The Mosby Heritage Area Association (MHAA) views with alarm the vague and general language in the draft Envision Loudoun 2040 Plan. The draft plan does not sufficiently protect the historic and rural landscape in western Loudoun County. While MHAA appreciates the time that has been spent by the stakeholders committee and staff in preparing the plan and the County's efforts to engage public input, the resulting plan does not do enough to protect citizens' interests and the historical and cultural resources of Loudoun County.

We recognize that one of the goals of the plan is to "Strengthen Natural and Historic Assets." We also support Policy 5 in Chapter 3 - Green Infrastructure. This policy captures the important contribution that the county's historic landscape makes to Loudoun's character. Unfortunately, Action L under this policy states that the county will encourage developers to propose tradeoffs between historical and open space. This policy should be struck from the plan as it undercuts citizens' desire to maintain and enhance Loudoun County's unique character.

We are extremely concerned that the language used in the surrounding chapters on Land Use, Housing, Economic Development, Fiscal Management and Public Infrastructure includes so many other threats to efforts to strengthen natural and historic assets.

Specific examples include the following:

• The many open-ended policies calling for increased flexibility in facility standards, policy interpretation, and responsiveness to developers. Any of these could be used as a wedge to destroy Loudoun's historic and natural heritage.

• The failure to establish goals and measures for the overall conservation and protection of historic properties. Retention of our unique cultural landscape cannot be achieved by focusing on individual development decisions. The County needs to establish annual reporting of the amount of land protected under easements, to identify priority areas for protection of historically significant properties, and to work with private landowners to increase those protected lands.

• Uncertainty over how the "Place Type" concept will apply to the rural area. Envision 2040 proposes Place Types as a replacement for traditional zoning regulations but only applies two broad place types to the entire rural policy area. It is not clear what this means for future decisions about development in the RPA. At a minimum, additional place types, including one for existing Historic and Cultural Conservation districts, should be defined for the rural area so that the public and developers will know what to expect in the future.

MHAA appreciates the opportunity to present our views on the Envision Loudoun 2040 Draft plan.