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HomeMy WebLinkAboutSP201900009 Correspondence 2020-04-06FOR OFFICE USE ONLV SP X Fee Amount s Date Paid By who? Receipt R Ck# Bv. Resubmittal of information for Special Use Permit` PROJECT NUMBER THAT HAS BEEN ASSIGNED: 5P R LO 1 CI—00DO 9 Owner/Applicant Must Read and Sign I,1hereeby certify that the information provided with this resubmittal is what has been requested from staff _V �Q,2 u b W • I 1'FCrt� 46) U, 7,020 Signature of Owner, ConYact Pjzbhaser Date �lAlutt� V�.'t34- q51-570� Print Name Daytime phone number of Signatory FEES to be paid after application For original Special Use Permit fee of $1,075 First resubmission (TO BE PAID WHEN THE RESUBMISSION IS MADE TO INTAKE STAFF) Flee ❑ Each additional resubmission (TO BE PAID WHEN THE RESUBMISSION IS MADE TO INTAKE STA 1 $538 For original Special Use Permit fee of $2,000 ❑ First resubmission (TO BE PAID WHEN THE RESUBMISSION IS MADE TO INTAKE STAFF) Free ❑ Each additional resubmission (TO BE PAID WHEN THE RESUBMISSION IS MADE TO INTAKE STAFF) $1,075 County of Albemarle Department of Community Development 401 McIntire Road Charlottesville, VA 22902 Voice: (434) 296-5832 Fax: (434) 9724126 Revised [IM015 Page I of I WILLIAMS MULLEN Direct Dial: 434.951.5709 vlong@williamsmullen.com April 6, 2020 Via Email: blangille(aMbemarle.org and electronic submission Cameron Langille Senior Planner Planning Division Department of Community Development Albemarle County, VA Re: SP 2019-00009 S.L. Williamson Replacement Asphalt Plant Dear Cameron, Thank you for your comment letter of October 3, 2019, and your attendance at and participation with the community meeting we held on December 16, 2019 in connection with SUP 2019- 00009 for the S.L. Williamson Replacement Asphalt Plant. Enclosed are updated SUP Plans and other materials prepared in response to your comments, and below are our written responses to the comments in your letter. General Annlication Comments: 1. Please revise the title of the plan to "Concept Plan" and include the application number, SP201900009. The title of the plan has been revised to "Concept Plan" as requested. The application number has been added to the title of the plan. 2. Project narrative/Concept Plan: Under A. Proposal, the narrative states that the lease area of the asphalt plant is 5.6 acres. However, Sheet 1 of the Concept Plan states that the SP area is 4.4 acres and follows the limits of the SL Williamson lease area. Please clarify this discrepancy and revise either the narrative or Sheet 1 of the Concept Plan so that the acreages match and are correct. The total lease area is 5.6 acres and located on TMP 88-18 (4.4 acres) and TMP 88- 13B (1.2 acres). At this time, TMP 88-13B is not located within the Natural Resource Extraction Overlay (NR) district. The SP request is only for the portion of the lease area that is located within the NR district, the 4.4 acres located on TMP 88-18. 321 East Main Street, Suite 400 Charlottesville, VA 22902 T 434.951.5700 F 434.817.0977 will iamsmullen.com I A Professional Corporation April 6, 2020 Page 2 3. Flood Hazard Overlay District (FH) — Per the application narrative and notes on Sheet 1 of the Concept Plan, the applicant is pursuing a floodplain study to determine the true extent of the 100-year floodplain within the extent of the SP project. Once completed, and in consultation with the County Engineer, a Letter of Map Revision (LOMR) will be filed with FEMA. This will identify the true extent of the 100-year floodplain, and the proposed plant will be located outside of the floodplain. On Sheets 2-4 of the Concept Plan, please identify the existing extent of the FH District (100-year floodplain) per FEMA FIRM panel, and label this feature with the FIRM panel number. The FEMA floodplain line has been added to sheets 2-5. It has been labeled with the FIRM Panel number to differentiate it from the LOMR floodplain limits. ii. If the LOMR is completed prior to the Board of Supervisors public hearing (as the applicant anticipates according to the project narrative), Sheets 2-4 will need to identify the boundaries of the 100-year floodplain in accordance with the LOMR. Acknowledged. iii. Please explain how the proposal will be consistent with Strategy #7a from Chapter 4 of the Comprehensive Plan through the approval of the LOMR. A LOMR is being processed to prove that the asphalt plant is not located within the 100-year floodplain. By keeping the plant out of the floodplain, the proposal will reduce the risk of any impairment of the function of the floodplain. Please keep in mind that this asphalt plant has been located in this precise location for over 50 years, and the Applicant is only proposing to replace the existing outdated plant equipment with new and more environmentally friendly equipment. 4. Critical Slopes: Please make the symbology representing areas of critical slopes darker/more visible on Sheets 2-4 of the Concept Plan. The hatching for the areas shown as critical slope has been updated as requested. The areas have been updated to correspond with the aerial topography within the Lease Area, so that the areas are more accurately depicted. However, as discussed in more detail in our response to item 5 below, these areas are not technically critical slopes since they are merely man-made piles of overburden from the legal and normal operations of the approved quarry. We have nevertheless updated these areas as requested for clarity. 5. Critical Slopes: The proposed layout of the asphalt plant and associated travelways/ improvements encroaches into areas of critical slopes. Furthermore, staff cannot verify that grading or construction activity that will be performed to establish the asphalt plant and April 6, 2020 Page 3 improvements will not encroach into critical slopes as required by Section 18-4.2.3(b). Therefore, two special exception applications are needed: i. 18-4.2.3(a) — waive or modify the requirement that "no structure or improvement shall be located on any lot or parcel in any area other than a building site." ii. 18-4.2.3(b) — waive or modify the requirement that "no structure, improvement, or land disturbing activity to establish the structure or improvement shall be located on critical or preserved slopes except as otherwise permitted under sections 4.2.5, 4.2.6, 4.3.1, and 30.7.4." iii. 18-4.2.5(a)(1) and 18-33.44 — Please submit an Application for a Special Exception. The special exception application will run with and as part of the SP application. Submit all required information identifying how the request would satisfy one or more of the findings set forth in Section 18-4.2.5(a)(3). iv. 18-4.2.5(a)(1) —The special exception application must also shall state the reason for the modification or waiver, explaining how the modification or waiver, if granted, would address the rapid and/or large-scale movement of soil and rock, excessive stormwater run-off, siltation of natural and man-made bodies of water, loss of aesthetic resources, and, in the event of septic system failure, a greater travel distance of septic effluent (collectively referred to as the "public health, safety, and welfare factors") that might otherwise result from the disturbance of critical slopes. The definition of "Critical Slopes" in Section 3 of the Zoning Ordinance provides that "slopes of 25 percent or greater which are lawfully created within a development that was approved by the County shall not be considered critical slopes." A careful review of the available aerial photography shows that the "critical slopes" on the western side of the SP limits are actually not technically critical slopes, but merely man-made piles of materials resulting from the normal, lawful operations of the quarry. These slopes were created by the placement of the overburden as areas of the quarry have been excavated. They are literally man-made piles of materials that are part of the quarry operations, which is a legal, permitted and thus approved use. As such, the construction and installation of the asphalt plant will not impact any actual critical slopes as defined by the Ordinance, such that a critical slope waiver is not required. 6. Grading: Please revise the Concept Plan so that it includes information showing proposed grading and the extent of disturbed areas. This information is needed in order for staff to evaluate the proposal's consistency with Objectives 3, 4, and 6 of Chapter 4 of the Comprehensive Plan. i. This is also a requirement for all special use permit applications in accordance with Section 18-33.33(F) of the Zoning Ordinance. A Grading Plan has been added to the plan set as sheet S. April 6, 2020 Page 4 7. Natural Resources Extraction Overlay District (NR): There are several Zoning Ordinance Code sections that establish different standards that apply to uses within the NR Overlay District. Please provide more information that identifies how the proposal is consistent with these requirements: 18-30.4.05 — Percentage of lot coverage. All operations associated with the extraction of natural resources as well as the provision of parking areas and access roads and driveways shall not occupy more than eighty (80) percent of the total site. The existing lot coverage in the SP area is equal to 63% (2.8 acres). The proposed lot coverage after the construction and installation of the plant will be 63% (2.8 acres). ii. 18-30.4.06 — No uses or structure shall be located within two hundred (200) feet of any occupied dwelling. Please provide information demonstrating the replacement use and associated structures will be located a minimum of 200 feet from any occupied dwelling. The distances to the four closest buildings (residential and church) have been added to the bottom right corner of Sheet 2. The closest building, the church, is at least 575' from the proposed asphalt plant. The closet dwelling is 1,200 feet away on TMP 100-24. iii. 18-30.4.09 - Existing trees and ground cover along public road frontage shall be preserved, maintained and supplemented by selective cutting, transplanting and addition of new trees, shrubs and other ground cover for the depth of any roadside setback (100 ft.). What is the extent of the existing tree line and groundcover within the 100 ft. roadside setback within the SP area? Providing notes on proposed landscaping (specifically by providing native vegetation) will make the proposal consistent with Objective 4, Strategy #4e of Chapter 4 of the Comprehensive Plan. An existing stand of trees is located between Red Hill Road and the asphalt plant parking area/storage area. The stand is comprised of deciduous trees and varies in depth from 20' to 60'. The existing plant has been in the current location since 1969, and the Applicant is not proposing to move the plant any closer to the road or to make any other modifications to the plant layout. It is merely proposing to replace the existing equipment which has reached the end of its useful life with more modern equipment that will be a benefit to the community and nearby landowners as well as to the Company. The general layout of the asphalt plant generally has been in place for decades, and an existing travelway and parking area already exist just beyond the existing vegetated area. This travelway and parking area are critical to the current operation of the plant. April 6, 2020 Page 5 As for supplementing this area with additional landscaping, the Applicant advises that would create significant adverse impacts on the Company by significantly increasing the risk of theft and vandalism of the property. Based upon many decades of owning and operating asphalt plants in Albemarle County and the surrounding areas, the Applicant advises that if additional landscaping were added to the existing stand of trees, it would create a blind spot for vehicles to park without being seen from the road, which would substantially increase the risk of theft or vandalism of the plant equipment and associated materials. In addition, the wide shared entrance with the quarry leaves an opening for the plant to be viewed from the roadway even if additional landscaping were added, such that the plant would still be visible from the road, as it has been for decades. We contend that the existing vegetation provides just enough screening of the plant from the road, without creating any adverse impacts. The Applicant will preserve and maintain the existing vegetated area. iv. 18-30.4.10 — See Zoning Division comments regarding hours of operation. In similar SP applications for asphalt plants in the Rural Areas and NR Overlay District, hours of operation have been restricted to 7:00 a.m. and 10:00 p.m., Monday through Saturday, provided that for no more than sixty days per year, the hours of operation may be between 7:00 a.m. and 12:00 a.m., Monday through Saturday. Staff will be recommending those hours as a condition of approval of the SP. The Applicant cannot agree to a condition of approval limiting operating hours. This plant has been operating 24 hours a day, 7 days a week, for over 50 years, and the ability to operate as such is critical to the business. Furthermore, the company has numerous large contracts with the Virginia Department of Transportation to provide asphalt for public roads in the County and surrounding region. VDOT requires that re -paving work to be carried out after-hours to minimize the impact on the travelling public, which thus requires the asphalt to be made at the plant after hours, including between the hours of 10:00 pm and 7:00 am, and including on Sundays. 8. Water Protection Ordinance (WPO): The proposed layout encroaches into the WPO stream buffer within the SP area. Under the WPO Ordinance, the furthest that any structure, improvement, or activity can encroach into the WPO buffer is the most landward 50' feet, in accordance with Section 17-604(A). The travelway and portions of the stormwater facilities are located beyond the most landward 50.' The layout needs to be revised to the satisfaction of the County Engineer before staff can recommend approval. This will strengthen the application's consistency with Objective 1, Strategy #1a and Objective 3, April 6, 2020 Page 6 Strategy #3a from Chapter 4 of the Comprehensive Plan. See Engineering and Zoning Division comments for further information. The travelway has been reconfigured to be in the landward 50' of the stream buffer. The settling basins have also been relocated to be in the landward 50' of the stream buffer. 9. Natural Resources: David Hannah, Natural Resources Manager, has reviewed the application and has no objections so long as proposed grading and improvements do not extend further northward into the site. There are existing wetlands and other sensitive ecological features along the stream north of the improvements shown on the Concept Plan. Please be aware of this issue when addressing comment #8. If certain features can only be relocated north of where currently shown, they should be located to be entirely outside of the 100' WPO stream buffer. i. There appears to be a rectangular -shaped area north of the proposed travelway that is located between the 500'-600' contour lines that could be utilized for relocating the travelway turnaround and/or SWM facilities, as mentioned in the previous comment. This area measures approximately 8,100 sq. ft. and is located outside of the WPO 100' stream buffer. If necessary in order to address comment #8, staff could support the northward relocation of improvements to this area. The travelway has been reconfigured to be in the landward 50' of the stream buffer. The settling basins have also been relocated to be in the landward 50' of the stream buffer. It is necessary to maintain the forward movement of the truck traffic through the plant and the rectangular area you reference is not wide enough to allow for the turning radius of the trucks that will use the site. Comprehensive Plan Comments: Your letter states that your will not be able to make a favorable recommendation on the proposal unless the Applicant demonstrates that the application is consistent with the following objectives from Chapter 4 of the Comprehensive Plan — Natural Resources. First, we ask that you keep in mind that this existing asphalt plant has been operating in this exact location for over 50 years, and that the Applicant is only replacing old equipment with new and more modern equipment in the exact same location. We think that context is critical to the staff's review and analysis of this application. Nevertheless, we contend that the application is fully consistent with these goals as follows: Objective 1: Ensure clean and abundant water resources for public health, business, healthy ecosystems and personal employment by preventing shortages and contamination. As noted previously, the travelway and settling basins have been reconfigured to be within the landward side of the 50' stream buffer, and the project is not creating any impacts to the April 6, 2020 Page 7 stream or other environmental features of the property. The new plant will be substantially more protective of water resources than the existing plant that is over 50 years old, thus substantially reducing any risk of water contamination. The new plant will not have any impact on water capacity or availability. Objective 2: Protect air quality The new plant will be substantially more protective of air quality than the existing plant that is over 50 years old and that leaks dust because the metal is thin and patched. And the new plant is designed to contain the dust. Objective 3: Recognize the economic value of the County's mineral resources while giving due consideration to the potential harm mineral extraction activities and byproducts can have on human health and property values. This SUP application successfully balances these two goals, in that it would enable the existing plant to be replaced with new and more modern equipment, which will support the existing business activity of producing the asphalt from the existing mineral resources, without creating any harm or byproducts that would impact human health or property values. In fact, the proposed replacement plant will significantly reduce risks to human health and property values by replacing old, noisy, and dust -generating equipment with new equipment that is quieter, newer, cleaner, energy -efficient, and far more protective of environmental resources. Objective 4: Protect the biological diversity and ecological integrity of the County in both the Rural Area and Development Areas. This SUP application will enable the existing plant to be replaced with new and more modern equipment, In addition, because the plant is not proposing to materially expand the footprint of its over 50-year operations, the application will not have any impact on any new areas, including those with any significant biological diversity. The project merely proposes to replace old equipment with new and more modern equipment in the exact same location. Objective 6: Retain and improve land cover near rivers and streams and protect wetlands The proposal does not involve clearing any additional land area at all, nor will it have an impact on any wetlands areas. It is merely proposing to replace old, outdated equipment with more modern and environmentally protective equipment in the exact same location where it has existed for over 50 years. Objective 7: Protect residents and properties from damage that can be prevented when natural hazards are present. April 6, 2020 Page 8 This proposal will protect residents and properties by replacing old outdated equipment with new equipment that will result in less noise and dust than the existing equipment, and will not create any impacts on air or water quality. Zoning 1. The application narrative notes that the Red Hill Plant is located on 5.6 acres of the larger 579-acre parcel pursuant to the lease of the area with Martin Marietta Materials, Inc. However, the Site Data on sheet 1 of the Special Use Permit concept plan shows the Special Use Permit area as 4.4 acres. Bring these numbers into agreement or specify if the lease area is not the size of the requested area of the Special Use Permit. The total lease area is 5.6 acres and located on TMP 88-18 (4.4 acres) and TMP 88-13B (1.2 acres). At this time, TMP 88-13B is not located within the Natural Resource Extraction Overlay (NR) district. The SP request is only for the portion of the lease area that is located within the NR district, the 4.4 acres located on TMP 88-18. The SUP narrative has been revised to clarify this issue. The applicant's proposal to replace the existing S.L. Williamson Company, Inc. asphalt plant on TMP 08800-00-00-01800 requires the following considerations: Impacts to Roads. The applicant has asserted that the plant replacement will not increase the number of vehicular trips and will not result in any traffic changes. That is correct. ii. Performance Standards. The project must adhere to performance standards in section 18-4.14. A certified engineer's report will be required as a condition of approval of the Special Use Permit. Acknowledged, thank you. iii. Development in the water protection ordinance 100-foot stream buffer. The submitted concept plan shows the creation of a road well within the 100-foot stream buffer. While staff appreciates the use of a circular turnaround to avoid the noise of trucks backing up, development within the stream buffer is prohibited, and the installation of the road is not permitted. As noted previously, the travelway has been reconfigured to be in the landward 50' of the stream buffer. The settling basins have also been relocated to be in the landward 50' of the stream buffer. iv. Development in the 100-year floodplain. The concept plan titled "Proposed Layout Plan Special Use Permit SL Williamson Asphalt Plant @ Red Hill Quarry," shows an adjusted 100-year floodplain per a currently unapproved LOMR. The existing entrance road does still cross through his adjusted 100-year floodplain. The April 6, 2020 Page 9 currently existing road within the floodplain may not be further disturbed or developed. Acknowledged, thank you. v. Parking, lighting, appropriateness of use. The currently proposed plan satisfies these elements. Acknowledged, thank you. 3. Suggested conditions of approval will likely include: i. SP201900009 shall be developed in general accord with the concept plan titled "Proposed Layout Plan Special Use Permit SL Williamson Asphalt Plant @ Red Hill Quarry," with the layout changes recommended by staff. The Zoning Administrator may approve revisions to the concept plan to allow compliance with the Zoning Ordinance; The Applicant is agreeable to this proposed condition. ii. Approval of the special use permit is contingent on the acceptance and approval of an Letter of Map Revision (LOMR) or Letter of Map Amendment (LOMA) to the County's 100-year floodplain map to remove the plant and all its associated construction and land disturbance from the 100-year floodplain; The Applicant is agreeable to this proposed condition. iii. Use of the asphalt plant authorized by this special use permit shall expire when the adjacent quarry is no longer in operation; The Applicant cannot agree to this proposed condition. In the unlikely event that Martin Marietta were to close the adjacent quarry, S.L. Williamson would still need to operate at this location. The Company would bring in material from off - site in such event, and cannot have its ability to legally operate be dependent upon the business of another that it has no control over. iv. Hours of operation of the asphalt plant shall be between 7:00 a.m. and 10:00 p.m., Monday through Saturday, provided that for no more than sixty days per year, the hours of operation may be between 7:00 a.m. and 12:00 a.m., Monday through Saturday; As noted previously, the Applicant cannot agree to a condition of approval limiting operating hours. This plant has been operating 24 hours a day, 7 days a week, for over 50 years, and the ability to operate as such is critical to the business. Furthermore, the company has numerous large contracts with the Virginia Department of Transportation to provide asphalt for public roads in the County and surrounding region. VDOT requires that re -paving work to be carried out after-hours to minimize the impact on the travelling public, which thus requires April 6, 2020 Page 10 the asphalt to be made at the plant after hours, including between the hours of 10:00 pm and 7:00 am, and including on Sundays. v. Sound/noise barriers and attenuation measures will be provided as necessary to comply with the County's noise ordinance (section 18-4.18); Enclosed is a report from Bill Yoder, a sound scientist with Acentech, a sound consultant for the project, dated April 3, 2020, which concludes that the sound levels from the new plant will be equal to or less than the levels from the existing plant, and that based on a conservative model, the sound levels are likely to comply with the County noise ordinance. vi. Plant site lighting will comply with the County's outdoor lighting ordinance (section 18- 4.17). The Applicant is agreeable to this proposed condition. vii. Height of the asphalt plant and all associated structures will be limited to 80 feet. The Applicant is agreeable to this proposed location. 4. The supporting documentation for the authorized signatories are: (1) for a board of directors, the articles of incorporation or a shareholders agreement may limit the board's statutory authority (Virginia Code § 13.1-673); (2) for a person expressly authorized by the board of directors, written evidence of that authorization, such as a board resolution or board minutes; (3) for a committee, an action of the board of directors authorizing the committee to act; the articles of incorporation or the by-laws may limit the statutory authority (Virginia Code § 13.1-689); (4) for a corporate officer, the by-laws or the delegating resolution of the board of directors (Virginia Code § 13.1-694). Acknowledged, thank you. We believe that the materials we submitted with our original application satisfies these requirements based on the County accepting the application as complete, but please let me know if there is any additional documentation you require. Engineering 1. If this activity results in greater than 10,000 sf of land disturbance, a VSMP application will be required [Chapter 171. If a VSMP application is required, Section 17-600 (stream buffers) applies and a 100-ft stream buffer is required to be retained if present and established where they do not exist. Please identify the total area of land disturbance on the application plan. If this exceeds 10,000 sf, the layout will need to be modified to be no closer than 50-ft of the stream [17-604.A] (assuming impacts to the outer 50-ft is required to allow reasonable use of the lot), mitigation will be required for impacts to the outer 50-ft of buffer, and the inner 50-ft buffer will need to be established. April 6, 2020 Page 11 The travelway has been reconfigured to be in the landward 50' of the stream buffer. The settling basins have also been relocated to be in the landward 50' of the stream buffer. 2. Floodplain limits will need to be revised prior to approval. Acknowledged. Fire and Rescue: Fire Rescue has no objections to the special use permit application. Adequate emergency apparatus access must be maintained. Acknowledged, thank you. Access to the plant for emergency apparatus will be maintained. Should you have any questions or comments regarding the responses contained in this letter, or regarding any aspect of the updated Concept Plans or other enclosed materials, please do not hesitate to contact me at 951-5709. Sincerely, Valel-ie Al Zalr(g Valerie W. Long Enclosures: 1. Updated Concept Plan (5 sheets) 2. Colored version of Concept Plan (1 sheet) 3. Updated SUP Narrative 4. Sound Study by Acentech Cc: Blair Williamson, S.L. Williamson & Company Ammy George, Roudabush, Gale & Associates 42306862_1 August 19, 2019 Revised: April 6, 2020 S.L. Williamson Company —Replacement Asphalt Plat at Red Hill Quarry A. PROPOSAL: S.L. Williamson is a third -generation asphalt paving and road construction company. It produces plant mix asphalt in three asphalt plants located near Charlottesville, two of which are located in Albemarle County. One location is at the Luck Stone Quarry in Shadwell, and the other is at the Martin Marietta quarry at Red Hill off of Red Hill Road. The Red Hill plant is located on tax map parcel 88-18, on a 4.4-acre portion of the larger 579-acre parcel (the "Property"), pursuant to a lease with Martin Marietta Materials, Inc., the owner of the Property that comprises the Red Hill Quarry. The 4.4 acre area that is subject to the SUP is part of a larger lease area that also includes a 1.2-acre portion of tax map parcel 88-13B, which is also owned by Martin Marietta Materials, Inc. The precise boundaries of the Property is shown in detail on the enclosed Concept Plan prepared by Roudabush, Gale & Associates dated August 19, 2019, revised December 17, 2019 (the "Concept Plan"). The Property is zoned Rural Areas and Natural Resource Overlay District, and within Rural Area 4 of the Comprehensive Plan. The property also has areas that are zoned Flood Hazard Overlay District. The existing plant has been in the current location since 1969 and has reached the end of its useful life and must be replaced. The existing plant will be removed, and a new drum mix plant will be installed in its place, in the same location. The existing use is a legal non -conforming use, but after several meetings with the Applicant, Community Development Staff have determined that a Special Use Permit is necessary to replace the existing plant in the same location. The proposed new drum mix plant will be similar to the S.L. Williamson operation at the Shadwell Luck Stone Quarry. By replacing the existing plant with a modern facility, it will enable this long- time thriving local business to continue serving its customers in the Charlottesville/Albemarle County region, including the Virginia Department of Transportation, in addition to its numerous private sector customers. This will support and enhance economic development in the County, and have immeasurable benefits to all of the Company's public and private sector customers in the County, consistent with the Comprehensive Plan. B. CONSISTENCY WITH THE COMPREHENSIVE PLAN The Property is located in the Rural Areas 4 of the Comprehensive Plan. Among the goals of the Rural Areas is protected natural resources. An Objective of the Natural Resources plan is to recognize the economic value of the County's mineral resources, will giving due consideration to potential harm on human health and property values. By locating the replacement plant in the same location as the existing plant, no adverse impacts on adjacent properties or property values will be created, nor will the use change the character of the area. The proposal will also further the Comprehensive Plan goals in the Natural Resources Plan to protect air and water quality by utilizing more modern equipment. As such, the proposed SUP and replacement asphalt plant will enable the Applicant to recognize the economic value of the County's mineral resources, support its existing business, better serve its customers, and avoid any impact on adjacent properties or environmental resources. This is August 19, 2019 Revised: April 6, 2020 consistent with the Comprehensive Plan, including the Land Use Plan, the Natural Resources Plan, and the Economic Development Plan. C. IMPACTS ON PUBLIC FACILITIES AND INFRASTRUCTURE: The proposed project will not have any negative impacts on public facilities or public infrastructure. The Property is currently used for an asphalt mixing plant, and the proposed new plant will be the exact same use, but with more modern equipment that will increase public safety, minimize noise, and have a reduced environmental impact. No additional vehicular trips are proposed, and no additional land disturbance are proposed. Furthermore, no additional traffic changes are proposed. D. IMPACTS ON ENVIRONMENTAL FEATURES The proposed project will not have any negative impacts on environmental features. The Property is currently used for an asphalt mixing plant, and the proposed new plant will be the exact same use, in the same location, but with more modern equipment that will increase public safety, minimize noise, and have a reduced environmental impact. No additional vehicular trips are proposed, and no additional land disturbance are proposed. The existing plant is located within the 100-year floodplain per the FEMA 100-year from FIRM panel 51003C0405D. Roudabush, Gale & Associates, the project engineers, has performed a floodplain study using HEC-RAS to determine the extent of the 100-year Floodplain in the area of the creek that is located to the west of the existing plant. Pursuant to the updated floodplain study, the existing plant and associated buildings are located outside of the floodplain. Representatives of Roudabush Gale & Associates have been consulting with the County Engineer on the timing of the SUP application and a planned amendment to the floodplain maps in the form of a Letter of Map Revision ("LOMR"). The LOMR is likely to be complete prior to the Board of Supervisors hearing on the SUP, such that it will be clear after the LOMR that the new plant will be outside of the floodplain. While a certified engineers report was requested to be submitted with the SUP application, we request that this be an item that can be submitted as a condition of site plan approval, or with the initial site plan application. That was a condition of approval of the SUP for the replacement plant at SL Williamson's facility at the Luck Stone Quarry in Shadwell (SP 2006-0023). 40658549_2 2 };10 ACENTECH April 3, 2020 Blair Williamson S.L. Williamson Company, Inc. 1230 River Road Charlottesville, VA 22901 blairftslwilliamson.com Subject Sound Level Predictions Red Hill Asphalt Plant, Albemarle County, VA Acentech Project No. 632575 revision 2 Dear Ms. Williamson: s� C� 2150 Wise Street #4875 < < ' Charlottesville, VA 22905 434 218 0759 acentech.com ) Y44i We have completed our sound level survey of the asphalt plant at your Red Hill location. This report outlines the details of a small set of sound level measurements taken at the existing plant, an acoustical model of the proposed plant, and a brief comparison of the existing and proposed sound levels. EXECUTIVE SUMMARY Based on the results of our measurements and analysis, predicted sound levels due to the proposed new equipment at your Red Hill asphalt plant are expected to be equal to or lower than the plant's current equipment. Our predictions are shown in Figure 2 as a noise contour map, where color bands represent bands of sound level. These predictions indicate that the sound levels may be 1 - 2 dBA above the nighttime noise ordinance at a small portion of property line boundaries during asphalt production operations. First, note that 1-2 dBA is not considered perceptibly' different by humans. Second, note that our model generates conservative predictions such that it is likely that the actual sound levels generated from the new plant will comply with the daytime and nighttime noise ordinance limits. A brief glossary is included at the end of this letter. BACKGROUND Background Info We understand that you lease the land for your asphalt plant site from Red Hill Quarry, which is owned by Martin Marietta. We also understand that the parcel directly adjacent to the west of the asphalt plant parcel is also owned by the quarry, making the nearest abutter the Red Hill Church. You and your staff have also shared with me that the current equipment at the Red Hill asphalt plant is very old, noisy, requires frequency maintenance, and cannot be automated. In contrast, the proposed Gencor Ultraplant is supposed to be new, quieter, relatively maintenance free, and capable of being fully automated. Albemarle County Noise Ordinance The Albemarle County code includes regulations for noise 2, which outline the necessary equipment, measurement procedure, and performance standard that must be met. Table 1 shows the performance ' Regarding human perception, a sound level change of 2-3 dB is considered just noticeably different, 5 dB is clearly louder, and 10 dB is considered twice as loud. 2 Albemarle County Code, Chapter 18, Section 4.18 acoustics , av/it/security I vibration S.L. Williamson Company, Inc. April 3, 2020 Page 2 of 5 standards (the maximum allowable sound level at the property line) based on the zoning of the abutting receiver (the "receiving zone" property line) . Note that these performance standards are defined as a five-minute A -weighted equivalent continuous (energy -average) sound pressure level, known as LAeq. The abutting neighbors all fall under the rural zoning type and will require you to meet the most stringent performance standards for all periods of operation, 60 dBA during the day and 55 dBA at night. TABLE 1: ALBEMARLE COUNTY RECEIVING ZONE MAXIMUM AVERAGE SOUND LEVELS Maximum Sound Pressure Level (LAeq, dBA) by ■ Receiving Zone Time of Day Rural, Residential, Commercial Industrial Public Daytime (7AM — 10PM) 60 65 70 Nighttime 10PM — 7AM 55 65 70 Note that all sound measurements reported in this report were made using an ANSI S1.4 Type 1 compliant Sound Level Meter with current laboratory and field calibrations. SOURCE LEVELS Modeling Process We use a software package called CadnaA to build a model, predict noise levels, and both tabulate and graphically present that data. CadnaA is a widely recognized and accepted noise propagation modeling software that follows ISO 9613-2 3. You have provided us information vital to acoustically modeling the future asphalt plant, including the proposed layout of the plant and the Gencor Ultraplant Sound Level Readings reference. We also used topographic information to aid in predicting spreading, ground absorption, shielding, and diffraction. Because of how the reference sound level readings are reported by Gencor, in an everything operating at once condition, the prediction model is more conservative since any reference sound level may be influenced by more than one piece of equipment and likely does not have omnidirectional sound. This means that the predictions from the model will likely overestimate the sound level due to the plant at any given location, though we cannot say by how much without significant additional information or sound testing from Gencor. Atmospheric attenuation of sound is somewhat influenced by temperature and relative humidity, but does not have a large impact on our results. This is because lower frequencies and higher frequencies do not behave the same for a given set of conditions. Landscaping such as trees and bushes were excluded from the model since the effects of these objects would be relatively small and the predictions less accurate due to sparsity and seasonal variations. Note that the exclusion of ground cover from the model, even though it actually exists in the area around the asphalt plant, also makes the predictions more conservative. In the model, we have ignored temperature inversions, wind speed, and wind direction. These variables require meteorological data specific to the site and further complicate the predictions. A review of typical weather conditions for the region on Weather Spark shows a low average wind speed of around 3 — 5.5 mph. ISO 9613-2 states that a correction factor for wind of this speed is typically very small and around 0 3 International Standards Organization 9613-2, Attenuation of Sound during Propagation Outdoors. 4 https://weatherspark.com/y/20225/Average-Weather-in-Charlottesville-Virginia-United-States-Year-Round#Sections-Wind 41100� ACE NTECH S.L. Williamson Company, Inc. April 3, 2020 Page 3 of 5 — 2 dBA, which is not considered perceptibly different. Any applicable correction factor would increase the predicted sound level when the receiving location is downwind, and decrease the predicted sound level when the receiving location is upwind. Since the applicable correction factor would be small, imperceptible, and based on wind direction, it has not been included in our model. This means that our model, and predictions, generally represent the wind conditions expected for this region. Relative Sound Levels Table 2 shows measured and predicted sound levels at six locations near the asphalt plant. Figure 1 shows each of these measurement locations relative to the proposed plant. These locations were chosen to support the development of the predictive model and to show predicted changes between existing and proposed plant sound levels. These locations were not chosen to show compliance with the noise ordinance, as the noise contour map will provide a more complete view of sound level at any given location. The measured sound levels were due to operations of the current plant during the mid -morning hours of November 21, 2019. The predicted sound levels were generated using our CadnaA model of the proposed plant, following the details defined above. TABLE 2: SOUND LEVELS OF EXISTING AND PROPOSED PLANTS Sound Pressure Level, Sound Pressure Level, Predicted Change Measurement Position Existing Plant Proposed Plant with Proposed Plant Measurements Predictions 1 Directly in Front of Plant 77 dBA 72 dBA -5 dBA 2 Angled from Plant 65 dBA 64 dBA -1 dBA 3 At Plant Entry 61 dBA 61 dBA 0 dBA 4 Red Hill Church 65 dBA 56 dBA -9 dBA 5 NW Residential 51 dBA* 42 dBA N/A due to Ambient 6 Western Residential 49 dBA* 41 dBA N/A due to Ambient * The asphalt plant was inaudible and these measurements represent the ambient sound level The predicted sound level at each location in Table 2 is equal to or lower than the measured sound level at those same locations. Locations 1 through 3 were nearest the plant and actually on the plant site, while locations 4 through 6 are on or outside the plant's property line boundary, or adjacent to a road. Note that we were unable to predict the change at locations 5 and 6 because the ambient sound level was higher than the plant sound level at those locations, masking plant noise, making it inaudible and unmeasurable. Ambient noise at all measurement locations was apparent and due largely to road noise from US Route 29 and Red Hill Road. Other expected sources of occasional ambient noise include additional transportation noise, such as from rail and flight traffic. Noise Contour Maps A noise contour map is a way of graphically representing the sound level of a particular site. They allow the reviewer to quickly determine the approximate sound level at any given location, and determine compliance or impact at those locations. In our model, the sound levels on the noise contour maps are calculated on a 5-meter x 5-meter grid at a height of 1.5 meters. Sound levels are represented by bands 41;1;f�►ACENTECH S.L. Williamson Company, Inc. April 3, 2020 Page 4of5 of color that indicate a range of sound levels. For our purposes, each color band represents a 5 dBA range. It is possible to further refine the map to show finer steps and ranges, but interpreting the data becomes more difficult when interpreting smaller color shifts and additional color contours. Figure 2 shows the predicted noise contour map generated by the CadnaA model. This figure should allow you, or the county, to quickly determine the predicted sound level at any location shown within the contour map. To identify the approximate sound level at any given location, observe the color and reference the legend. The southern property boundary is shown to be almost entirely below 55 dBA, save a small section where the boundary jogs further north towards Red Hill Road where the property line has a predicted sound level of around 57 dBA. The site's western boundary at Red Hill Church has a predicted sound level of around 56 dBA at that boundary's loudest point. The northern and eastern boundaries to non -Martin Marietta properties are predicted to be well below the noise ordinance limits. CONCLUSIONS The proposed plant is predicted to have sound levels equal to, or lower than, the existing plant. This is demonstrated in Table 1 and Figure 2. In reviewing Figure 2, note that the color band at most boundaries are tan or green in color, which indicates that the predicted sound level is below 55 dBA, and thus in compliance with both the daytime and nighttime limits of the noise ordinance. The places where the conservative model predicts sound levels to exceed the nighttime noise ordinance limit are mostly at portions of the Red Hill Church boundary and a small section of the site's southern boundary near Red Hill Road. However, the sound level predictions produced by the noise model are conservative and likely overestimate the sound levels that will actually be generated by the new equipment. Due to this, the new equipment may actually meet the noise ordinance at all regulated locations, even at the couple of locations that are predicted to exceed the nighttime limit, since the predicted exceedance at those locations is on the order of only 1 - 2 dBA. I hope this letter provides you with the information that you need at this time. If you have any questions, please feel free to contact me at byoder(a�acentech.com or 434.218.0759. Sincerely, Acentech Incorporated Bill Yoder Senior Staff Scientist Encl: Glossary of Acoustical Terms Figures 1-2 411(0� ACENTECH S.L. Williamson Company, Inc. April 3, 2020 Page 5 of 5 Glossary of Acoustical Term - We understand that acoustic terminology may be confusing. The following is a brief glossary of some acoustical terms used in this report that you may find useful. Ambient Sounds The sounds due to environmental, traffic, or other nearby sources that are unrelated to the source(s) being measured or characterized. dB = decibels, dBA = decibels, A -weighted Decibels (abbreviated dB) are used to measure the relative loudness of sound, based on a logarithmic scale. For reference, normal human speech is in the range of 65 decibels, painful rock music may be more than 110 decibels, while aircraft noise may be as loud as 130 decibels. A -weighting filters the sound in a way that is similar to human hearing, and hence dBA levels are often referenced in various acoustical standards. Note that a 10dB increase in sound is associated with a perceived doubling in sound level. Leq, LAeq The equivalent continuous sound level, or energy -average sound level, over a defined measurement period. Note that the instantaneous sound level may be higher or lower during the measurement period LAeq is the A -weighted version of the equivalent continuous sound level. Omnidirectional Sound radiation characterized by equal spreading in all directions. Propagation Loss A reduction of sound energy due to distance. This may include attenuation due to the atmosphere, the ground, natural or manmade barriers, and spherical spreading. Sound Pressure Level This is the level used to characterize the loudness of a sound at a specific location. 4-!.( 4►ACENTECH RURAL RESIDENTIAL pncifinn R / I Existing: 51 dBA* �/ Predicted: 42 dBA 0 ; MARTIN MARI ETTA , Position 6 Existing: 50 dBA* Predicted: 41 dBA r--------------------------------------- ::-CROWN- ORCHARD -COMPANY. ----------- RED HI«; CHURCH Pnci+inn d Existing: 65 dBA Predicted: 56 dBA SL Williamson Asphalt Plant @ Red Hill Quarry Sound Level Comparison of Existing Sound Levels and Predicted Sound Levels after Proposed Plant Changes * - At some locations the asphalt plant was inaudible and these measurements represented the ambient sound MARTIN MAR I ETTA I eve 1. Position 2 --------- _________________ Existing- 65 dBA Predicted: 64 dBA ;MARTIN MARI ETTA' ; --------------------------------- :MARTIN MARIETTA ------------------------------------- Position 3 Existing- 61 dBA Predicted: 61 dBA Position 1 Existing: 77 dBA Predicted: 72 dBA :RURAL RESIDENTIAL ----------------------------------- ���0(0� &CS AWITi5ECl1RITE VIBRATION RURAL RESIDENTIAL (0 0 O ARTIN MARIETT 1FftfqHILL MARTIN C RICH V 4 CROWN ORCHARD COMPANY MARTIN MARIETrA Q ,,R(ETTA 2 MARTIN MARIETTA� 4 1 a� 3M, 0 0 RURAL RESIDENTIAL F,-] '7 0 A SL Williamson Asphalt Plant @ Red Hill Quarry Noise Contour Map of Proposed Plant Changes. Pred'cted Sou-�c: Level Comparison Position Existing Predl cted 1 77 dBA 72 dBA 65 dBA 64 dBA 3 61 dBA 61 dBA 4 65 dBA 56 dBA 5 51 dBA` 42 dBA C 49 dBA` 41 dBA * - At some locations the asphalt plant was inaudible and these measurements represented the ambient sound level. <35dBA 35 dBA - 40 dBA 40 dBA - 45 dBA 45 dBA - 50 dBA 50 dBA - 55 dBA 55 dBA - 60 dBA 60 dBA - 65 dBA 65 dBA - 70 dBA 70 dBA - 75 dBA 75 dBA - 80 dBA > 80 dBA ,'0 CSEYN T�E VIBRATION