HomeMy WebLinkAboutSP202200014 Review Comments Appeal to BOS 2022-07-18County of Albemarle
\;. Community Development Department - Planning Division
July 18, 2022
Ms. Valerie Long
Williams Mullen
323 Second Street SE, Suite 900
Charlottesville VA 22902
Scott Clark
sclark@al bemarl e.o rx
tel: 434-296-5832 ext. 3249
fax:434-972-4126
RE: SP202200014 Woodridge Solar Substation, SP202200015 Woodridge Solar, SE202200035 Woodridge Solar
Dear Ms. Long:
Your client's applications, listed above, have been reviewed by members of Albemarle County staff and our partner
agencies. Review comments are provided below, organized by Department, Division, or agency.
Plannine (Scott Clark)
SP202200014 Woodridge Solar Substation
o Please clarify or add to the substation layout(s) shown on sheet C5.0 of the conceptual plan.
• Are both the proposed "Project Substation" and "Dominion Substation" to be built within the same
substation envelope shown on the conceptual plan? Please show the overall layout of all proposed
facilities.
• Please provide information (at least estimates) on:
• Structure heights
• Footprint of surfaced vs. vegetated area
• Impervious area
• Noise generation of transformers or other equipment
SP202200015 Woodridge Solar
o Overall/Site Layout
• A portion of the applicant's presentation at the community meeting suggested that the proposed area
of disturbance and/or panel locations in the northwestern portion of the site would be reduced or
removed. Please show this and any other layout changes on a revised conceptual plan.
• If parcel 114-51 or any other parcels will not be included in the area of disturbance for the site, or
used for access, we recommend that they be removed from the application and not shown as part of
the project on the revised conceptual plan.
• Please provide a phasing plan for construction of the site, to demonstrate the areas that would under
construction and active erosion control at any given time.
• The GIS data provided by Timmons shows that, on the eastern edge of parcel 114-69, a segment of
Water Protection Ordinance buffer (purple area in image below) falls within the Limits of
Disturbance. Please revise the conceptual plan to avoid use or disturbance of this area.
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• In addition to the standard plan submittals, please provide revised site layout information as GIS
data.
o Grading and Soil
• Soil conditions and grading are a significant element of concern with this application. Unlike sites in
the lower Piedmont or the Coastal Plain, this site appears to require very extensive grading for the
creation of slopes that would accommodate panel arrays. A large part of the justification for
permitting solar energy facilities is that soil productivity will be maintained. This degree of grading
raises concerns that soil productivity could be reduced by compaction and by distribution of subsoils.
Wherever possible, major changes in existing topography should be avoided, and the extent and
depth of grading should be reduced.
• The extent and depth of grading shown so far, and the apparent condition of the soils, raise concerns
for plant viability at the surface. Poor existing soils (including minimal/absent topsoil), the
distribution of acidic, low -nutrient subsoils near the surface during grading, and grading -related
compaction all raise concerns that new vegetation would have poor survival conditions. Please
submit a detailed soil remediation plan that addresses proposed plans for soil management (tilling,
ripping, etc., as well as topsoil banking during the grading phase, if viable topsoil exists) and soil
amendment (lime, phosphorus, etc.) to ensure that plantings would be viable. (This plan should also
address soils in portions of the 200-foot visual buffer where new plantings are proposed.)
• From discussions during the review period, we understand that the submitted grading plan (showing
over 488,000 cubic yards of soil importation) does not accurately reflect the intended site work, and
that the intent is to balance the site and avoid importing fill. Staff cannot form a recommendation on
this application until a grading plan reflecting the applicant's actual intentions has been submitted.
We recommend that the site be designed to avoid soil exportation or importation.
• More detailed information on the characteristics of the soil on the site is needed. Given the history of
the site, typical soil profiles (topsoil, subsoil, saprolite) cannot be assumed to exist, and cores or
profiles are needed to understand how soil redistribution would affect the site.
• Normally, staff would recommend that the grading plan include the stockpiling and later
redistribution of topsoil. However, we do not currently have enough information to evaluate
the availability or suitability of topsoil on the site.
• Ideally, the revised grading plan and new soil-remediation plan would be developed in consultation
with experts in soil remediation and/or plant establishment on disturbed/graded sites, and would
incorporate their recommendations.
o Vegetation and Plantings
• Please see the Natural Resource Manager's attached comments regarding seed mixes and preference
for native species. Also, please provide verification that the volumes of seed needed for this site can
be provided by suppliers.
• Please explain how grading and construction would be timed so that planting of new vegetation
would be timed to maximize success in plant establishment.
• Although some management guidelines are provided in the conceptual plan, more details and logistis
are needed. Please provide a detailed vegetation management plan for the life of the facility that
specifies what maintenance activities will be carried out during each phase of the facility's
operations; who will be responsible for maintenance activities and for repair/replanting of damaged
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or poorly -performing areas; the frequency of on -site activities by responsible parties; and who the
County would work with to remediate any failures to maintain the proposed on -site vegetation.
• Is any vegetation management or restoration proposed within the 100-foot Water Protection
Ordinance Buffers or floodplains on the site? We recommend that any cleared areas within those
buffers be replanted with native hardwood species.
o Decommissioning
• The decommissioning plan refers to topsoil cover. Would this topsoil be obtained from the site
(implying that existing vegetation planted for this use would be lost), or would it be imported from
elsewhere?
• Section 7.4(8) refers to topsoil stockpiling and use of stockpiled soil to replace the removed roads.
How is this affected if the site does not include topsoil to be stockpiled? If topsoil is present, how
would it be protected from loss/erosion during the expected 40-year life of the project?
• Points regarding revegetation of cleared site areas in 7.4 should be reflected in the actual
decommissioning plan in section 4.
o Other Matters
Please address water use (for cleaning, etc.), and whether or not new wells would be needed.
The application proposes a six-inch gap under the fences for small -wildlife passage. What is the
expected fence height?
The following matters were raised by nearby landowners. We recommend that the applicants address
these issues in a revised narrative, in order to inform the public. A list of sources for reference
material would be helpful.
• EMF/magnetic field impacts — field strength generated compared to other typical uses, and
the distances at which any EMF generated by photovoltaic panels decays to background
levels
• Heat island effects — temperature increases, and the distance at which they can be detected
• Impacts of the proposed use on the values of the surrounding properties.
• SE202200035 Woodridge Solar (critical slopes)
o Please seethe Engineering comments on this application. As noted above, until a more -accurate grading plan
is submitted, staff cannot provide a recommendation on this application.
Natural Resources (Kim Biasiolli)
• SP202200014/SP202200015: Please see attached memo.
Historic Preservation (Mar¢aret Maliszewski)
The project area is located within the Southern Albemarle Rural Historic District and retains a rural character, which is a
key element of the district's significance. The proposal should include sufficient measures to maintain the rural character
of the area throughout the life of the project.
1. Provide additional information to clarify the extent of visibility of the panels from off -site locations, including but
not limited to the Southern Albemarle Historic District.
2. Provide photo -simulations from additional viewpoints to illustrate the view from Jefferson Mill Rd.
3. Provide an overlay of the panel locations and the cultural resource probability areas for review.
4. Revise the diagram on page 7 of the narrative and sheet C6.1 of the plan to accurately reflect the location of buffer
elements within the 200' buffer (fence, meadow, forest, 20'-wide added screening). Revise the "Vegetative
Buffer" paragraph on page 6 of the narrative to more clearly describe the locations. Note that fence installed on
the "interior of the buffer" can be interpreted multiple ways.
5. The narrative states that vegetative buffering will be maintained throughout the life of the project. Does this
include the addition of screening over time as currently existing forest changes over time?
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6. Provide aerial photographs (from 2021 or later) or current vegetation -cover mapping of the site and use that
current information as the base map for a planting plan showing where the existing buffer will remain, and where
additional screening plants will be required. This planting plan should be shown at a more detailed scale than the
current single -sheet plan, and should be presented as multiple sheets with more detail, as with the format of the
current grading plan.
7. Limit the buffer plant list to native trees and shrubs.
8. Follow the recommendations of the Stantec cultural resources assessment.
Zonin¢ (Lea Brumfield)
• Zoning comments will be provided as soon as they are available.
En¢ineerina (Emily Cox)
• SP202200014/SP202200015: Please see attached memo.
• SE202200035: Please see attached memo.
VDOT
• SP202200014: Please see attached memo.
• SP202200015: Please see attached memo.
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.
If you choose to resubmit, please use the form at the following link. There is no fee for the first resubmittal. The
resubmittal date schedule will be provided on the County website.
Please contact me with any questions and/or requests for assistance you may have. I can be reached at
sclarkkalbemarle.org or 434-296-5832, ext. 3249.
Sincerely,
Scott M. Clcwkl
Scott Clark
Senior Planner II
Planning Division
enc: Action After Receipt of Comment Letter
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DEPARTMENT OF COMMUNITY DEVELOPMENT
ACTION AFTER RECEIPT OF COMMENT LETTER
Within 30 days of the date of this letter, please do one of the following:
(1) Resubmit in response to review comments
(2) Request indefinite deferral
(3) Request that your Planning Commission public hearing date be set
(4) Withdraw your application
(1) Resubmittal in Response to Review Comments
If you plan to resubmit within 30 days, make sure that the resubmittal is on or before a resubmittal date as published in
the project review schedule. The full resubmittal schedule may be found at www.albemarle.oin the "forms" section
at the Community Development page. Be sure to include the resubmittal form on the last page of your comment letter
with your submittal.
The application fee which you paid covers staff review of the initial submittal and one resubmittal. Each subsequent
resubmittal requires an additional fee. (See attached Fee Schedule.)
(2) Request Indefinite Deferral
If you plan to resubmit after 30 days from the date of the comment letter, you need to request an indefinite deferral.
Please provide a written request and state your justification for requesting the deferral. (Indefinite deferral means that
you intend to resubmit/request a public hearing be set with the Planning Commission after the 30 day period.)
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(3) Request Planning Commission Public Hearing Date be Set
At this time, you may schedule a public hearing with the Planning Commission. However, we do not advise that you go
directly to public hearing if staff has identified issues in need of resolution that can be addressed with a resubmittal.
After outstanding issues have been resolved and/or when you are ready to request a public hearing, staff will set your
public hearing date for the Planning Commission in accordance with the Planning Commission's published schedule and
as mutually agreed by you and the County. The staff report and recommendation will be based on the latest
information provided by you with your initial submittal or resubmittal. Please remember that all resubmittals must be
made on or before a resubmittal date.
By no later than twenty-one (21) days before the Planning Commission's public hearing, a newspaper advertisement fee
and an adjoining owner notification fee must be paid. (See attached Fee Schedule) Your comment letter will contain the
actual fees you need to pay. Payment for an additional newspaper advertisement is also required twenty-two (22) days
prior to the Board of Supervisors public hearing. These dates are provided on the attached Legal Ad Payments for Public
Hearings form.
Please be advised that, once a public hearing has been advertised, only one deferral prior to the Planning Commission's
public hearing will be allowed during the life of the application. The only exception to this rule will be extraordinary
circumstances, such as a major change in the project proposal by the applicant or more issues identified by staff that
have not previously been brought to the applicant's attention. As always, an applicant may request deferral at the
Planning Commission meeting.
(4) Withdraw Your Application
If at any time you wish to withdraw your application, please provide your request in writing.
Failure to Respond
If we have not received a response from you within 30 days, we will contact you again. At that time, you will be given 10
days to do one of the following: a) request withdrawal of your application, b) request deferral of your application to a
specific Planning Commission date as mutually agreed to with staff, or c) request indefinite deferral and state your
justification for requesting the deferral. If none of these choices is made within 10 days, staff will schedule your
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application for a public hearing based on the information provided with your original submittal or the latest submittal
staff received on a resubmittal date.
Fee Payment
Fees paid in cash or by check must be paid at the Community Development Intake Counter. Make checks payable to the
County of Albemarle. Do not send checks directly to the Review Coordinator. Fees may also be paid by credit card using
the secure online payment system, accessed at
http://www.a lbemarle.org/department.asp?department=cdd&relpage=21685.
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401 McIntire Roadl Charlottesville, VA 22902-4596
County of Albemarle
\;. Community Development Department - Planning Division
MEMORANDUM
TO:
Scott Clark
FROM:
Kim Biasiolli
RE:
SP-2022-00015: Woodridge Solar
DATE:
June 30, 2022
KIM BIASIOLLI
kb iasiol I i @al bemarle.orx
tel: 434-296-5832 ext. 3325
fax:434-972-4126
The following comments are provided to encourage the design of a development that protects important natural resources
identified within and adjacent to the site. General comments as well as specific recommendations on the narrative and plan
(first submittal) are included.
1. Veeetation Management
A. Virginia Pollinator -Smart Solar Industry Certification is recommended, including following the guidelines in the
Pollinator -Smart Comprehensive Manual for site suitability analysis, vegetation management plan, installation,
monitoring, and adaptive management.
B. Please described how the vegetation management plan will implemented and updated to respond to changing site
conditions over the life of the project.
C. Species selection for vegetative buffer and groundcover plantings should be based on the site conditions (soil type,
moisture, light availability). Native species are recommended as they are more likely to be well suited to the local
site conditions and will maximize co -benefits for biodiversity.
D. Vegetative Buffer - Property Line 200' (Narrative p 6&7)
i. Within the 200' setback, the narrative describes a forest section with a minimum of 100' of mature existing
vegetation. Please show the minimum 100' of mature existing vegetation on the diagram (page 7 of the
narrative and on Sheet C6.1 on the plan), between the property line and the inner 100' of buffer.
ii. The diagram shows 80' of pollinator meadow with a 20' planting strip for the inner 100'. Please reduce the
width of the pollinator meadow to the minimum width necessary to prevent shading of the panels and replace
with mature existing vegetation (if it exists onsite) or an expanded planting strip of native trees and shrubs.
iii. Recommended Buffer Plant List on Sheet C6.1. Please use native and site appropriate species. Technical
experts can provide site specific species recommendations, and the County's Native Plant Database can be
used to select site -appropriate native trees for the landscaping plan. Adding more native woody species to the
list for additional diversity in the planting strip is recommended. Hardwood species such as native oaks would
maximize benefits for biodiversity and may not need to be evergreen (for the inner 100' of the 200' setback).
➢ Tsuga canadensis (Eastern hemlock) -native but not recommended due to the extensive dieback of
hemlocks in our area from the hemlock wooly adelgid.
➢ Magnolia grandiflora and sweet bay magnolia are two different species; neither is native to Albemarle
County and these may not thrive in this soil type.
➢ Ilex glabra -not native to the Piedmont or Albemarle County. This species and Ilex verticillata typically
grow in very wet sites.
➢ Native evergreen replacement species might include Ilex opaca (American holly), Juniperus virginiana
(eastern red cedar), Kaimiaiatifoiia(mountain laurel).
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E. Groundcover plantings: Utilization of VA Northern Piedmont ecotypes wherever possible is recommended.
i. Solar Farm Seed Mix includes some non-native species and some that do not seem appropriate for locating
under panels due to their light requirements. Please use native, non-invasive species that are site appropriate.
A native dry woodland species mix can be created by Ernst, which may be more site appropriate and would
maximize benefits for biodiversity.
➢ Please remove non-native species: Festuca ovinavar. duriuscu/a (Hard Fescue 'Jetty' and Hard Fescue
'Gladiator'), Poa pratensis(Kentucky bluegrass), and Trifo/ium repens(White Clover, Dutch). Replace with
native species. P. pratensis and T. repensare also considered to be invasive species in the mid -Atlantic.
ii. VA Solar Pollinator Buffer Mix includes E. purpurea (non-native to Virginia), C. /anceo/ataand P. digitalis
(nativity uncertain), and B. austra/is(not native to the Piedmont). Recommend removing non-native species
and including 1-2 native So/idagospp.
iii. VA Northern Piedmont Detention Basin Mix includes appropriate species. However, there is a mix designed
for the same conditions that is used in County -owned detention basins (Albemarle Stormwater Mix).
F. Stream Buffers & Wetlands
The conceptual plan shows avoidance of Water Protection Ordinance Buffers and delineated wetlands. Please
describe any planned management of these areas. Active planting and restoration with native woody riparian
vegetation is recommended for areas that are currently open or impacted from the timber harvest operation.
2. Soil Conservat/on
A. Much of the project site includes soils mapped as prime farmland and farmland of statewide importance. The
narrative (p8) describes minimization of grading; however, the conceptual plan illustrates extensive grading on the
site. Removal, redistribution, and compaction of soils may impact natural vegetation growth, limit the viability of
proposed plantings, and influence the site's potential for future reversion to agricultural use.
i. Consider reducing the extent of grading on the site and avoid importation of foreign soil to the site.
ii. Consider extending panel height or other measures that work with existing topography to avoid soil impacts.
iii. A site suitability analysis is recommended, including soil analysis and prepping the site prior to planting based
on current conditions (soil pH, nutrient availability, etc.).
iv. Limiting and/or addressing soil compaction after construction and prior to planting is recommended.
V. Include decompaction and other soil remediation measures as part of the decommissioning plan.
3. Roads
A. Please distinguish between existing roads and proposed new internal roads on the conceptual plan.
B. Internal roads are shown between the rows of panels only in some locations. Please describe whether these roads
will be required between all of the blocks of panels, and if/how they will surfaced.
4. Lieht/ng (Narrative p 5&6)
A. Please provide more detail on the specific type of lighting proposed, and the frequency and timing of its use.
B. Outdoor lighting impacts can be minimized by:
i. Utilizing fully shielded fixtures;
ii. Ensuring all outdoor fixtures have a color temperature of 3000K or less; and
iii. Dimming and/or turning off outdoor lights between 10 PM - 5 AM.
5. D commiss/oninga/an(p121)
A. Please expand description of (6) Site Restoration to provide more detail. Extensive grading and compaction of soils
may impact the ability of the site to easily return to productive agricultural or forestal uses. Decompaction and
seeding is described but it is unclear whether the costs of these activities are accounted for in Table 7-1.
B. Please describe the process of removal and restoration of internal roads.
6. Chemical Use
A. Please describe how the panels will be cleaned.
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�$ County of Albemarle
m COMMUNITY DEVELOPMENT DEPARTMENT
Memorandum
To: Scott Clark
From: Emily Cox
Date: 07/05/2022
Subject: Woodridge Solar (SP202200015)
401 McIntire Road, North Wing
Charlottesville, VA 22902-4579
Telephone: 434-296-5832
WWW.ALBEMARLE.ORG
The Woodridge Solar Special Use permit has been reviewed by Engineering. The following comments
will need to be addressed before approval:
1. [Narrative Page 8] The section titled Streams, Floodplain & Wetlands says there will be
no impact, however, there will be some impact for the internal road
construction/upgrades at the stream crossings and for any stormwater outfalls. Please
revise to include this disturbance.
2. Please note that per 17-600, "The stream buffer shall extend to whichever of the
following is wider: (i) 100 feet on each side of any perennial or intermittent stream and
contiguous nontidal wetlands, measured horizontally from the edge of the contiguous
nontidal wetlands, or the top of the stream bank if no wetlands exist; or (ii) the limits of
the flood plain."
3. Floodplain development permit will be necessary and must be approved before land
disturbance permit will be issued.
4. A floodplain study (in accord with Zoning Ordinance section 18-30.3.13.C.l(a) will be
required prior to WPO plan approval.
5. [Sheet C 3.6] Please remove internal road from the buffer.
6. Please review all internal road locations. The roads do not appear to be shown to scale
per the detail on Sheet C 5.0 (16' wide) and some are very close to the buffer. Once built
to scale, they would disturb the buffer.
7. Please show the roads, buffers, floodplaln, wetlands and SWM facilities on the grading
sheets.
8. Do you intend to phase the construction? If so, please show the proposed phasing plan.
9. A WPO VSMP plan will need to be approved before the land disturbance permit can be
issued. Comments to note regarding this VSMP include:
a. Pre -development condition for the VRRM should be forested.
b. The outfall of the SWM facilities should be combined as much as possible to
limit disturbance to the buffers.
c. Energy balance must be used for concentrated outfalls into natural conveyance
systems.
10. Please describe how you will provide seed bed preparation to establish the proposed
grasses and plants. The soils appear to be poor soils with little infiltration (HSG D). For
example and requirements, see VESCH 3.32, permanent seeding.
�$ County of Albemarle
m COMMUNITY DEVELOPMENT DEPARTMENT
Memorandum
To: Scott Clark
From: Emily Cox
Date: 07/05/2022
Subject: Woodridge Solar (SE202200035)
401 McIntire Road, North Wing
Charlottesville, VA 22902-4579
Telephone: 434-296-5832
WWW.ALBEMARLE.ORG
The Woodridge Solar Critical Slopes Waiver has been reviewed by Engineering. The following
comments will need to be addressed before approval:
1. Is all disturbance necessary? For example, in a few locations it appears there could be a few less
panels and no disturbance to the critical slopes.
2. Please provide a proposed grading plan.
3. Please explain how slopes will be stabilized.
COMMONWEALTH of VIRGINIA
DEPARTMENT OF TRANSPORTATION
Stephen C. Brich, P.E. 1401 East Broad Street (804) 7862701
Commissioner Richmond, Virginia 23219 Fax: (804) 786.2940
June 21, 2022
County of Albemarle
Department of Community Development
401 McIntire Road
Charlottesville, VA 22902
Attn: Scott Clark
Re: Woodridge Solar Substation — Special Permit
SP-2022-00014
Review # 1
Dear Mr. Clark:
The Department of Transportation, Charlottesville Residency Transportation and Land Use
Section, has reviewed the above referenced plan as prepared by Timmons Group, dated 16 May
2022, and offers the following comments:
1. Black Branch Farm Rd is a private road and any entrance off this road will require proper
easements.
2. Sight -distance from Black Branch Farm Rd onto Jefferson Mill Rd appears to have
problems, and may cause problems for trucks leaving after delivering equipment and
materials.
3. Note that the final plan must show conformance with the VDOT Road Design Manual
Appendices B(1) and F, as well as any other applicable standards, regulations or other
requirements.
These plans appear to be generally acceptable. If further information is desired, please contact
Doug McAvoy Jr. at (540) 718-6113.
A VDOT Land Use Permit will be required prior to any work within the right-of-way. The
owner/developer must contact the Charlottesville Residency Transportation and Land Use
Section at (434) 422-9399 for information pertaining to this process.
Sincerely,
Doug McAvoy Jr., P.E.
Area Land Use Engineer
Charlottesville Residency
VirginiaDOT.org
WE KEEP VIRGINIA MOVING
COMMONWEALTH of VIRGINIA
DEPARTMENT OF TRANSPORTATION
Stephen C. Brich, P.E. 1401 East Broad Street (804) 7862701
Commissioner Richmond, Virginia 23219 Fax: (804) 786.2940
June 21, 2022
County of Albemarle
Department of Community Development
401 McIntire Road
Charlottesville, VA 22902
Attn: Scott Clark
Re: Woodridge Solar Farm — Special Permit
SP-2022-00015
Review # 1
Dear Mr. Clark:
The Department of Transportation, Charlottesville Residency Transportation and Land Use
Section, has reviewed the above referenced plan as prepared by Timmons Group, dated 16 May
2022, and offers the following comments:
1. Black Branch Farm Rd and Eyeland Dr are private roads and any entrance off these roads
will require proper easements.
2. Sight -distance from Black Branch Farm Rd onto Jefferson Mill Rd appears to be lacking
and may cause problems for trucks leaving after delivering equipment and materials.
3. Sight -distance from Eyeland Dr onto Secretary's Rd appears to be lacking and may cause
problems for trucks leaving after delivering equipment and materials.
4. Some of the entrances shown will need to be upgraded to meet the standards of a Low -
Volume Commercial Entrance.
5. Note that the final plan must show conformance with the VDOT Road Design Manual
Appendices B(1) and F, as well as any other applicable standards, regulations or other
requirements.
These plans appear to be generally acceptable. If further information is desired, please contact
Doug McAvoy Jr. at (540) 718-6113.
VirginiaDOT.org
WE KEEP VIRGINIA MOVING
June 21, 2022
Attn: Scott Clark
A VDOT Land Use Permit will be required prior to any work within the right-of-way. The
owner/developer must contact the Charlottesville Residency Transportation and Land Use
Section at (434) 422-9399 for information pertaining to this process.
Sincerely,
Doug McAvoy Jr., P.E.
Area Land Use Engineer
Charlottesville Residency