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37 <br /> Review comments concerning the final draft of the proposed amendments to the Orange <br /> County Zoning Ordinance as completed by the Golf Course Amendment Review Task Force <br /> Prepared for: Ms. Emily Cameron, Orange County Planner <br /> Prepared by: Dr. Anita R. Bahe, Front Royal Environmental Services, Inc. <br /> Comment#1 -In order to keep the more detailed contents of the proposed ordinance in proper <br /> context, some clarity is required concerning the purpose of the draft ordinance as it relates to <br /> statements made in the background section contained in the introduction information. In response <br /> to the"most noticeable impact . . . "sentences therein, addressing the size and extent of <br /> disturbance associated with golf courses should perhaps be more distinctly qualified. Though it is <br /> stated that not all golf courses necessarily impart the same impacts, it would be fitting to mention <br /> that the potential impacts are dependent on numerous factors including the specifics of the site;the <br /> type of course being developed(par three, championship, residential component, etc.);the architect <br /> involved in the project; and the financing available. When considering many other land use <br /> alternatives, including but not exclusive to business parks, residential development, waste disposal, <br /> and agricultural expansion,the impacts of a well planned golf course can often be minimal in <br /> comparison. This type of inclusive text helps to keep in perspective the original primary objective <br /> determined in 1995 (Natural Resources Preservation)rather than taking offense, if you will,to the <br /> golf course development industry. <br /> Revisions to Articles 6 and 22 are positive. <br /> Comment#2- With regards to the establishment of penalties to remedy violations,the type of <br /> golf course project and the ownership will both play a role in the effectiveness of restraints. A <br /> Stop Work Order is apt to be effective in dealing with blatant violations, but the permit <br /> requirements must therefore be very distinctly defined to avoid unnecessary delays to owners, <br /> investors, contractors, etc. on a project that is curtailed due to misinterpretations. <br /> Comment#3- It is good to allow provisions for changing a Special Use Permit(SUP)following <br /> the original approval, but the use of specified criteria may be inappropriate. If the `due diligence' <br /> process reveals acceptable plans are in place and risk has been minimized, then an environmental <br /> summary of the information gathered during this process should be considered. I can not comment <br /> on the ten criteria because they were not included in the draft I received. <br /> Comment#4-It is difficult to make definitive comments about the SUP classifications (no code <br /> definitions included)and the land use restrictions by district due to a lack of familiarity and/or a <br /> lack of descriptive information about the demographics and geographic characterization of each <br /> district. It is advisable to include someplace in the document or in an appendix a thorough <br /> description of each district and each code in order to minimize misinterpretation of the proposed <br /> requirements within the document. <br /> 6.16.1 is acceptable <br /> Within 6.23.7 number two, the exception for tree removal in a stream buffer that falls in the line of <br /> play is an acceptable change,but rather than prohibit the removal of stumps or roots,the same <br /> objective could be accomplished with an alternative erosion control, sedimentation prevention,and <br /> 1 <br />