Loudoun County FSM PRC Meeting: Archaeology Amendments and Cultural Resource Survey Standards

Note: The agenda and transcript indicate the meeting was held on March 5, 2026, but the provided meeting date is March 17, 2026. This summary uses the provided date.

The Planning and Review Committee (PRC) of the Facilities Standards Manual (FSM) met to discuss proposed amendments to archaeological and cultural resource survey standards, primarily in Chapters 7 and 8 of the FSM. The meeting featured a presentation from the county archaeologist and planning staff, extensive deliberation on the scope of required surveys, and consideration of reporting requirements. No formal votes were taken; discussion will continue at the next meeting.

Consent Calendar

• The committee approved the minutes from the February 5, 2026 meeting by voice vote with a motion and second, all in favor.

Public Comments & Testimony

• No members of the public attended or spoke.

Discussion Items

• Administrative Update: Staff reported that the Board of Supervisors, at its March 3, 2026 business meeting, directed staff to prepare design and construction standards for new data communities, and to obtain input and recommendations from this PRC. The board also directed staff to return with a resolution of intent to amend the FSM to establish such standards. The scope is narrowed to residential data communities.
• Forest Management Plan Cemetery Buffer (Section 7.304 B): Proposed to add a requirement for forest management plans to show boundaries of all cemeteries, burial grounds, and graves, plus associated buffers (50 feet) located on property and within 50 feet of the property. Discussion clarified that this refers to previously identified cemeteries in the county's GIS database, not requiring new field surveys. Committee suggested language adjustments to clarify it is based on records, not new surveys.
• Conversion from Archaeological Survey to Cultural Resources Survey (Sections 7.800 and 7.810): Staff proposed renaming the chapter to "Cultural Resources Survey" to align with legislative checklists. Major changes include requiring a phase one cultural resources survey for the entire property at the preliminary plat stage, rather than only for the proposed limits of disturbance. This aims to prevent situations where development shifts to untested areas after approval, and to capture undocumented historic structures that may be demolished.
• Cost and Burden Debate: Committee members raised concerns about the significant cost of surveying entire properties (e.g., $52,000 for 32 acres). Some argued it would add to housing costs, while others noted it is a small fraction of total development costs. Alternative approaches were discussed: a process fix at the grading permit stage to catch changes, or allowing exclusion of areas not intended for development (e.g., floodplains, conservation easements). Staff noted the difficulties of implementing checks at the building permit stage without additional staffing.
• Submission to DHR (Virginia Department of Historic Resources): A new requirement was proposed that digital copies of phase one surveys and shapefiles be submitted to DHR to create a central repository. Currently, many surveys are not submitted. The committee generally supported this as beneficial for long-term record-keeping.
• Tech Memo Changes: Staff presented updates from the existing Technical Memorandum, including: allowing the county archaeologist (rather than the director) to approve a cultural resources management summary report; and narrowing the eligibility for an abbreviated report to only cases where no archaeological resources are found (removing the previous option where a consultant could request a summary report even if resources were identified but deemed not warranting further investigation). After discussion, the committee favored retaining the broader language to allow abbreviated reports when the archaeologist determines resources do not require further study, in order to reduce unnecessary voluminous reporting.
• Reconnaissance Survey Standards (Section 7.810): New standards formalize the reconnaissance (walkover) survey from the tech memo. Exceptions to the full property survey were discussed for special cases: telecommunications lease areas, utility easements, and county road rights-of-way, where only the lease/easement/right-of-way area must be surveyed. The committee suggested reorganizing these exceptions under the methods section rather than in the introductory paragraph.
• Previously Developed Properties: A provision allows a desktop reconnaissance survey (no field work) for properties that are already completely developed (paved, landscaped, etc.) to fulfill the reconnaissance requirement.
• Reporting and Application Number: Staff debated whether the FSM should require applicants to provide the previous application number on plans to reference an existing phase one survey. The committee concluded that providing the name, date, and preparer of the previous survey on the plan is sufficient; the application number may be noted internally.

Key Outcomes

• No votes or formal decisions were taken. The committee agreed to continue the discussion on the phase one survey scope and cost solutions at the next meeting (scheduled for Thursday, April 2, 2026, Dulles Room).
• Staff will refine the proposed amendments based on committee feedback, including: clarifying cemetery buffer language in section 7.304 B as applying to records only; preserving the broader eligibility for abbreviated reports; reorganizing reconnaissance survey exceptions; and addressing the application number requirement.
• The committee will also consider potential processes to capture changes at later permit stages as an alternative to requiring whole-property surveys upfront.