Ramble On

Friday, October 16, 2009

A Letter to the USDA regarding Page County's Project Clover

This week was the deadline for public comment on a prospective USDA loan to fund a large land purchase in Page County. Here is the letter I wrote; I would like to see industrial development but I disagree with the purchase that is currently being considered.

October 14, 2009
James H. A. ,
USDA Rural Development Office1934 Deyerle Ave Suite DHarrisonburg, VA 22801

Dear Mr. A.:
I am writing in response to the request for comments advertised in the Harrisonburg Daily News Record on September 16, 2009, regarding the USDA loan request for Project Clover in Page County, Virginia. There are several land use, environmental, alternative locations, and due diligence reasons that this loan should be denied.

Land Use: The location and character of the project is not a use that fits the nature of the agricultural setting where it is now planned. Converting prime farmland to industrial use is in conflict with the mission statement of the USDA, especially when there are alternative sites available for this purpose.

As far as transportation access goes to this site, it has no road frontage to a major highway and is separated from the US interstate highway system by a mountain range. The parcel is accessed by a steep two-lane road that exits off of the US 340 South Business bypass. To the north, US 340 is not expandable to four lanes due to the terrain it passes through; to the south, the road passes through a town before joining US 340 or access to US 211. It is very difficult to see how the transportation of any industrial output from potential industrial operations could be economically transported to market; it is equally doubtful that input/component goods could be delivered economically to this location.

Finally, the needed utilities for development on this scale are not in place, and are not planned to be built in the near future. The neighboring town of Stanley is known to have function and capacity problems with its utilities, especially sewer, and this site’s location within the Shenandoah River watershed make this an even more important consideration.

Environmental: The Project Clover parcel is located in an area identified as Karst geology. To the public’s knowledge, no investigation of this condition has been made to assess potential impact of industrial development and use on this type of geology. At the minimum, an assessment of potential aquifer impacts and future impacts to the Shenandoah watershed should be conducted to determine whether there are existing underground problems, to identify potential undesirable impacts, and mitigating steps that should be taken in case this development is pursued in the end.

Alternative Locations: Within the central part of Page County, there are several other large parcels on the market that offer better access to transportation networks and utility infrastructure, and there are existing industrial/brown field sites that can be reprogrammed for these purposes, likely at a much lower cost and risk than this parcel.

I agree with the insight offered by long-term residents that the selection of a location closer to the town of Luray is more suitable. Utility infrastructure, including water and sewer, are in place and there is access to US Route 211, a four- lane highway that links to Interstate 81. Rail access is available there as well, with an existing spur for potential businesses. This capacity sits unused. Additional land along the Rte 211 corridor is available, and land along the juncture of Rte 211 and Rte 340 is available.

Due Diligence: The petition of nearly 2,000 local citizens and their attendance at so many public hearings on this matter demonstrate that there is a broad consensus disapproving this purchase and the idea of developing this site for this purpose. There is general agreement that something should be done to encourage industrial development, but there is general recognition that this site is not a good choice.

Other than the reasons land use and environmental issues listed above, this concern boils down to financial and fiscal issues: simply that county’s involvement in this loan is not justified due to the lack of a business case, no appraisal of the land’s value to secure the loan, and no alternative sources of funds to repay the loan. By Page County EDAs own assessment, there have only been five or six inquiries about relocating to the County in the last three years, and Page County was not selected in any of those cases. In my opinion, these decisions are driven by basic economics of the location here rather than the lack of developable sites; to purchase this land for future development seems to me to be putting the cart before the horse, especially when no known relocation prospects are currently in the pipeline.

For additional background, I am enclosing a letter to the editor of the Page County News and Courier that was recently published. In this letter, I reviewed and analyzed the County’s strategic plan for development, and found that this rushed decision to purchase Project Clover actually conflicts with the findings and recommendations of that plan.

Please consider these factors and deny this loan. Failing that, I ask that you recognize that meaningful public comment requires public access to information, which has been lacking in this case. While non-disclosure agreements are frequently an element of business negotiations, there must be a limit to their purview and application when it comes to committing public funds for a use such as this, and Page County and the EDA have made access to relevant public documents such as the following difficult:

1. Lists and analyses of other sites, evaluation criteria and site evaluations.
2. Documents relied upon to establish a price for the relevant property and comparisons to other potential sites.
3. All purchase documents and amendments.
4. RDA loan application documents
5. The fiscal impact statement and analysis of total project costs over its lifetime, if any.
6. Traffic studies
7. Cultural resource study

This documentation should be made readily available to the concerned citizens of Page County, and once that step has been taken, the RDA 30 day comment period should be reset to begin after the last document is posted.

Thank you for the opportunity to contribute to your consideration of this loan request. If you would like to discuss the content of this letter further, please contact me by email at jt@.com.


J. Turner

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