HomeMy WebLinkAbout08-26 Agency Comments
DEPARTMENT OF TRANSPORTATION
14031 Old Valley Pike
Edinburg, Virginia 22824
VirginiaDOT.org
WE KEEP VIRGINIA MOVING
August 26, 2026
Mr. John Bishop
Frederick County Director of Planning
107 N. Kent St.
Winchester, VA 22601
Re: Gibson Property Rezoning
Dear Mr. Bishop:
This addendum serves to supplement VDOT’s original comment on the Gibson Property
Rezoning, dated August 7, 2026. All comments in the original letter remain in full effect
except as clarified below. Additional comments are provided in response to updated proffers
submitted by the applicant on August 21, 2026.
1. The updated proffers include a trigger for the required Signal Justification Report (SJR)
and associated entrance improvements tied to a building square footage threshold of
2,000,000 square feet. The SJR and associated improvements should be provided once a
signal is warranted based on the actual uses proposed at the time of final site plan. A
2,000,000 square foot backstop would be acceptable; however, the improvements may be
required sooner depending on the intensity of the uses proposed with the final site plan.
2. The proffer to construct improvements at the intersection of Route 522 and Route 340 is
insufficient to guarantee mitigation will be provided by the developer. The proffer
includes a caveat that these improvements would only be provided should sufficient
right-of-way exist and it appears that the existing right-of-way may not accommodate the
additional of a dedicated eastbound left-turn on Route 277 as well as an additional
receiving lane on Route 277 for the second northbound left turn lane on Route 522/340.
It should also be noted that these improvements would likely require replacement of the
existing traffic signals at this intersection. It might be beneficial for the applicant to
depict these intersection improvements within the rezoning documents to provide some
level of confidence that they are of a scope that can be accomplished by the developer.
Sincerely,
Joseph W. Johnson, PE
Area Land Use Engineer
Edinburg Residency
Virginia Department of Transportation
DEPARTMENT OF TRANSPORTATION
14031 Old Valley Pike
Edinburg, Virginia 22824
VirginiaDOT.org
WE KEEP VIRGINIA MOVING
August 7, 2026
Mr. John Bishop
Frederick County Director of Planning
107 N. Kent St.
Winchester, VA 22601
Re: Gibson Property Rezoning
Dear Mr. Bishop:
The Virginia Department of Transportation (VDOT) has completed its review of the Gibson
Property Traffic Impact Study (TIS), dated July 30, 2026 , prepared in support of the rezoning
request for the Gibson Property along Route 277 (Fairfax Pike) and Route 522/340. Based on
our evaluation, VDOT is in general concurrence with the methodology, assumptions, and
conclusions presented in the study.
As part of our review, VDOT offers the following comments and recommendations for
consideration by the Planning Commission/Board of Supervisors:
1. Western Parcel Entrance Alignment Requirement – During site plan development,
VDOT will expect the proposed entrance serving the western portion of the Gibson
Property to be aligned with the Madison Farm entrance located directly opposite on
Route 277. This corridor already faces spacing constraints, and aligning these
entrances is essential to limiting the number of future major intersections or traffic
signals and preserving safe, efficient traffic operations. The applicant has not
demonstrated that an entrance cannot be accommodated at this location. Accordingly,
VDOT will consider this alignment necessary during the site plan development and
review process.
2. Right-of-Way Dedication Along Route 277 - VDOT recommends that the applicant
dedicate sufficient right-of-way along the project frontage to accommodate the
ultimate U4D roadway section for Route 277, as identified in the Frederick County
Comprehensive Plan. Securing this right-of-way at the rezoning stage is essential to
support long-term corridor improvements.
3. Lack of Transportation Mitigations in Proffer Statement - Based on the proffer
statement submitted to VDOT with the application, no transportation improvements
or mitigations are being offered by the applicant. The TIS demonstrates significant
delays at the intersection of Route 277 and Route 522/340, particularly during peak
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hours. Under future 2035 background conditions (without the project), the
intersection is projected to operate at LOS F/F, with overall intersection delay at 109
sseconds in the AM and 161 seconds in the PM. With the development in 2035,
intersection overall intersection delay increases to 147 seconds in the AM and 190
seconds in the PM. The TIS provides a mitigated scenario that includes an exclusive
eastbound left turn lane and a second northbound left turn lane that improves overall
intersection delay to 53 seconds in the AM (LOS D) and 94 seconds in the PM.
Given these findings, VDOT cannot support the rezoning application without
transportation mitigations that address the documented operational deficiencies.
4. Entrance Locations, Signalization, and Future Studies - All entrance locations,
spacing, and configurations will be determined during the final site plan review
process. No Signal Justification Reports (SJRs) have been provided with this
rezoning application. The signal warrant analyses included in the TIS are preliminary
and do not constitute an approved SJR. VDOT reserves the right to eliminate,
relocate, or modify any entrance shown on the Generalized Development Plan (GDP)
based on final engineering review, spacing requirements, and corridor operations.
While VDOT concurs with the technical findings of the July 30, 2026 TIS, the rezoning
application does not currently include the transportation commitments necessary to support
safe and efficient operations along Route 277 and Route 522/340. VDOT recommends that
the Board of Supervisors require the applicant to address the items outlined above as
conditions of rezoning approval.
Sincerely,
Joseph W. Johnson, PE
Area Land Use Engineer
Edinburg Residency
Virginia Department of Transportation
315 Tasker Road PH (540) 868-1061 Eric R. Lawrence
Stephens City, Virginia 22655 Fax (540) 868-1429 Executive Director
www.FrederickWater.com
Water At Your Service
June 12, 2026
Thomas Moore Lawson
PO Box 2740
Winchester, Virginia 22604
RE: Rezoning Application Comment
Gibson Properties Rezoning
Tax Map Numbers: 87-3-A; 87-3-B; 87-A-16B
294.14-acres
Dear Mr. Lawson:
Thank you for the opportunity to offer review comments on the Gibson Properties rezoning
application package, Impact Analysis Statement dated May 27, 2026. Frederick Water offers
comments limited to the anticipated impact/effect upon Frederick Water’s public water and
sanitary sewer system and the demands thereon.
The project parcels 87-3-B and 87-A-16B are located within the sewer and water service area
(SWSA), and therefore by county policy, Frederick Water’s water and sewer services are
available to access. A 12-inch water main parallels the south side of Route 277. A sanitary sewer
force main was recently constructed on and in the vicinity of the project parcels; the force main
was not sized to accommodate development of the subject properties and therefore may not
have capacity to support this development. When the force main was being planned, designed,
and constructed, the property owner did not support more intensive development and wanted
to continue their agricultural interests with the potential for 4 residences. A parallel force main
was designed but not constructed as projected demands for sewer service did not warrant the
additional force main capacity.
Project parcel 87-3-A is not currently within the SWSA and is therefore by county policy may
not access the public water and sewer. Public water and sewer facilities are not in the vicinity
of parcel 87-3-A.
Page 2
Gibson Properties rezoning application
Thomas Moore Lawson
June 12, 2026
The application’s Impact Analysis Statement dated May 27, 2026, page 2, provides the
application narrative regarding water and sewer facilities:
“The Sewer and Water Service Area (SWSA) defines the areas of the County to which
public water and sewer services may be extended. Tax Map Numbers 87-3-A and 87-3-B
are located inside of the SWSA as defined by Frederick County Staff. Domestic water
will be provided by Frederick Water, and Applicant understands and acknowledges the
extension of water mains that will be required to serve this project. Sanitary collection
and treatment will also be provided by Frederick Water, and Applicant understands and
acknowledges the timing associated with the sanitary sewer connection and the effort
required by the County to make that available.”
The Impact Analysis Statement is silent on proposed water and sewer demands, and applicant
responsibilities. The applications states that they – the Applicant- “understands and
acknowledges the timing associated with the sanitary sewer connection and the effort required
by the County to make that available”. The applicant should provide proposed water and sewer
demands, and clarification of the statement regarding “the effort required by the County
regarding sanitary sewer”.
The applicant will need to ensure that adequate water and sanitary sewer conveyance and
treatment system capacity is available to achieve the projected build-out of the project. It is the
applicant’s responsibility to fund the design, easement acquisition, and construction of the
extensions of water and sewer services necessary to satisfy their proposed demands.
Sanitary sewer infrastructure is sized reflective of anticipated flows. Gravity sewer is often
easier to plan for as gravity will contribute to proper flow movement, and minimal flow is less
troublesome. A sanitary sewer force main warrants much more scrutiny during design as flows
through the force main must be pumped, and an oversized force main with inadequate flows
can result in septic conditions. Such conditions contribute to sludge buildup, reduce flow
capacity, internal corrosion, cycling fatigue, and odors. Force mains should be sized reflective
of known or anticipated sanitary sewer flows. As noted above, a parallel sanitary sewer force
main was designed but not constructed due to the lack of projected demands of additional
sanitary sewer flow.
This applicant will need to address its sanitary sewer requirements and solutions once its
sanitary flow generation is more clearly known. The sewer demands and timing of when sewer
demands will be realized should be considered by the applicant as they design and construct
the sewer improvements necessitated by the development. If the appropriate sewer solution
benefits a regional service and not solely the applicant’s properties, then a partnership with
other benefiting property owners and Frederick Water should be considered.
Page 3
Gibson Properties rezoning application
Thomas Moore Lawson
June 12, 2026
Water and sanitary sewer improvements are to be constructed in accordance with Frederick
Water standards and specifications. Easements will be required to accommodate infrastructure
that is dedicated to Frederick Water. Please be aware that Frederick Water is offering these
review comments without the benefit or knowledge of the proposed water and sewer demands
for the site.
Water supplies and sanitary sewer conveyance capacities change daily; with each new
customer connection brings additional demands and generated flows. This letter does not
guarantee system distribution, collection and/or treatment capacities to accommodate the
development proposal.
Thank you for the opportunity to offer review comments.
Sincerely,
Eric R. Lawrence
Executive Director
Page 2
Gibson Properties rezoning application
Thomas Moore Lawson
June 12, 2026
The application’s Impact Analysis Statement dated May 27, 2026, page 2, provides the
application narrative regarding water and sewer facilities:
“The Sewer and Water Service Area (SWSA) defines the areas of the County to which
public water and sewer services may be extended. Tax Map Numbers 87-3-A and 87-3-B
are located inside of the SWSA as defined by Frederick County Staff. Domestic water
will be provided by Frederick Water, and Applicant understands and acknowledges the
extension of water mains that will be required to serve this project. Sanitary collection
and treatment will also be provided by Frederick Water, and Applicant understands and
acknowledges the timing associated with the sanitary sewer connection and the effort
required by the County to make that available.”
The Impact Analysis Statement is silent on proposed water and sewer demands, and applicant
responsibilities. The applications states that they – the Applicant- “understands and
acknowledges the timing associated with the sanitary sewer connection and the effort required
by the County to make that available”. The applicant should provide proposed water and sewer
demands, and clarification of the statement regarding “the effort required by the County
regarding sanitary sewer”.
The applicant will need to ensure that adequate water and sanitary sewer conveyance and
treatment system capacity is available to achieve the projected build-out of the project. It is the
applicant’s responsibility to fund the design, easement acquisition, and construction of the
extensions of water and sewer services necessary to satisfy their proposed demands.
Sanitary sewer infrastructure is sized reflective of anticipated flows. Gravity sewer is often
easier to plan for as gravity will contribute to proper flow movement, and minimal flow is less
troublesome. A sanitary sewer force main warrants much more scrutiny during design as flows
through the force main must be pumped, and an oversized force main with inadequate flows
can result in septic conditions. Such conditions contribute to sludge buildup, reduce flow
capacity, internal corrosion, cycling fatigue, and odors. Force mains should be sized reflective
of known or anticipated sanitary sewer flows. As noted above, a parallel sanitary sewer force
main was designed but not constructed due to the lack of projected demands of additional
sanitary sewer flow.
This applicant will need to address its sanitary sewer requirements and solutions once its
sanitary flow generation is more clearly known. The sewer demands and timing of when sewer
demands will be realized should be considered by the applicant as they design and construct
the sewer improvements necessitated by the development. If the appropriate sewer solution
benefits a regional service and not solely the applicant’s properties, then a partnership with
other benefiting property owners and Frederick Water should be considered.
Page 3
Gibson Properties rezoning application
Thomas Moore Lawson
June 12, 2026
Water and sanitary sewer improvements are to be constructed in accordance with Frederick
Water standards and specifications. Easements will be required to accommodate infrastructure
that is dedicated to Frederick Water. Please be aware that Frederick Water is offering these
review comments without the benefit or knowledge of the proposed water and sewer demands
for the site.
Water supplies and sanitary sewer conveyance capacities change daily; with each new
customer connection brings additional demands and generated flows. This letter does not
guarantee system distribution, collection and/or treatment capacities to accommodate the
development proposal.
Thank you for the opportunity to offer review comments.
Sincerely,
Eric R. Lawrence
Executive Director
(540) 955-5132
www.clarkecounty.gov
Clarke County Department of Planning
Berryville-Clarke County Government Center
101 Chalmers Court, Suite B
Berryville, VA 22611
TO: Tyler Klein
FROM: Brandon Stidham, Planning Director
RE: Comments on Gibson property rezoning
DATE: June 12, 2026
Thank you for the opportunity to comment on the Gibson property rezoning application. Clarke
County Planning Department staff does not have any comments at this time, however we would
like to reserve the opportunity to comment on any possible transportation impacts after we are
able to review VDOT’s comments on this application. VDOT staff has offered to involve us in
their review process.
Please let me know if you have any questions.
COUNTY of FREDERICK
Department of Planning and Development
540/ 665-5651
Fax: 540/ 665-6395
107 North Kent Street, Suite 202 • Winchester, Virginia 22601-5000
August 24, 2026
Thomas Moore Lawson, Esquire
Winchester Gateway LLC
P.O box 2460
Winchester, VA 22604
RE: Request for Historic Resources Advisory Board (HRAB) Comments
Gibson Property (REZ) Application
Zoning: RA (Rural Area) District
Property Identification Number (PIN): 87-A-16B, 87-3-A, 87-3-B
Magisterial District: Shawnee
Dear Mr. Lawson:
The Frederick County Historic Resources Advisory Board (HRAB) considered the above
referenced REZ application during their meeting on August 21, 2026. This application seeks to
rezone +/- 294.14 acres from RA (Rural Areas) to M1 (Light Industrial). The properties are located
between Rt. 277 and Rt. 522 in the Shawnee Magisterial District. The HRAB was advised by the
Applicant that the property identified by PIN 87-3-A is intended to be removed from the
application upon formal submittal
Following their review of this application, the HRAB recommended a commemorative marker for
the Battle of Double Tollgate be sited on the property, that a Phase 2 Archeological Survey be
conducted (if warranted by the Phase 1 Archeological Survey) and additional documenting and
preservation of the architectural features of the Funkhouser Farmhouse be completed if developing
the subject property identified with 87-3-A.
Thank you for the opportunity to provide a summary of the August 24th HRAB meeting. Please
contact our office if you have any questions or concerns.
Sincerely,
Eric Bittner
Planner II
cc: Lucas Cooke, HRAB Chairman
Tyler Klein, Senior Planner
COUNTY of FREDERICK
Department of Planning and Development
540/ 665-5651
Fax: 540/ 665-6395
June 18, 2026
Thomas Moore Lawson, PC (tlawson@lsplc.com)
P.O. Box 2740
Winchester, VA 22604
RE: Proposed Rezoning Application for Gibson Property (Estate of Monte Gibson, Jr.)
Property Identification Numbers (PIN): 87-3-A, 87-3-B, & 87-A-16B
Dear Mr. Lawson:
Planning and Development staff had the opportunity to review the draft rezoning (REZ) application
for the above project. This application seeks to rezone +/- 294.14-acres from the RA (Rural Areas)
zoning district to the M1 (Light Industrial) zoning district with proffers. The subject property is
located generally north and west of the intersection of Route 277 (Fairfax Pike) and Route 522 in
the Shawnee Magisterial District. Prior to formal submission to the County, please ensure that these
comments and all review agency comments are adequately addressed. At a minimum, a letter
describing how each of the agencies and their comments have been addressed should be included
as part of the submission.
• Comprehensive Plan Conformance. The Comprehensive Plan (adopted November 2021)
and the Southern Frederick Area Plan (2024) provide guidance on the future development
of the subject property. The Plan identifies the subject properties with “industrial” and
“mixed-use industrial office” (MUIO) land use designations and as being within the limits
of the sewer and water service area (SWSA).
“The Route 277 Triangle Centers of Economy is designed to be a significant area
of commercial and industrial opportunity that is fully supportive of the Frederick
County Economic Development Authority’s targeted goals and strategies. The
intent of the mixed-use designation is to further enhance the County’s commercial
and industrial areas and to provide focus to the County’s future regional
employment centers. In specific areas a mix of flexible uses, with office uses in
prominent locations is encouraged. Such areas are supported by substantial areas
of industrial and commercial opportunity and provide for areas that are well
designed with high quality architecture and site design. It is the intent of such
areas to promote a strong positive community image. Residential land uses are not
envisioned in this area.”
The proposed zoning district, M1 (Light Industrial) is typically associated with the future
land use designation for “industrial,” for which the properties are partially designated.
However, the proposal is silent on potential (or restricted uses) and how it would further
County policy and the Economic Development Authorities targeted industries or the area
plan envisioned “mix of flexible uses” and/or meets the intention of the “mixed-use
industrial office” (MUIO) designation on portions of the properties along Route 277. At a
Page 2 of 3
minimum, uses that might be noxious, unsafe, or disruptive as well as uses that generate
higher traffic than what has been contemplated in the TIA should be considered for
exclusion. Other elements of plan policy, such as “high quality architecture and site design”
are absent or under-developed in the application materials. For example, EIFS (exterior
insulation and finish system) specified as a primary building material in Proffer 1.2 is not
typically considered “high quality.” No building renderings, elevations, or conceptual
layout of future buildings are provided to evaluate if policies regarding architecture and
site layout are being met. In this respect, plan conformance is only partially achieved.
Further, sensitivity should be given to the broader area and how a future large assembly of
industrial development may impact other sub-planning areas and the rural areas of Clarke
County. Specifically, the Lake Frederick Urban Development Area is immediately to the
south, which is planned for future residential and neighborhood village (Lake Frederick
and more recently the Madison Farms projects). The uses ultimately to be developed on
the Gibson properties or uses to be prohibited, should be carefully selected and their
potential impacts (noise, odor, vibration, traffic) be fully mitigated. Given the surrounding
area is primarily residential and agricultural, enhanced buffering and screening, lower
building heights, and increased building setbacks may be appropriate mitigation measures
for potential impacts and address the Plan policy for high-quality architecture and site
design.
The subject property identified with PIN #87-3-A does not have a future land use
designation and is outside of the limits of the SWSA. The property is otherwise planned to
remain “rural.” A concurrent CPPA request for this parcel did not receive consensus for
further study.
• Transportation & Traffic Analysis.
• The Plan also identifies planned transportation improvements on the subject
properties including a “new major collector” road and multiuse trail connecting
Route 277 to Route 522. Additionally, a multiuse trail is envisioned along Route
522 and Route 277 (Fairfax Pike) and future widening to Route 277 (improved
minor arterial). While the collector road right-of-way (ROW) is proffered, the
other planned transportation improvements outlined above are missing from
application materials, including the GDP and proffer statement.
• The Traffic Impact Study (May 8, 2026) notes that the “future with development”
key regional intersections studied (Intersections #1 & #3) continue to fail, and
because there is no known transportation improvements planned, “no
improvements are proposed as a result of the Gibson development.” This is grossly
inadequate as it is long-standing policy in Frederick County that developments
shall fully mitigate potential impacts to adjoining transportation infrastructure.
Special attention should be paid to what improvements, as ultimately warranted by
VDOT, could accommodate improvements to Route 522 & Fairfax Pike/Lord
Fairfax Highway (Intersection #3).
• A signal justification report (SJR), as noted in the TIS for Route 522 (and Site
Entrances #4 & #5) and the western site entrance* on Fairfax Pike (Route 277; Site
Page 3 of 3
Entrance #1), should be completed as part of the preliminary comment period,
reviewed and approved by VDOT prior to acceptance of the application for public
hearings. Uncertainty about the improvements necessary for a particular
development and timing of when those improvements are needed raises concern
for staff about the appropriateness of the proposal at this location.
*Staff notes the approved Madison 277 proffer statement (REZ #07-25) also
contemplates a SJR and potential traffic signal at their site entrance on Route 277.
This applicant is advised to reach out to the Madison 277 owner (Dave Madison)
and coordinate on how the cost and installation of a potential signal at this
location could be shared among both projects, and the trigger (timing) of such
improvement.
• Proffer Statement. The following comments are offered on the proffer statement dated
2026.
• Provide a “Original Date of Proffers.”
• The proffer statement does not contemplate allowed or prohibited uses and the
potential impacts to adjoining properties and roadways or mitigation measures.
• Proffer 2 does not fully address level of service (LOS) failures, traffic impacts, and
planned transportation improvements outlined in the Comprehensive Plan to
adjoining roadways. Specifically, the TIS notes turn lanes for points-of-access
to/from Route 522, and these are not expressly listed in the proffer statement.
• Other Application Materials & Fee. Based on the fees adopted by the Board of
Supervisors, the application fee for this CUP application would be $32,207.
• Agency Comments. Agency comments are attached. Once the application is “complete,”
and the fee is paid it will also need to go to the Historic Resources Advisory Board (HRAB)
prior to scheduling for public hearing.
All the above comments and reviewing agency comments should be appropriately addressed before
staff can accept this application for a public hearing. The Applicant should verify with Planning
& Development staff application completeness prior to final submission.
Please feel free to contact me with questions regarding this application.
Sincerely,
M. Tyler Klein, AICP
Senior Planner
Attachments: Agency Comment Letters
fmo@fcva.us
Fax: 540-678-4739Phone: 540-665-6350
Winchester, VA 22602
1080 Coverstone Drive
Frederick County Fire and Rescue Department
Office of the Fire Marshal
Other:
Thomas Moore Lawson. P.C.
Gibson Property
White Post, Virginia 22663
1787 Fairfax Pike
Business Name
Printed Date: 06/16/2026
Plan Review
Rezoning
Status: Approved
General Information
05/20/2026Received Date:
06/16/2026
06/16/2026
Review Begin Date:
Review End Date:
1.0000Hours:
Residential
Property Use:
Occupancy Type:
ApplicationReview Cause:
Activity Number:I056080
Activity Details
Rezoning from Rural Areas to Light Industrial (M1)Project Name
Comments:
All future development shall comply with the Frederick County Fire Prevention Code and all other applicable codes.
Adam Hounshell
Lieutenant/Assistant Fire Marshal
Page 1 of 1
Project Name: ________________________________________________
Acreage: ___________
PIN(s): __________________
Address (or general location):
Existing Zoning District: ____________________________________________
Proposed Zoning District: ___________________________________________
Staff Name (Email Address): _________________________________________
Agency Name Completing Comments (select one):
____ Frederick Water
____ Virginia Department of Transportation
____ Winchester Regional Airport
____ Virginia Department of Health
____ Historic Resources Advisory Board
____ Frederick County (FC) Public Schools
__X FC Public Works
____ FC Inspections
____ FC Fire Marshal
____ FC Parks & Recreation
____ FC County Attorney
____ Other (Specify): ________________________
Resubmission to address comments requested? Y _____ or N _____
REQUEST FOR REZONING COMMENTS
Reviewer Name (Email Address): __________________jwilder@fcva.us________________
Review Agency Comments:
*Comments that may not fit in the box should be attached to the cover sheet on agency or department letterhead.
A comprehensive review shall occur at the time of site plan submission.
We offer no additional comments at this time.