Comments on Albemarle County’s Natural Resources Chapter Draft

October 30, 2012

The Free Enterprise Forum believes Albemarle County’s Natural Resources chapter needs to refocus on natural resources and move away from the pull of biodiversity. While one school of biodiversity seeks to maintain and restore habitat to maintain the status quo another school suggests alterations in our biodiversity are continuous and humans, while having an impact, are a part of that continuous change.

In the past, we have raised significant concerns with the mission statement that is placed on Albemarle County’s website regarding the Biodiversity committee.  It states there mission as ” The mission of the Natural Heritage Committee (NHC) is to maintain and restore the County’s native biological diversity and provide a healthy environment for the citizens of Albemarle County.” This is far broader than the authority granted by the Board of Supervisors.

Throughout this chapter I see the Biodiversity Committee as assisting and informing staff decisions without input from elected officials.  This is a mistake.

On page 2 of the chapter it states, without scientific back up, “Biodiversity is essential to human life”.  Later it indicates that humanity has an ethical responsibility to care for other life forms on earth.  How can the natural resources chapter place ethical constraints on other chapters.  Ethics, and religion, do not belong in the comp plan. Some might suggest that humanity has an ethical responsibility to provide adequate shelter to other humans but that does not appear in our affordable housing chapter.  Both these statements should be removed.

On Page 4 there is a map referenced regarding areas for mountain protection but it does not indicate how such map is to be determined or if it is the map that was refused by the Board of Supervisors previously.

Reading between the lines on Page 12 the Free Enterprise Forum believes the Biodiversity Action Plan should be renamed the Biodiversity Downzoning Plan.  We are most concerned that a biological inventory informing land use decisions might preclude landowners from exercising their property rights in the name of biodiversity with limited benefit.

While respecting the intentions of the overzealous Natural Heritage Committee we believe the introduction of biodiversity as a land use metric is simply a back door to population control and the potential extinguishing of development rights without compensation.

In addition we fear the Biodiversity action plan would be in direct opposition to much of the neighborhood model design of dense development and pocket parks in the development areas.

On Page 14 we believe Objective 1 strategy a – should include language about preservation of property rights while encouraging sensitive site selection and design ….

On Page 18 we believe the use of the term “tragedy of the commons” to be unnecessary and prejudices the document.

On page 19 under Objective 3 strategies a and b seem to be in conflict and need to be reworded or combined.

On Page 20 – The Free Enterprise Forum believes Comprehensive Plan language should suggest not dictate we ask that Strategy d be we worded as follows – “Consider watershed divides when evaluating any future changes to Development Area boundaries to coordinate land use planning and water resources policy.”

I also noticed a couple of typos which I will forward to staff.  Thank you for the opportunity to review and comment on this document

Respectfully Submitted,


Neil Williamson, President


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