advised that as review of this application continues, if the applicant chooses to resubmit rather than
going straight to the Planning Commission, it may be determined that additional special exceptions are required.
Comprehensive Plan
Initial comments on how your proposal generally relates to the Comprehensive Plan are provided below. Comments on
conformity with the Comprehensive Plan are provided to the Planning Commission and Board of Supervisors as part of
the staff report.
The Comprehensive Plan identifies Tax Map Parcel (TMP) 07600-00-00-046AO west of Old Lynchburg Road, and the
portion of TMP 07600-00-00-046FO included in this application, as Urban Density Residential land use. This
classification calls for primary uses to consist of residential uses at gross densities between 6.01-34 dwelling units/acre.
Secondary uses in this classification include supporting uses such as religious institutions, schools, commercial, office and
service uses. The proposed rezoning from R-2 Residential and CO, Commercial Office, to PUD, Planned Unit
Development, with residential as proposed on these parcels appears to be consistent with the Comprehensive Plan land
use recommendations. However, no density calculations were provided for the proposed Block 1. See graphic below from
page 33 of the Southern and Western Neighborhoods master plan.
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The Comprehensive Plan identifies Tax Map Parcel (TMP) 07600-00-00-046AO east of Old Lynchburg Road and TMP
07600-00-00-05400 as Community Mixed Use land use. This classification calls for primary uses to be residential (up to
34 units/acre), community scale retail, service and office uses, places of worship, schools, and public and institutional
uses. Secondary uses in this classification include auto -commercial sales and service with all service activities within a
building with a maximum foorprint of approximately 7,500 square feet. Office/R&D/flex/light industrial uses with
maximum single -building footprint of approximately 20,000 square feet. The proposed rezoning from R-2 Residential and
R-10 Residential, to PUD, Planned Unit Development, with residential and commercial uses as proposed on these parcels
is partially consistent with the Comprehensive Plan land use recommendations. However, no density calculations were
provided for the residential areas. In addition, the proposal for 80,000 square feet of hotel/self-storage is more than the
60,000 sq. ft. footprint recommended by the comprehensive plan. See graphic on next page from page 33 of the Southern
and Western Neighborhoods master plan.
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Neighborhood Model
Projects located within the Development Areas are typically reviewed for consistency with each of the Neighborhood
Model Principles found in the Comprehensive Plan. Comments are provided below on relevant aspects of the
Neighborhood Model. More detailed comments may be provided after more detailed plans are provided.
Pedestrian Orientation
This principle is partially met with the information that was provided. No sidewalks are
specifically shown on the block plan that was provided. In addition, there are no
sidewalks shown along most of the existing roads, although there are some segments
shown. Please indicate whether sidewalks will be provided internally. Are
interconnections with adjacent properties proposed? The concept plan demonstrates that
the project will be developed in a block format. What are the dimensions of the blocks,
as the comprehensive plan suggests about 200 feet for a block length?
The Comprehensive Plan supports pedestrian interconnections between adjacent
parcels, as well as sidewalks internal to a development.
Mixture of Uses
This principle appears to be met, with a mixture of potential residential types, as well as
commercial and service uses. However, the use table doesn't specify specific uses
outside of hotel/self-storage.
See Zoning comments for additional comments regarding the Use Table.
Neighborhood Centers
This principle is partially met. The conceptual plan provides blocks with commercial
and service uses that appear to act as a central area. This principle is important for a
PUD district, as it should be considered a mini -neighborhood providing services and
housing for the community. In addition, COB — 5'h St., across the street from this
development, is a designated "center" in the comprehensive plan. However, it is not
clear if there are any proposed connections or interaction between that area and the
proposed Royal Fern development.
Mixture of Housing Types
This principle is met, as the application plan proposes both townhouse units and multi -
and Affordability
family, with Block 3 being limited to townhouses only, and the potential for more
multi -family units in blocks 1 and 2.
Relegated Parking
This principle appears to be partially met. There are hatched areas shown on the
application plan designated as no parking. However, they do not cover the entire
frontage of those parcels. In addition, Blocks 3 and 4 are along the Entrance Corridor of
5'h Street, and should have relegated parking along the entire frontage. Such a situation
is not shown for a portion of Block 4. Parking areas in the other blocks are not currently
defined.
The conceptual plan does not identify any parking lots or parking spaces, and the
project narrative does not mention relegated parking or the orientation of the proposed
buildings in relation to the street frontage. Staff cannot verify that adequate area will
exist to provide parking in a relegated manner. Revise the plan to show where parking
will be provided. Consider the following:
• Parking should be relegated to the back or side of buildings.
• Front loaded garages on townhouse units should be the exception.
• Parking areas located adjacent to the street should be screened from
streets and should not be along the Entrance Corridors.
Interconnected Streets and
This principle is partially met. The conceptual plan shows a street connection between
Transportation Networks
Old Lynchburg Road and Wahoo Way. However, there are no additional streets shown,
including in Block 1. Is there any proposal to connect Mountainwood Road and Country
Green Road with a new internal street?
Multimodal Transportation
This principle is partially met. The conceptual plan shows sidewalks and multi -use
Opportunities
paths in some areas and along some road segments, but not along others.
It does not appear that bike lanes will be installed within the development, as they are
neither shown in the conceptual plan nor discussed in the project narrative.
Transit opportunities are also not shown. This property lies approximately a mile from
5t1i St. Station, across from the COB — 5'1i St., and north of the proposed Southwood
development, all important centers along this corridor. Is there any proposal for transit
stops or service in this area?
Parks, Recreational
This principle is partially met. Open space is shown. However, it extends into the street,
Amenities, and Open Space
which is not allowed. In addition, PUDs have a minimum required amount of
recreational/open space, and it is not clear from this plan whether that amount is
currently met, as there are no calculations provided.
In addition, there is an intermittent stream on this property that connects with Moores
Creek. It is suggested that the applicant contact David Hannah, Natural Resources
Manager with the County, to discuss this natural feature. (dhannah@albemarle.org)
Buildings and Spaces of
This principle is partially met. The application is conceptual and shows no buildings to
Human Scale
evaluate scale. However, some additional pedestrian connections are shown as being
provided.
Redevelopment
This principle is met. There is currently no development on these parcels, and they are
considered infill development within the Development Areas, as there is development
on all adjacent parcels.
Respecting Terrain and
This principle is partially met. The only environmental features found on these parcels
Careful Grading and Re-
are managed steep slopes, which can be disturbed with approval of the County
grading of Terrain
Engineer. Any grading that would occur must meet the requirements of Albemarle
County Code during the site plan stage of any potential development plan. There is no
water protection buffer on this property. However, there is an intermittent stream with
managed steep slopes along it.
Clear Boundaries Between
This principle is not applicable to the request. The subject property is located within the
the Development Areas and
Southern and Western Urban Neighborhoods Development Area. No improvements or
the Rural Area
changes in use near any boundaries with the Rural Area are proposed.
Planning - Transportation
Please see the attached Transportation Planning comments from County's Transportation Planner, Kevin McDermott,
kmcdermott(&albemarle.org.
Zoning Division, Community Development Department
Please see the attached zoning comments from Kevin McCollum, kmccollum(c-r�,albemarle.org.
Engineering & Water Resources Division, Community Development Department
The following comments regarding this proposal have been provided by the County Engineer, Frank Pohl,
ffpohl(a�albemarle.org.
Sheet 6 - Private streets must meet VDOT standards, except as allowed in the Albemarle County Code and Design
Standards Manual. Underground stormwater storage facilities are not allowed within public or private street rights -of -
way. Engineering is also implementing policy that UG storage is not allowed under alleys or "private travelways" serving
as the only means of accessing individual lots. Remove UG storage from under private streets (and private travelway if
serving individual lots).
Sheet 6 - Can Open Space include the paved area of Country Green Road?
E911, Community Development Department
The following comments regarding this proposal have been provided by the E911 Division GIS Specialist, Andy Slack,
aslack(kalbemarle.org.
This application will require two (2) new road names:
"Road B — 36' Private"
"Private Road B — 20' "
Please contact our office (aslack@albemarle.org) to reserve road names for this application.
An option to consider is renaming the portion of Wahoo Way that extends from the intersection of 5th St. to the beginning
of the planned "Road B." This portion would be renamed to the same name as "Road B" to prevent a potentially
confusing situation in which Wahoo Way appears to change names midway through. The addresses of the apartments off
of Wahoo Way would not be affected because, as indicated on the submitted plan, Wahoo Way continues onto parcel 76-
54A1 (i.e. the portion of Wahoo Way that goes through the parking area would not be renamed). Since our department is
not in a position to initiate this change, you would need to work with the property owner of parcel 76-54A1 to move this
option forward. If this is of interest to both parties, our office would facilitate the change. I would reiterate that this is not
necessary to do, but it is our recommendation to make the road naming in this area more predictable, particularly for
emergency response.
Building Inspections Division, Community Development Department
No objection at this time.
Albemarle County Fire -Rescue
The following comments regarding this proposal have been provided by the Fire & Rescue plans reviewer, Shawn
Maddox, smaddoxkalbemarle.org.
Fire Rescue has no objections to the zoning map amendment. Street widths, turning radius, water supply and any other
fire code requirements will be addressed during the site plan review process.
Albemarle County Service Authority
Please see the attached comments from ACSA plans reviewer, Richard Nelson, melsonnserviceauthority.org.
Virginia Department of Transportation
Comments will be forwarded to applicant upon receipt by County staff. VDOT contact — Adam Moore,
adam.moorenvdot.virginia. gov.
Albemarle County Office of Economic Development
The following comments regarding this proposal have been provided by J.T. Newberry of the Albemarle County Office of
Economic Development, jnewberr cr,albemarle.org.
Goal 4, Objective 3 of Project ENABLE calls for the County to "lead the promotion of Opportunity Zones." Broadly
speaking, these zones present a unique opportunity for our community to attract private capital investment to our area.
However, in this case specifically, the proposed non-residential space provides an additional benefit by creating spaces
where an Opportunity Fund can invest directly into a growing business that would locate there.
Therefore, staff supports allowing the maximum amount of non-residential space that is consistent with the
Comprehensive Plan. In doing so, the County will also be taking the lead to "help businesses take advantage of grant
programs, state and federal financing opportunities" (Goal 3, Objective 3).
Albemarle County Architectural Review Board (ARB)
The following comments regarding this proposal have been provided by Margaret Maliszewski, staff planner for the ARB,
mmaliszewskigalbemarle.org.
In Blocks 3 and 4, parking should be relegated from 5th Street and Old Lynchburg Road, and building elevations facing
5th Street should be designed as "fronts."
Action after Receipt of Comments
After you have read this letter, please take one of the actions identified on "Action After Receipt of Comment Letter,"
which is attached.
Resubmittal
If you choose to resubmit, please use the attached form. There is no fee for the first resubmittal. The resubmittal date
schedule is provided for your convenience online at:
http://www.albemarle.org/upload/images/forms_center/departments/Community Development/forms/schedules
/Special_ Use Permit_& Zoning Map Amendment Schedule.pdf
Notification and Advertisement Fees
Prior to scheduling a public hearing with the Planning Commission, payment of the following fees is needed:
$ 435.00 Total amount due prior to Planning Commission public hearing for Public Notice requirement
Additional notification fees will not be required unless a deferral takes place and adjoining owners need to be notified of a
new date.
Please feel free to contact me if you wish to meet or need additional information. My email address is
areitelbachgalbemarle.or , and my phone number is 434-296-5832 ext. 3261.
Sincerely,
W 1%cf aw Reite6"
Andy Reitelbach
Senior Planner
Planning Division, Department of Community Development
enc: Memorandum from Department of Community Development, Transportation Planning
Memorandum from Department of Community Development, Zoning Division
Memorandum from Albemarle County Service Authority
ZMA2019-00003 Action After Receipt of Comments
Zoning Map Amendment Resubmittal Form
OF AL
COUNTY OF ALBEMARLE
Department of Community Development
401 McIntire Road, North Wing
Charlottesville, Virginia 22902-4596
Phone (434) 296-5832 Fax (434) 972-4126
TO: Applicant
FROM: Kevin McDermott; Principle Planner —Transportation
DATE: May 3, 201
SUBJECT: ZMA201900003 Royal Fern Comments
The Albemarle County Community Development Department, Planning Division, Principle Planner for
Transportation has reviewed the above referenced plan and associated traffic impact statement as
submitted by Shimp Engineering P.C. (March 2019) and would like to submit the following comments:
Application Plan:
• The Pedestrian and Bike Facility on 5t' Street should be identified as a Shared -use Path and meet
VDOT standards not a Multi -use Path meeting Albemarle County Class B standard.
• Internal pedestrian networks and bicycle facilities such as bike parking should be identified as a
necessary component of the application plan.
• Transit facilities such as provision of a transit stop on 5' Street Extended should be identified as a
necessary component of the application plan
Traffic Impact Analysis:
• Can you provide some evidence for the claim that the new crossover will take 80% of the existing
right turn traffic on Wahoo Way? My understanding is that the development to the north is unable
to make lefts out of their entrance in the peak hour and instead make a right and a U-turn. It
seems that Wahoo Way will see this same issue. This open crossover may later be closed to
crossover traffic if a roundabout is built at Old Lynchburg Rd and 5t' Street Extended. In the
Build condition this is still a LOS of D. Is it worth it to open that crossover?
• Table 4 and Table 11 lists the Old Lynchburg SB with a SBT/SBL LOS of A. Is this a typo and
should those two movements be reversed? Please verify.
If you have any questions regarding these comments, please feel free to contact me.
Kevin M. McDermott
Principal Planner — Transportation
Albemarle County
401 McIntire Road
Charlottesville, VA 22902
(434) 296-5841 Ext. 3414
kmcdermott@albemarle.org
ALBEMARLE COUNTY COMMUNITY DEVELOPMENT — Information from Service Providers
1.
2.
3.
4.
5.
6.
To be filled out by ACSA for ZMA's and SP's
Site is in jurisdictional area for X_ water _X sewer water to existing structures only
not in jurisdictional area.
Distance to the closest water line if in the development area is _Wahoo Way
feet.
Water pressure is with gallons per minute at psi.
Distance to the closest sewer line if in the development area is _On site feet.
Capacity issues for sewer that may affect this proposal _No
Requires Rivanna Water and Sewer Authority capacity certification _X_Yes No
Water flow or pressure issues that may affect this proposal
7.
Red flags" regarding service provision (Use attachments if necessary)
County of Albemarle
Department of Community Development
Memorandum
To: Andy Reitelbach
From: Kevin McCollum and Francis MacCall
Division: Zoning
Date: 4/29/2019
Subject: Staff Comments for Rezoning Application ZMA201900003 Royal Fern
Tax Map Parcels 76-46A, 76-46F, and 76-54
The following comments are provided as input from the Zoning Division regarding the above
rezoning application. Any comments that you have that are duplicative of these please use your
comment.
1. Proposal — Rezone three parcels from R-2, R-10, and CO to Planned Unit Development
(PUD). Section 20 of the Zoning Ordinance outlines the regulations for the proposed
PUD district.
2. Section 20.8.2 provides that no less than 25% of the residential area shall be in open
space. Sheet 6 of 10 of the Application Plan shows .93 acres of open space on the site
with 4.16 acres of residential in Block 1. Additionally, there are 6.02 more acres of
residential in Blocks 2 and 3 combined (sheet 8), but with no additional open space. If
the applicant is going to show the proposed open space location, they shall show the
appropriate amount (25% of the residential area or approximately 2.55 acres) or apply
for a special exception
3. Section 4.7 provides open space regulations. One of the intentions of open space is to
provide active and passive recreation opportunities. For this application to better meet
this intent to provide active and passive recreation opportunities the open space shall be
safe and convenient for the residential areas. Additional open space on the parcels east
of Old Lynchburg Rd would better meet this intent and provide recreational opportunities
to all the residential areas in the entire PUD.
4. Section 20.9.3 provide that the total gross floor area of uses permitted in commercial/
service areas shall not exceed twenty (20) square feet per dwelling unit approved on the
application plan. The Application Plan on Sheet 8 proposes a maximum number of 300
units. At this number of units, the maximum square footage of commercial/service area
is only 6,000 square feet. To be able to show a larger max square footage for
commercial/service the Application Plan either needs to show a larger number of
proposed units or apply for a special exception.