The Piedmont Environmental Council (PEC) appreciates the opportunity to review and comment on the current draft of the Virginia Outdoors Plan (VOP).  The draft VOF brings an innovative approach to production of the plan, using story maps to present a wide range of information and analysis related to the public’s preferences and opinions on outdoor recreation in Virginia and as a source for guiding project selection during the Open Project Selection Process of Land and Water Conservation Fund grant rounds for the next 5 years of implementation.  The plan reflects the considerable effort undertaken by DCR to update the VOP, particularly during the period of the COVID-19 pandemic.  

While recognizing the importance of the VOP and the effort to complete the draft plan, PEC also notes that there are opportunities to enhance, improve, and/or update the the plan, in both form and substance.  In this regard, PEC’s principal comments include the following:  

1. Difficulty Navigating the Plan.  The presentation of the draft VOP in a story map format provides an appealing and interactive approach that allows users to explore different aspects of the plan.  While PEC commends DCR for embracing this innovative approach to presenting the expansive survey and/or geographic information found in individual chapters, we found this format also diminished a reader’s ability to easily comprehend the plan’s context and priorities, whether local, regional, or statewide.  In short, this story map format requires readers to actively engage with the content and make connections between various sections and themes on their own. 

To address the challenges of navigating the draft VOP, PEC recommends that the plan (1) provide an Executive Summary that compiles the most significant findings and recommendations of the plan and (2) offer a searchable PDF version so that readers can more easily make connections between themes, factual information, recommendations, and priorities.  

2. Recognizing Scenic, Historic, and Cultural Landscape Conservation. Unlike prior Virginia Outdoor Plans, the current draft VOP does not appear to include discussion or recommendations that will further the conservation of scenic, historic, and cultural landscapes.  

We believe this consideration of the conservation of significant scenic, historic, and cultural landscapes is an important component of the VOP.  According to the 2018 Virginia Outdoors Plan, “The integrity of Virginia’s scenic vistas, which often possess a combination of natural and historic features, is susceptible to incremental degradation — ranging from isolated development to large linear infrastructure projects — that endangers the character of viewsheds” (2018 Virginia Outdoors Plan, p. 12-3).  The threat is even greater today given the demand for electricity and additional transmission and generation infrastructure created by the explosive growth of data centers in Virginia. 

Scenic and cultural landscape conservation is an essential element of Virginia's tourism economy. According to the 2022 Virginia Outdoors Survey, 54 percent of sample respondents rated scenery and scenic views very important when making travel plans, marking an increase over the 51 percent of respondents in the 2017 Survey.  The Appalachian National Scenic Trail and the Potomac Heritage National Scenic Trail highlight the significant intersection between scenic resource conservation and recreation.  

3. Restoring and Updating Regional Profiles and Features.  The draft VOP does not appear to have the detailed background for each Planning District that characterized the 2018 version. This omission makes the latest plan more generic and less connected to the specific needs and identities of the regions it aims to serve. This appears to be particularly evident with the omission of narrative about conservation of historic, cultural, and scenic resources by region.   

To the extent that regional priorities with statewide significance are identified, the draft VOP notes that the Featured Projects by Planning District represent “projects that were recommended by regional and local planners, and other stakeholders, at meetings held throughout the Commonwealth between 2018-2021,” and that “[M]any projects are continued from the 2018 VOP.” 

There is an opportunity to strengthen the implementation of the VOP in the coming years by incorporating Featured Projects from the 2018 VOP that were omitted in the current draft plan as well as conservation and outdoor recreation opportunities that have emerged since 2021. 

In and around the PEC nine county service area, a sample of notable 2018 VOP Featured Projects and prospective future Featured Projects that can or should be included in the current VOP include the following:  

VOP Region: Region 2 – Central Shenandoah Planning District Commission. 

Projects found in Region 2 – Central Shenandoah Planning District Commission that were identified in prior Virginia Outdoors Plans or emerging projects that can or should be included in the current draft VOP include:  

• Expand land protection and opportunities for recreational and wildlife connectivity around the Afton Gateway 

• Complete restoration of the Blue Ridge/Crozet Tunnel and develop connector trails on both sides of the tunnel in Augusta County 

VOP Region: Region 3 – Thomas Jefferson Planning District Commission.

Projects found in Region 3 – the Thomas Jefferson Planning District Commission that were identified in prior Virginia Outdoors Plans or emerging projects that can or should be included in the current draft VOP include:  

• Develop Biscuit Run Park and Greenway 

• Implement the Rivanna River Blueway and Greenway

• Develop Rivanna River Bicycle and Pedestrian Bridge (Albemarle and Charlottesville)

• Develop Ragged Mountain-Hedgerow Park trail connections. (removed but should be included)

• Implement Meadow Creek Greenway and Tunnel (Albemarle and Charlottesville)

• Implement Moores Creek Greenway (Charlottesville and Albemarle)

• Implement Norfolk Southern Rail Trail (Charlottesville)

• Complete Northtown Trail (Albemarle)

• Implement Northtown Trail Extension to Ruckersville (Albemarle and Greene)

• Implement Ruckersville to Standardsville Greenway (Greene)

• Complete McIntire Botanical Garden (Charlottesville)

• Presidential Precinct Trail (Albemarle)

• Implement the Thomas Jefferson Planning District Commission‘s Jefferson Area Bike Pedestrian Plan.

VOP Region: Region 4 - Northern Virginia Regional Commission

Projects found in Region 4 - Northern Virginia Regional Commission that were identified in prior Virginia Outdoors Plans or emerging projects that can or should be included in the current draft VOP include:  

• Implement the Journey Through Hallowed Ground National Scenic Byway / Heritage Area

• Complete feasibility study and acquire Oak Hill as a state park, a National Historic Landmark that is key conservation priority in the Journey Through Hallowed Ground National Heritage Area and along the Journey Through Hallowed Ground National National Scenic Byway (Loudoun County)

• Complete feasibility study of pedestrian trail connecting Mt. Zion Church and the Aldie Mill, identified as key Interpretative Sites within the Journey Through Hallowed Ground National National Scenic Corridor Management Plan (Loudoun County)   

• Expand protection of the natural and scenic resources of the Bull Run Mountains, consistent with the Virginia Outdoors Foundation Special Project Area and the Journey Through Hallowed Ground National National Scenic Corridor Management Plan (Fauquier, Loudoun, and Prince William Counties)   

4  Balancing Energy Siting and Design with Conservation  PEC appreciates the draft VOP’s recognition that renewable energy sources are an important part of Virginia’s future energy generation portfolio.  We also note that the VOP quotes a source that states “While renewable energy sources have attractive emission characteristics, wind and solar generation are among the most demanding from a land use perspective (and will require) development of roughly 161,000 acres of available land."  Given the changing (and increasing) energy demand characteristics associated with data centers and other users, there are indications that substantially more than 161,000 acres of land in Virginia may be slated for conversion to renewable energy production, as much as 1 million acres.  In preparing the final plan, DCR may wish to update the 161,000 acre figure with more current projections for land conversion.     

5. Incorporating Other Plans and Data. PEC appreciates how the draft VOP incorporates links and/or references to numerous other plans and data sources that help inform the analysis and recommendations in the plan.  Additional plans and data sources that DCR may wish to reference in the final plan include the (1) Virginia Wildlife Corridor Action Plan ; the (2) Chesapeake Conservation Atlas; (3) the EPA's Environmental Justice Screening and Mapping Tool (Version 2.3); and, to the extent possible, more open space and trail plans that have been developed by local jurisdictions.    

Inclusion of the above plans and data can help further inform conservation and recreation priorities as DCR works to implement the plan. 

6.  Accountability and Transparency.  The draft VOP indicates that a Technical Advisory Committee (TAC) played a key role in coordinating the development of the plan and will have the responsibility for “measuring progress, making future recommendations and proposing future VOP priorities.  PEC was unable to identify in the draft plan the members of the TAC. 

In the spirit of both transparency and accountability, it is recommended that the final version of the VOP include the members of the TAC as well as other individuals and organizations that contributed to creating the plan.