The Orange County staff report, dated May 6, 2009, recommends approval of Walmart's application to the Planning Commission, stating that it is consistent with the county's Comprehensive Plan. However, a more in-depth analysis reveals that it conflicts with the plan in numerous ways. Read more below about how Walmart's proposal conflicts with the Comprehensive Plan:

Economic Development

The area for both proposals is identified as Economic Development by the County's Future Land Use Map. To date, the zoning ordinance language for this classification has yet to be drafted. But language in the Comprehensive Plan referring to Economic Development offers the following guidelines for such areas:

• Area is for the development of business parks and related uses in those areas of the county where there is infrastructure to support business growth.
• Development should be supported if it combines various types of commercial and industrial activities that provide strong connections and services to achieve a healthy economic sector for good paying jobs.
• Proposals for new development will incorporate features and designs that are compatible with and reflective of the cultural and historic resources of the county.
• The impact of new developments on the existing major transportation corridors such as Route 3 should be minimized.
• Require that all development proposals be accompanied by a fiscal impact analysis.

The Walmart application includes a large retail store and pad sites for future chain stores. No economic analysis has been submitted to indicate what type of impact this development would have on other orange County industry (tourism, agriculture, etc.) or to suggest this development would bring good paying jobs or achieve a healthy economic sector. Transportation improvements appear to prepare the County for a future realignment of the Route 20 corridor, an impact that is in complete conflict with stated goals for the corridor. A big box chain store is hardly in keeping with the immediate areas' historic and cultural resources (Wilderness Battlefield, Elwood, etc.).

Rural Character, the Environment, and Historic Resources

While some design guidelines have been approved by the County, it is difficult at best to design these types of businesses to be sensitive to or reflect our cultural and historic resources such as the Wilderness Battlefield. The supervisors have already indicated their support of the project (in advance of any hearing) and the guidelines appear to be drafted in anticipation of Walmart's approval.

One of the primary goals found within the Comprehensive Plan is:
Shield the rural character of the county from the undesirable effects of uncontrolled growth, thereby preserving the unique and distinguishing characteristics of Orange County.

Some of the objectives found within this goal are:

• Develop a template for environmental impact analysis to be required as part of review and approval of development proposals.
• Develop guidelines for the protection of wildlife and their habitats.
• Develop a tree preservation ordinance to ensure the retention of an adequate tree canopy for all new development.
• Develop a long-term historic preservation plan.
• Consider historic resources in land use decisions.
• Develop a comprehensive battlefield resource protection plan for Civil War sites.

At this time, these objectives appear to have been ignored by the applicant and the County. The County has failed to produce many of the documents called for within the plan (Battlefield Protection Plan, environmental impact analysis template, etc.). Consideration of this proposal in advance of the necessary guidance documents will lead to an uninformed decision by the County, leaving many potential impacts unaddressed.

Impacts to Route 20

The Orange County Comprehensive Plan is clear in its intent to limit any impact to Route 20 that would necessitate the widening of the Route to four-lanes. With regard to Route 20, the Plan states:

• It is the intent of the county to aggressively pursue remediation of acute safety hazards through safety related intersection construction and through traffic management.
• While the study made traffic projections based on recent trends, it is the intent of the County to discourage development that would necessitate construction of a four-lane highway over any portion of the route in Orange County.
• It is the intent of the County not to undertake improvements that would encourage more non-county related traffic.
• While the study did not seriously explore options other than realigning Route 20 through one of the most significant historical resources in the county, this is no impediment to addressing current needs.

It is our belief that these proposals would increase traffic at the Route 3/20 intersection and inevitably on the eastern end of Route 20. This level of traffic would be difficult to mitigate and would further damage the integrity of the Wilderness Battlefield.

Conclusion

PEC opposes Walmart at the proposed location. Before the County considers any rezoning or special use permit for this area, the following items need to be addressed:

• Completion of the zoning ordinances for Economic Development and Mixed Use.
• Complete a buildout analysis of the growth area commonly referred to as the Germanna Corridor growth area, evaluating whether it is representative of a twenty-year planning period (Comprehensive Plans represent a twenty-year vision). There are roughly 2,600 acres of zoned agricultural land within the growth area and many already undeveloped lots that are already zoned commercial, residential and industrial. The analysis should include an evaluation of the specific proposals as presented and any expected impacts on the timeline for existing and future residential.
• Development of a fiscal impact model to evaluate these and future proposals.
• Development of a historic preservation plan and a battlefield resource protection plan.
• Development of other important guidance documents as suggested within the Comprehensive Plan (environmental impact).
• Review of any transportation analysis for the projects against the Comprehensive Plan guidance - Route 3/20 impacts.
• Completion of design guidance as suggested within the plan (Tourism Corridor Overlay District) instead of relying on weak guidelines adopted in a rush and with the desire to approve Walmart.