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HomeMy WebLinkAboutSDP201900025 Review Comments Major Amendment, Final Site Plan 2019-07-15 1 COUNTY OF ALBEMARLE Department of Community Development 401 McIntire Road, North Wing Charlottesville, Virginia 22902 (434) 296-5832 July 15, 2019 Tim Miller Meridian Planning Group LLC 440 Premier Circle, Ste 200 Charlottesville VA 22901 RE: SDP201900025 Floor Fashions - Major Site Plan Mr. Miller: The Major Site Plan amendment application has been reviewed. In order for the amended site plan to be approved the following revisions are required: 1. [24.2.1(49) 32.5.2(b), 32.6.2(a)] The HC zoning regulations limit warehouse to 4,000 square feet per site. Additional warehouse is not permitted unless approved by special exception. This site has more than 4,000 square feet of existing previously approved warehouse. Please specify the amount of existing previously approved warehouse area and list the site plans that such approvals were received. Also, specific the amount of proposed new warehouse area. Does the site plan propose additional warehouse area? 2. [24.2.1(49), 32.5.2(b), 32.6.2(a)] The site data provided on the cover sheet lists the existing and proposed uses as commerical; however, throughout the site plan the uses are listed as office/warehouse and commerical/warehouse. For each building provide the SF calculations for the existing uses and provide the SF calculations for the proposed uses. Does this plan propose an increase in the intensity of development onsite? 3. [24.2.2(13), 24.2.1(53), 32.6.2(a)] The site is subject to the 400 gallons of water consumption per site acre per day cap because external changes are proposed to the site. Specify the proposed uses and provide water consumption data for the site, and for each parcel to ensure each lot will not exceed 400 gallons per site acre per day. This information shall be submitted by the applicant, reviewed and approved by staff prior to site plan approval. 4. [32.5.2(q), 32.6.2(a)] Provide traffic generation figures for the site based on current Virginia Department of Transportation rates; indicate the estimated number of vehicles per day and the direction of travel for all connections from the site to a public street. 5. [32.7.2, 32.7.2.1, 32.7.2.1(a)] Remove the proposed northern entrance and access road onto Hunters Way which serves Lot 1. The new entrance is not permitted because the site is already served by 2 existing entrances onto public streets. The existing accessway between Lot 1 and TMP 79-4A shall remain. Depict, label, and dimension a new access easement over TMP 79-4A or TMP 79-4P to serve Lot 1. 2 6. [32.4.3.2, 32.4.3.2(b), 32.6.2] The wastewater treatment facility shall be approved by County Engineering, VDH, and DEQ prior to site plan approval. If other government agency approvals are warranted, they shall also be gained prior to site plan approval. 7. [32.6.2(d), Section 3] The site plan depicts a wastewater treatment facility proposed on TMP 07900-00-00-004P0 to serve TMP 07900-00-00-004A0. However a wastewater treatment facility is considered an accessory use1 to the primary use it serves. By definition (Section 3.0 in the Albemarle County Zoning Ordinance), an accessory use must be located on the same property as the use it serves. Because this requirement is found within a definition, it is not subject to variance and there is no provision for waiver of this requirement. Revise to ensure each lot is provided its own sewage system and well on the lot it serves. The system(s) shall be approved by VDH, DEQ, and the County prior to site plan approval. 8. [24.2.1(49) 32.5.2(b), 32.6.2(a)] Revise to ensure the parking calculations provided on sheet 1 coincide with the uses proposed throughout the site plan for each lot. For example: the parking calculations on sheet 1 utilize office and warehouse calculations for Lot 4A (building #2422) and Lot 1 (building #2424); however, other sheets of the site plan list the uses in these buildings as commercial and warehouse. Also, ensure the total square footage of each building provided in the parking calculations coincide with the square footages of each building provided throughout other sheets of the site plan. 9. [4.12] The parking calculations for warehouse uses shall include one (1) space per employee plus one (1) space per each five hundred (500) square feet of floor area open to the public for customer parking, but in all cases a minimum of two (2) customer parking spaces. Please label which spaces are for customers. Also, if a commerical use is truly proposed, ensure the commerical parking calculations are provided for the specific uses per section 4.12. 10. [32.7.2.3, 352.7.2.2, 32.6.2(a)] The existing accessway between Lot 1 and TMP 79-4A shall be upgraded to provide a 5’ sidewalk between the two lots for pedestrian access. Additionally, 5’ sidewalks shall be provided internally throughout the site to connect the three uses and further pedestrian safety and access. This will enable pedestrians to walk safely and conveniently between buildings on the site. 11. [4.2.3, 4.2.5, 33.44] The current design relies on critical slope disturbance throughout the site. Prior to site plan approval the Board of Supervisors shall act on this special exception to permit the disturbance requested. The applicant requested a deferral of the Special Exception for Critical Slopes till the item is scheduled, heard, and acted on by the Board of Supervisors. The applicant plans to address the SRC comments, submit revised plans, and submit a revised critical slopes waiver request. When the critical slopes SE is revised please ensure the property owner signs the application as required under Section 33.44(B). 1 Accessory use, building or structure. “Accessory use,” “building” or “structure” means a subordinate use, building or structure customarily incidental to and located upon the same lot occupied by the primary use, building, or structure, and located upon land zoned to allow the primary use, building or structure; provided that a subordinate use, building or structure customarily incidental to a primary farm use, building or structure need not be located upon the same lot occupied by the primary farm use, building, or structure. For the purposes of County Code § 18-1.7(c)(2), any street may serve any use or structure authorized by this chapter, regardless of whether the use or structure is on the same lot or in the same zoning district as the street. 3 12. [4.12.19, 4.12.13(e)] Provide details on the plan to ensure the dumpster pads meet the minimum design standards. 13. [32.5.2(n), 32.6.2(a)] Dimensions all existing and proposed improvements. 14. [32.7.5.1, 4.1(b)] Lot 1 shall be provided an onsite well for water service. Depict the well location and connection line. VDH approval of the well is required. 15. [32.6.2(j), 32.7.9.2] The site plan requires substancial changes which will effect the landscape plan. Additionally, an ARB application is required which will effect the landscape plan. Prior to final site plan approval a landscape plan that complies with section 32.7.9 and encompass all ARB requirements must be approved. 16. [32.6.2(j), 32.7.9.6] An area of at least five (5) percent of the paved parking and vehicular circulation area shall be landscaped with trees or shrubs. The plan attempts to only apply this requirement to ‘new’ paved areas; however, this is not the intent of this section. Revise to apply the standard to all paved parking and vehicular circulation areas. 17. [32.5.2(a), 32.6.2(a), Section 24, Section 21, 4.20] Revise the setbacks on the cover sheet as follows: Building Setback for TMP 79-4P and TMP 79-4A Front Minimum: 10 feet from the right-of-way Front Maximum: None because the lots abut a principle arterial highway. Side and Rear Minimum: Primary structure shall be separated in accordance with the current edition of the Building Code. Side and Rear Maximum: None Parking Setback: Front Minimum – 10’ from the public street right-of-way Building Setback for Lot 1 Front Minimum: 10 feet from the right-of-way Front Maximum: maximum setback does not apply to the existing building Side and Rear Minimum: Primary structure shall be separated in accordance with the current edition of the Building Code. Side and Rear Maximum: None Parking Setback: Front Minimum – 10’ from the public street right-of-way 18. [32.5.2(a), 32.6.2(a), Section 24, Section 21, 4.20] On the plans label the distance TMP 79-4A and TMP 79-4P are from the Montichello Historic district, which is across Rte 250. 19. [32.5.2(b), 32.6.2(a), 4.12.8(e)] As proposed 37 of the required spaces for the use on TMP 79- 4A are located on TMP 79-4P. On the site plan designate these 37 spaces. Ensure these parking spaces are provided a sidewalk for pedestrians to safely access these spaces from TMP 79-4A. Also, it is recommended that a shared parking agreement be developed and recorded prior to final site plan approval. 20. [4.12, 32.6.2(a)] Parking spaces provided on Lot 4A are labeled as being 16’ in length; however, they are truly 18’ in length. Revise the label. 21. [32.6, 32.4.3.2, 32.4.3.3] ARB approval of the final site plan is required. 22. [32.6.2(j), 4.17.4] Outdoor Lighting. Revise the lighting plan and photometric plan to utilize the light loss factor (LLF) of 1. Ensure the spillover onto all public roads does not exceed 0.5 4 23. [Comment] Revise the title of the site plan to be: “SDP2019-25 Major Site Plan Amendment to SDP-218 and SDP2004-53 for Floor Fashions of Virginia”. 24. [32.5.1(c), 32.6.2(a), 32.6.2(g)] All required off-site easements, if any once revisions take place, must be approved and recorded prior to final site plan approval. Recordation information of this action shall be provided on the final site plan. 25. [32.6.2(h)] Revise the signature panel to provide a signature line for each member of the site review committee. Please add a line for ARB. 26. [17-1004] Provide the required tier 4 assessment for County Engineering’s review and approved prior to site plan approval. 27. [32.7.4.1, 32.7.4.2] Prior to site plan approval the WPO application must be approved. 28. [32.5.2(f), 32.6.2(a)] Provide the name and location of all watercourses and other bodies of water adjacent to or on the site. 29. [32.4.3.6, 32.4.3.2] The site plan shall not be approved until all SRC reviewers have approved the plan. Their comments are referenced below and attached. Engineering – John Anderson Requested changes, see attached review. Virginia Department of Health (VDH) - Alan Mazurowski Requested changes, see attached review. DEQ – Brandon Kiracofe Requested changes, see attached review email. VDOT – Adam Moore Requested changes, see attached review letter. ARB - Margaret Maliszewsk Requested changes, see attached review. Building Official – Michael Dellinger Requested changes, see attached review. Fire and Rescue - Shawn Maddox No objection, see attached review. E911 – Andy Slack No objection, see attached review. Thomas Jefferson Foundation – Liz Russell Thomas Jefferson Foundation provided the attached communication expressing concerns with the underground wastewater treatment plant and associated dischare into a storwater drainage culvert owned by VDOT, then through over private property of the Foundation (Shadwell Farm). 5 Staff has provided references to provisions of Chapter 18 of the Code of the County of Albemarle. The Code is kept up to date by the County Attorney’s office. The Code may found on the County Attorney’s website which may be found under “Departments and Services” at Albemarle.org. In accord with the provisions of Section 32.4.3.5 of Chapter 18 of the Code if the developer fails to submit a revised final site plan to address all of the requirements within six (6) months after the date of this letter the application shall be deemed to have been voluntarily withdrawn by the developer. If you have any questions about the comments please feel free to contact me. Sincerely, Christopher Perez Senior Planner Planning Division 1 Christopher Perez From:Brandon Kiracofe <brandon.kiracofe@deq.virginia.gov> Sent:Tuesday, June 25, 2019 8:56 AM To:Christopher Perez Cc:Dameron Jason jpb60155 Subject:RE: SDP201900025 Lowes and Floor Fashions - Major Site Plan Mr. Perez: Ryder Enterprises, LLC was issued VPDES Permit No. VA0092790 for the discharge of treated wastewater from Ryder Enterprises Wastewater Treatment Plant (WWTP) located at 2305 Hunters Way, Charlottesville. The location of the discharge from Ryder WWTP that was specified in the permit application and that was utilized in the development of VPDES Permit No. VA0092790 is consistent with what is shown on the final site plan. The design flow specified in the VPDES permit for the WWTP is 0.015 MGD. Part I.D.5 of VPDES Permit No. VA0092790 states, “Certificate to Construct (CTC) / Certificate to Operate (CTO) Requirement – The permittee shall, in accordance with the DEQ Sewage Collection and Treatment Regulation (9VAC25-790), obtain a CTC and a CTO prior to constructing and operating the wastewater treatment works. Noncompliance with the CTC or CTO shall be deemed a violation of the permit.” As part of the Application for a CTC, an Engineer’s Certification Statement Signature is required. Projects are no longer reviewed by DEQ for compliance with the design requirements of the Sewage Collection and Treatment Regulations. It is the responsibility of a licensed professional engineer in the Commonwealth of Virginia to certify that the design adheres to the design requirements of the Sewage Collection and Treatment Regulations. An application for a CTC for Ryder Enterprises WWTP has not been received by DEQ. Sincerely, Brandon Kiracofe ----------------------------------------------- Brandon D. Kiracofe | Water Permits & Compliance Manager | DEQ - Valley Regional Office | (540) 574-7892 ----------------------------------------------- Brandon D. Kiracofe | Water Permits & Compliance Manager | DEQ - Valley Regional Office | (540) 574-7892 From: Christopher Perez <cperez@albemarle.org> Sent: Friday, June 21, 2019 9:42 AM To: brandon.kiracofe@deq.virginia.gov Subject: RE: SDP201900025 Lowes and Floor Fashions - Major Site Plan From: Christopher Perez Sent: Friday, June 21, 2019 9:24 AM To: jason.dameron@deq.virginia.gov; brandon.kircofe@deq.virginia.gov Cc: John Anderson <janderson2@albemarle.org> Subject: RE: SDP201900025 Lowes and Floor Fashions - Major Site Plan Mr. Kiracofe and Mr. Dameron, RE: SDP201900025 Lowes and Floor Fashions - Major Site Plan 2 I request that DEQ review the above referenced site plan for compliance with an approved DEQ permit (attached). To view the plan electronically click on SDP201900025. Below is a brief description of the proposal. What is your estimated time to provide review comments on this plan? Please give me a call if you have any questions. PROJECT LEAD REVIEWER: Christopher Perez PROJECT: SDP201900025 Lowes and Floor Fashions - Major Site Plan MAGISTERIAL DISTRICT: Scottsville TAX MAP/PARCEL: 079000000004P0 and 079000000004A0 LOCATION: 2305, 2424, and 2422 Hunters Way, at the intersection with Richmond Road. PROPOSAL: Request for approval of a major site plan amendment to construct a new entrance on Hunters Way, reconfigure and divide parcels, reconfigure drive aisles and associated parking for existing buildings. The existing uses of office warehouse and commercial warehouse are proposed to continue. Associated with the request is a critical slopes waiver request. ZONING: HC Highway Commercial – commercial and service; residential by special use permit (15 units/ acre). ENTRANCE CORRIDOR: Yes PROFFERS: No COMPREHENSIVE PLAN: Rural Area – preserve and protect agricultural, forestal, open space, and natural, historic and scenic resources; residential (0.5 unit/ acre in development lots). Christopher Perez | Senior Planner Community Development Department Planning Services 401 McIntire Road | Charlottesville, VA 22902 434.296.5832 ext. 3443 1 Christopher Perez From:Liz Russell <lrussell@monticello.org> Sent:Monday, July 01, 2019 3:36 PM To:Christopher Perez Subject:Comments RE: SDP2019-25 Lowes + Floor Fashions- Major Attachments:2015-01-08_Ryder WWTP Comments (TJF) v.3_LGB SIGNED.pdf Importance:High Chris – please know that a letter will be coming to you but I wanted to make sure you had these comments in email form before the end of the day. Thank you, as always, for the opportunity to provide comments. Dear Mr. Perez, This letter is in response to Project SDP201900025 Lowes and Floor Fashions - Major Site Plan, notification of which was shared via SRC Distribution Memo 2019-05-20. The two TMPs, 79-4P and 79-4A, fall within the Monticello Viewshed; additionally, the Thomas Jefferson Foundation (TJF) is an abutting property owner (79-7A) of Shadwell, a property originally owned by Peter Jefferson, Thomas Jefferson's father. The property is the birthplace of Thomas Jefferson. The Thomas Jefferson Foundation wishes to state concerns regarding the proposed Major Site Plan Amendment – the primary concern is the underground wastewater treatment plant (WWTP) and associated discharge into a stormwater drainage culvert owned by the Virginia Department of Transportation ("VDOT") under State Route 250 and then through and over private property of the Foundation (Shadwell Farm) before (if ever) ultimately reaching state waters. TJF and other abutting property owners received notification of this application via a letter dated June 5, 2019; however, neither the letter nor the SRC Distribution Memo mention the WWTP. In 2015, in addition to additional concerned parties, TJF attended public information sessions hosted by Albemarle County regarding a permit for Ryder Enterprises to construct a wastewater treatment plant at this site (VPDES Permit No. VA 0092720). Our concerns were communicated to the Virginia Dept. of Water Quality in a letter dated January 9, 2015 (letter is enclosed). With the assistance of a civil engineer, we outlined our concerns and questions regarding the Permit. Project SDP201900025, as presented, does not raise any significant viewshed concerns to the Foundation at this time; however, we have significant concerns that Shadwell water quality will, or may be, adversely impacted if the concerns and questions expressed in the January 9, 2015 are not addressed by the applicant. There is not enough detail in the current application materials (site plan dated April 16, 2019 by Meridian Planning Group, LLC.) to assess the type of WWTP and implications to water quality. Thank you for the opportunity to provide comment. Sincerely, Liz Russell Assistant Director of Facilities + Planning, Thomas Jefferson Foundation 2 Liz Russell | Assistant Director of Facilities + Planning Thomas Jefferson Foundation, Inc. | Monticello P.O. Box 316 | Charlottesville, VA 22902 Work: 434-984-7589 | Cell: 434-466-1275 | Email: lrussell@monticello.org January 9, 2015 .Mr. Jason Dameron Virginia Dept. of Environmental Quality Valley Regional Office 4411 Early Road P.O. Box 3000 Harrisonburg, VA 22801 RE: Ryder Enterprises, LLC; VPDES Permit No. VA 0092720 Mr. Dameron: Lc:s uc: GRF.F.NE BowMAN !'resident I am writing on behalf of the Thomas Jefferson Foundation, Inc. ("Foundation"), to address questions and comments and to request a public hearing concerning the draft permit for Ryder Enterprises, LLC ("Applicant"); Wastewater Treatment Plant ("WWTP") VPDES Permit No. VA 0092720 ("Draft Permit"). Thomas Jefferson Foundation, Inc. The Foundation owns and operates Monticello, the mountaintop home of Thomas Jefferson and the only home in America on the elite World Heritage List of the United Nations. As a private, nonprofit organization, the Foundation receives no regular federal or state budget support for its twofold mission of preservation and education. Since 1923, the Foundation has steadily expanded its role as a museum and educational institution. Its facilities now include the house and gardens on over 2,000 of Jefferson's original 5,000 acres; the Robert H. Smith International Center for Jefferson Studies next door at Kenwood, a headquarters for Jeffersonian research and teaching and home to the Jefferson Library; and the Thomas Jefferson Center for Historic Plants, which propagates heirloom varieties and makes them available to institutions and individuals. The Thomas Jefferson Visitor Center and Smith Education Center hosts state-of-the art exhibits for visitors of all ages. It serves as the gateway to Jefferson 's timeless Monticello, preparing guests for their trips to the historic mountaintop through dynamic content presenting fresh perspectives on Monticello and the enduring significance of Jefferson 's life and ideas. About a half a million people visit Monticello each year. THOMAS ]EFFERSON FOUNDATION, INC. Post Office Box 316 · Charlottesville, Virginia 22902 · www.monticello.org Address Mailing Address: Overnight Address: Thomas Jefferson Foundation Post Office Box 316 Charlottesville, VA 22902 Comments and Justification for Public Hearing 1070 Monticello Loop Operations Cottage Charlottesville, VA 22902 For the reasons set out in the numbered paragraphs below, the Foundation is concerned that the Draft Permit, as currently written, may be inconsistent with, or in violation of, the State Water Control Law (Va. Code§ 62.1-44.2 et seq .), federal law or the regulations promulgated thereunder. 1. The Foundation owns Shadwell Farm, a property originally owned by Peter Jefferson, Thomas Jefferson's father. The property is the birthplace of Thomas Jefferson. Shadwell is adjacent to the proposed WWTP and the Foundation is requesting a hearing because it believes Shadwell will, or may be, adversely impacted if the concerns and questions expressed here are not adequately addressed. 2. The WWTP will be located in Albemarle County's Entrance Corridor. Entrance Corridors are streets that provide routes of tourist access to the County and to historic landmarks, structures, and districts. The goal of this regulation is to ensure that new development in these corridors reflects the traditional architecture of the area and that development within the corridors is orderly and attractive. 3. A public hearing is warranted and due consideration given to the fact that Shadwell Farm is located in the Monticello Historic District ("MHD"). The intent and purpose of the MHO is to create a planned historic district: a. To permit restoration, preservation, conservation, education, programs, research, business and support activities, including fundraising activities for the public and/or contributors, all of which are related to the operation of a historic house museum and historic site at Monticello; b. To promote the preservation, interpretation and enhancement of a unique historical site; c. To preserve significant tracts of agricultural and forestal land; d. To be a district that is unique to those parcels which both belonged to Thomas Jefferson and contain uses related to the operation of the historic site, in recognition of: 1. the importance of Thomas Jefferson to the history of Albemarle County; n. the importance of Monticello to the reputation, education, and economy of Albemarle County; 2 111. Monticello as a unique element of the historical and architectural legacy of Albemarle County, the nation, and the world, as recognized by its inclusion on the World Heritage List administered by the United Nations Educational, Scientific, and Cultural Organization. See Albemarle County Code of Ordinances, Ch. 18, § 11. 4. The effluent will not enter a water of the state at the outfalL Instead, it is our opinion that the effluent from the WWTP will need to pass through a stormwater drainage culvert owned by the Virginia Department of Transportation ("VDOT") under State Route 250 and then through and over private property of the Foundation (Shadwell Farm) before (if ever) ultimately reaching state waters. Discharge permits do not convey property rights. See 9VAC25-31-190 G. Applicant has not sought, and does not hold any form or permission or easement to discharge effluent to Foundation property. 5. The discharge from the WWTP is proposed to flow through a VDOT culvert that may be inadequately sized to transmit both stormwater and treated effluent. If the VDOT storm culvert is improperly sized to carry effluent and storm flow, this may result in flooding and further release of effluent to private and public property and the roadway. 6. The Draft Permit makes reference to a nutrient trading. The Rivanna Water and Sewer Authority ("Authority") has expended significant sums to upgrade its Moores Creek Wastewater Treatment Plant facility as part of the Charlottesville-Albemarle community's commitment to remove nutrients from the watershed at a level higher than that required by law. If this WWTP requires trading to achieve its permit limitations, it could be seen as undercutting this commitment by the localities and the Authority. Additionally, as worded, the Draft Permit appears to allow the WWTP to discharge nitrogen and phosphorus into a stream with critical flows of zero. Virginia DEQ should reevaluate the WWTP discharge facility taking into consideration the limits of technology in the interest of minimizing stream impairment. 7. The application stated that the facility would be designed for 0.015 mgd (15,000 gpd), to serve 125 people. Please identify the building facilities that are planning to use the WWTP and the basis for the design flow. The application addendum states that the operations generating the wastewater include medical offices. We would also like to know where the medical offices are located as none appear present at the address listed. 8. The effluent discharge is identified as flowing in an ephemeral stream for about 2,000 ft. (0.42 mi.) This is essentially discharge to the surface ofthe ground in 7Q10 conditions, and not to a flowing stream. We do not understand how the WWTP described could discharge effluent from this secondary treatment facility at levels that will meet water quality standards as 1 00 percent effluent. 3 9. Ammonia-N toxicity is pH dependent. If the effluent at the design flow does reach Bam Branch, then the pH of existing discharges in the watershed may need to be considered. We would be interested to know if the ammonia concentration in Barn Branch was evaluated or if pH sampling of the stream was performed. 10. If the effluent does reach the stream, as an ephemeral stream, the receiving water does not appear to be able to provide a minimal dilution of 1 0 to 1 . An extended failure of the WWTP treatment could result in the discharge of partially treated, or even untreated, sewage. 11. The WWTP will be permitted as Reliability Class II. We would like to understand the rationale for Reliability Class II shown in the Fact Sheet and not Reliability Class I. A Class I facility would be equipped with an electrical generation facility. It is reasonable to conclude that the location of the discharge, or potential discharge, due to the volume or character, might permanently or unacceptably damage neighboring properties, the VDOT right of way, Route 250, or adversely affect private property or the receiving waters or public health and welfare during periods of short-term operations interruptions. See 9 V AC 25-790- 70. The facility should be considered for qualification as Reliability Class I. 12. The VPDES application indicates this WWTP is a tertiary treatment facility. We do not understand how a Rotating Biological Contactor ("RBC") with a secondary clarifier may be considered tertiary treatment. 13. No buffer zone is included in the Draft Permit. A 200 foot buffer zone is required for a WWTP of this type. See 9 VAC 25-790. The site plan in the VPDES permit application does not appear to meet the requirements of law. Conclusion The Foundation contacted Applicant and attempted to discuss the comments above with Applicant directly. This attempt was rejected and a representative or vendor of the applicant referred us directly to Virginia DEQ. The Foundation has valid and substantial concerns and respectfully requests complete responses and a public hearing in accordance with Va. Code § 62.1-44.15:02. Please refer questions or comments concerning this letter to our attorney, Dale Mullen, at 804.775.4710, dmullen@mcguirewoods.com. Sincerely,. .. , .. --;;. ~ // y·--· • J 1f j .l :1 (~· , ~?-~ A J1 11 11 . 61 /1 d \<:: -~~\jv l \:~: ... Y~ v v v v ;1 t/ v Vl-------------·----; LESLIE GREENE BOWMAN 4