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00SN0126-FEB9.pdf................... CPC February 9, 2000 BS STAFF'S REQUEST ANALYSIS AND RECOMMENDATION 00SN0126 (AMENDED) Tidewater Fibre Corporation - Michael Benedetto Bermuda Magisterial District West line of Old Stage Road (AMENDED) Rezoning from Light Industrial (I-1) to Heavy Industrial (I-3) plus Conditional Use Planned Development to allow setback exceptions plus proffered conditions on an adjacent parcel currently zoned Heavy Industrial (I-3). pROPOSED LAND USE: A curbside recycling and reclamation center is planned. However, with approval of this request other I-3 uses would be permitted. PLANNING COMMISSION RECOMMENDATION RECOMMEND APPROVAL SUBJECT TO THE CONDITION AND ACCEPTANCE OF THE PROFFERED CONDITIONS ON PAGES 2 THROUGH 4. AYES: MESSRS. CUNNINGHAM, GECKER AND LITTON. ABSTENTIONS: MESSRS. GULLEY AND MARSH. Providing a FIRST CHOICE Community Through Excellence in Public Service. STAFF RECOMMENDATION Recommend approval for the following reasons: The proposed zoning and land uses conform with the Eastern Area Land Use and Transportation Plan which suggests the property is appropriate for general industrial use. The proposed zoning and land uses are compatible with, and representative of, existing and anticipated industrial development along this portion of Old Stage Road. The requested setback exceptions wouM be appropriate since the Plan suggests that the adjoining properties are appropriate for general industrial use. (NOTE: CONDITIONS MAY BE IMPOSED OR THE PROPERTY OWNER MAY PROFFER CONDITIONS. THE CONDITIONS NOTED WITH "STAFF/CPC" WERE AGREED UPON BY BOTH STAFF AND THE COMMISSION. CONDITIONS WITH ONLY A "STAFF" ARE RECOMMENDED SOLELY BY STAFF. CONDITIONS WITH ONLY A "CPC" ARE ADDITIONAL CONDITIONS RECOMMENDED BY THE PLANNING COMMISSION.) (STAFF/CPC) In conjunction with the approval of this request, exceptions shall be granted to allow setbacks to be regulated as though adjacent properties were zoned 1-3. (P) PROFFERED CONDITIONS (STAFF/CPC) 1. Prior to any site plan approval, thirty-five (35) feet of right-of-way on the west side of Old Stage Road, measured from the centerline of that part of Old Stage Road immediately adjacent to the property, shall be dedicated, free and unrestricted, to and for the benefit of Chesterfield County. (T) (STAFF/CPC) 2. Direct access from the property to Old Stage Road shall be limited to one (1) entrance/exit, located towards the southern property line. The exact location of this access shall be approved by the Transportation Department. Prior to any site plan approval, an access easement, acceptable to the Transportation Department, shall be recorded across the property to ensure shared use of this access with adjacent properties. (T) 2 00SN0126/WP/FEB9I (STAFF./CPC) STAFF/CPC) (STAFF/CPC) Prior to issuance of an occupancy permit, the ditch along the west side of Old Stage Road shall be relocated to provide an adequate shoulder for the entire property frontage, and additional pavement shall be constructed along Old Stage Road at the approved access to provide left and right turn lanes, based on Transportation Department standards. The developer shall dedicate to Chesterfield County, free and unrestricted, any additional right-of-way (or easements) required for these road improvements. (T) The County wastewater system shall be used. (U) The following shall not be permitted. Contractors' offices, shops and storage yards. Cottonseed oil milling. Other fabricated metal products manufacturing not otherwise listed in this chapter. Paint and varnish manufacturing. Storage yards. Abrasive, asbestos and miscellaneous non-metallic mineral products manufacturing. Blast furnaces, steel works and rolling and finishing ferrous metals. Fuel (gas or liquid) distribution storage. Cement (hydraulic) manufacturing. Chrome plating and anodizing. Coal and coke storage. Concrete, gypsum and plaster products manufacturing. Crematoriums. Grain mill products manufacturing. Iron and steel foundries. Leather tanning. Gas production plants, natural or manufactured gas storage and distribution points and other gas utilities. Nonferrous foundries and other primary metal industries. Paper, pulp and allied products manufacturing. Paper recycling by the chemical method. Primary smelting and refining of nonferrous metals. Rolling, drawing and extruding of nonferrous metals and alloys. Rubber and miscellaneous plastic products manufacturing. 3 OOSN0126/WP/FEB9I Secondary smelting and refining of nonferrous metals and alloys. Provided, however, that the recycling of any material permitted to be manufactured in the Heavy Indus~al (I-3) District shall be permitted, excluding the recycling of motor vehicles or other machinery or parts thereof, washing machines, dryers and structural steel. (P) (STAFF/CPC) Any crashing, bailing or shredding associated with a recycling process shall be conducted entirely within an enclosed structure. (P) (STAFF/CPC) Any recycling facility shall apply to the VirgLn_ia Departmem of Transportation to enroll in the "Adopt a Highway" program for the length of Old Stage Road from Route 10 to Osborne Road. If the application is approved, the recycling facility shall participate in the program for as long as the facility is located on the property. (P) (STAFF/CPC) Development shall conform to the requirements of the Zoning Ordinance for 1-3 Districts except as amended by this rezoning case. No Development Standards Waiver or Variance shall alter this condition. (P) GENERAL INFORMATION Location: Fronts the west line of Old Stage Road, south of Coyote Drive. Tax ID 802-657-9750 and 803-657-0311 (Sheet 27). I-landI-3 15.2 acres 4 OOSNO126/WP/FEB9I Vacant Adjacent Zoning & Land Use: North - I-3; Industrial South & West - I-I; Vacant East - I-3 and A; Vacant Public Water System: Public There is an existing twelve (12) inch water line extending along the eastern side of Old Stage Road, adjacent to the request site. Use of the public water system is required by County Code. Wastewater System: There is an existing twenty-seven (27) inch wastewater trunk line extending along Redwater Creek, approximately 460 feet southwest of the request site. In addition, there is an existing twelve (12) inch wastewater trunk line extending along the eastern side of Old Stage Road and ending at Coyote Drive, approximately 840 feet north of the request site. The use of the public wastewater system has been proffered. (Proffered Condition 4) The subject property drains in several directions to Redwater Creek and ultimately the James River. It appears that the property may have been used as a borrow pit in the past. It may be necessary to obtain off-site easements to accommodate runoff from development of the property. Fire Service: The property is currently served by the Dutch Gap Fire/Rescue Station, Company Number 14 and Bensley-Bermuda Rescue Squad. When the property is developed, the number of 5 00SN0126/WP/FEB9I hydrants and quantity of water needed for fire protection will be evaluated during the plans review process. Transportation: This request will not limit development to a specific land use; therefore, it is difficult to anticipate traffic generation. Based on light industrial trip rates, development could generate approximately 880 average daily trips. These vehicles will be distributed along Old Stage Road which had a 1999 traffic count of 4,303 average daily trips. The Ih~rgggll~Pg~ identifies Old Stage Road as a collector with a recommended right of way width of seventy (70) feet. The applicant has proffered to dedicate thirty-five (35) feet of right of way, measured from the centerline of OM Stage Road, in accordance with that Plan on that portion of the property to be rezoned to I-3. (Proffered Condition 1) Development must adhere to the Zoning Ordinance, relative to access and internal circulation (Division 5). Access to collectors, such as Old Stage Road, should be controlled. The applicant has proffered to limit direct access from the property to be rezoned to I-3 to Old Stage Road to one (1) entrance/exit, located towards the southern property line (Proffered Condition 2). The proffer requires that an access easement be recorded across the property to be rezoned to ensure shared use of this access with adjacent properties. Mitigating road improvements must be provided to address the traffic impact of this development. The applicant has proffered to relocate the ditch to provide an adequate shoulder along the west side of Old Stage Road for the entire property frontage of that part to be rezoned to I-3 and construct additional pavement along Old Stage Road at the approved access to provide left and right turn lanes, based on Transportation Department standards. (Proffered Condition 3) At time of site plan review, specific recommendations will be provided regarding access and internal circulation. Comprehensive Plan: Lies within the boundaries of the Eastern Area Land Use Plan which suggests the property is appropriate for general industrial use. 6 00SN0126/WP/FEB9I Area D~velopment Trends: Area properties to the north, south and west are zoned for industrial uses and are vacant. The property to the east is zoned Agricultural (A) and is vacant. It is anticipated that area properties will be developed for industrial uses in accordance with the recommendations of the Plan. The request property lies within an Emerging Growth Area. New construction must conform to the requirements of the Zoning Ordinance which address access, parking, landscaping, architectural treatment, setbacks, signs, buffers, utilities, and screening of dumpsters and loading areas. The applicant is seeking relief of setback requirements on that part of the property to be rezoned to I-3. Specifically, in some instances the Ordinance requires different setbacks in I-3 Districts where adjacent to Agricultural (A) and Light Industrial (I-l) Districts. Since the Plan suggests surrounding property should eventually be zoned and developed for I-3 uses, the applicant is seeking permission to allow adjacent properties to be considered zoned I-3 for the purposes of setbacks (Condition). Specifically, the Ordinance requires a 200 foot setback where I-3 is adjacent to I-1. This application proposes a mi,imum of a ten (10) foot setback along the southern boundary where adjacent to I-1 zoning. This would be the required setback if the adjacent property were zoned I-3 consistent with the recommendations of the Plan. Proffered Condition 8 would require compliance with Zoning Ordinance requirements for 1-3 Districts, except as modified by this request, unless a future zoning case amends the requirement. In short, although a Development Standards Waiver or Variance may be granted, the applicant has agreed that the approval would not be exercised without an amendment through the Planmng Commission and Board of Supervisors to this zoning case. This proffer was submitted in response to area residents' concerns relative to future compliance with Ordinance requirements. Architectural treatment of buildings, including materials, color and style, must be compatible with buildings located within the same project. Compatibility may be achieved through the use of similar building massing, materials, scale, colors and other architectural features. Within Emerging Growth Areas, no building exterior which would be visible to any Agricultural (A) District which is not vacant or any public right of way may consist of architectural materials inferior in quality, appearance or detail to any other exterior of the 7 00SN0126/WP/FEB9I same building. There is, however, nothing to preclude the use of different materials on different building exteriors, but rather, the use of inferior materials on sides which face adjoining property. No building exterior may be constructed of unpainted concrete block or corrugated and/or sheet metal. No portion of a building constructed of unadorned concrete block or corrugated and/or sheet metal may be visible from any adjoining A property which is occupied by a house or any public right of way. In I-3 Districts, junction and accessory boxes need not be minimized from view of any I-2 or I-3 District or from any public right of way which does not accommodate or is not intended to accommodate through traffic movements. The view of junction and accessory boxes must be minimized from view of adjacent I-1 and A properties as well as from Old Stage Road. This requirement does not apply to any Agricultural (A) property which is vacant and designated for I-2 or I-3 uses. Mechanical equipment, whether ground-level or rooftop, need not be screened from view of any 1-2 or I-3 District or from any public right of way which does not accommodate or is not intended to accommodate through traffic movements. Mechanical equipment must be screened from view of adjacent I-1 and A properties and Old Stage Road. If adjacent Agricultural (A) property is vacant and designated for I-2 or I-3 uses, this requirement does not apply. Solid waste storage areas (i.e., dumpsters, garbage cans, trash compactors, etc.) need not be screened from view of any I-2 or I-3 District or any public right of way which is not intended to accommodate through traffic. Solid waste storage areas must be screened from view of any I-1 District and Old Stage Road and any Agricultural (A) property which is not vacant. Screening may be accomplished by a solid fence, wall, dense evergreen plantings or architectural feature. In addition, sites must be designed and buildings oriented so that loading areas are screened from any property where loading areas are prohibited and from public rights of way. With the approval of this request, outside storage would be permitted. Outside storage areas must be screened from view of adjacent properties on which such uses are not permitted and from areas and public rights of way. Outside storage includes, but is not limited to, the parking of all company owned vehicles, except passenger vehicles and trucks which have cargo areas that may be accessed from the driver's seat without existing the vehicle. 8 00SN0126/WP/FEB9I Proffered Condition 7 would require participation in VDOT's "Adopt a Highway" program if approved by VDOT. This proffered condition was submitted to address concerns of area residents concerning the potential for debris along Old Stage Road from trucks utilizing any recycling facility. The proposed zoning and land use conform with the Eastern Area Land Use and Transportation Plan which suggests the property is appropriate for general industrial use. In addition, the proposed zoning and land uses are compatible with, and representative of, existing and anticipated industrial development along Old Stage Road. The requested setback exceptions would be appropriate since the Plan suggests that the surrounding property is appropriate for general industrial use (Condition). Given these considerations, approval of this request is recommended. CASE HISTORY Planning Commission Meeting (10/19/99): The Commission, on their own motion, deferred this case to their November 16, 1999, public hearing to allow an opportunity for the applicant and area property owners to meet and discuss the proposal. Staff (10/20/99): The applicant was advised in writing that any significant new or revised information should be submitted no later than October 25, 1999, for consideration at the Commission's November 16, 1999 public hearing. Applicant, Area Property Owners, Bermuda District Commissioner and Staff (10/28/99): A meeting was held to discuss the proposed zoning and the details of the specific use intended, a recycling facility. The applicant generally agreed to submit a proffered condition to restrict the I-3 uses that would be permitted on the property. 9 00SN0126/WP/FEB9I Applicant (11 / 15/99): The applicant submitted the following proffered condition for that part of the property currently zoned I-1: Uses permitted shall be limited to those uses permitted in the Light Industrial (I-l) District plus the recycling of any material permitted to be manufactured in the Heavy Industrial (I-3) District. Provided, however, that recycling shall not include the recycling of motor vehicles or other machinery or parts thereof. Planning Commission Meeting (11/16/99): On their own motion, the Commission deferred this case to their December 13, 1999, public hearing. Staff (11/17/99): The applicant was advised in writing that any significant new or revised information should be submitted no later than November 22, 1999, for consideration at the Commission's December public hearing. Applicant, Area Property Owners, Bermuda District Commissioner and Staff (11/18/99): A meeting was held to discuss the proposal. The applicant agreed to amend the request to include currently zoned I-3 property and to offer proffered conditions on that property. Area property owners were to provide the applicant with a list of uses that they had concerns with. Applicant (11/19/99): The request was amended, as reflected herein. Applicant (12/7/99): The applicant withdrew the proffered condition restricting the uses permitted on the tract currently zoned I-1. 10 00SN0126/WP/FEB9I Staff (12/9/99): To da~e, the applicant has not submitted any proffered conditions on the tract currently zoned I-3. Area property owners had not provided the applicant with a list of uses that they have concerns with. Applicant (12/13/99): Two (2) additional proffered conditions for both the existing and proposed 1-3 tracts were submitted to restrict the uses permitted on the property and to require that any crushing, bailing or shredding associated with a recycling process shall be conducted entirely within an enclosed structure (Proffered Conditions 5 and 6). Further, the applicant agreed to include the previously submitted four (4) proffers for the entire 15.2 acre tract. Planning Commission Meeting (12/13/99): The Commission, on their own motion, deferred this case to their January public hearing. Staff(12/14/99): The applicant was advised in writing that any significant new or revised information should be submitted no later than December 20, 1999, for consideration at the Commission's January public hearing. Board of Supervisors' Meeting (12/15/99): The Board, on their own motion, deferred this case to their January public hearing, pending the Planning Commission's recommendation. Applicant, Area Property Owners, Staff and the Bermuda District Commissioner (12/28/99): A meeting was held to discuss the proposed zoning. The applicant agreed to consider submission of additional proffered conditions to address quality of stormwater runoff; odor and sound control; cleaning up of debris along area roads which may fall off of tracks coming to the site; future exceptions to Zoning Ordinance requirements; submission of site plans to the Planning Commission and further clarification of the term "structural steel". 11 00SN0126/WP/FEB9I It was generally agreed that an additional meeting would be held on January 10 to review any new or revised information or proffered conditions. Applicant, Area Residents, Staff and the Bermuda District Commissioner (1/10/00): A meeting was held to review additional proffered conditions which were developed as a result of the meeting on December 28, 1999. As a remit of the meetings, the applicant offered two (2) additional proffered conditions to address concerns about the potential for debris along Old Stage Road from trucks utilizing any recycling facility and future Development Standards Waivers or Variances. (Proffered Conditions 7 and 8) Planning Commission Meeting (1/18/00): The applicant accepted the recommendation. A representative of area citizens indicated that if the proffered conditions and Ordinances are enforced, the proposed recycling facility should not adversely affect the area. He indicated that area residents trusted the County to enforce the requirements. On motion of Mr. Cunningham, seconded by Mr. Litton, the Commission recommended approval of this request subject to the condition and acceptance of the proffered condition on pages 2 through 4. AYES: Messrs. Cunningham, Gecker and Litton. ABSTENTIONS: Messrs. Gulley and Marsh. Board of Supervisors' Meeting (1/26/00): Due to inclement weather, the Board deferred this case to February 9, 2000. The Board of Supervisors, on Wednesday, February 9, 2000, beginning at 7:00 p.m., will take under consideration this request. 12 00SN0126/WP/FEB9I NZ A I-3 c-5" ## % # 5 A I-1 ! ! N Case #: 00SN0126 (AMENDED) Rezoning: ~i I-3 W/PROFFERS ~ I-1 TO I-3 W/C.U,P.D. Sheet #: 27 ¥ ¥ I I I '1 N February 8, 2000 VIA HAND DELIVERY AND U.S. CERTIFIED MAIL Mr. Michael B. Hamar Tavss, Fletcher, Maiden, and King, P.C. Post Office Box 3747 Norfolk, Virginia 23514 Dear Mr. Haman On January 13, 2000 1 received three copies of a letter that alleged that I was "circulatin..g untruths about TFC in general and its operations in Chesterfield County in particular, including allegations of (I) questionable character and (II) building code and/or zoning violations." Also copied on that letter was my father, Ashley Weatherford. I was initially befuddled as to why I received the letter and perplexed as to why a member of my family was copied on that letter. I have attached a citizen complaint that I handed to Mr. William D. Dupler, Building Official, County of Chesterfield. That is my response to the letter I received from you on January 13, 2000. Inc. Citizen Complaint CC: Ashley Weatherford Michael Benedetto Richard (Dickie) King Jr. February 8, 2000 VIA HAND DELIVERY Mr. William D. Dupler Building Official County of Chesterfield Department of Building Inspections P.O. Box 40 Chesterfield, Virginia 23832 Dear Mr. Dupler: I would like to make an official citizen compliant against Tidewater Fibre Corp located at 14500 Jefferson Davis Highway, Chester, Virginia. On January 18, 2000 1 requested (document 1) under the Virginia Freedom of Information Act the following information on Tidewater Fibre Corp or ANY business representing 14500 Jefferson Davis Highway during the period of April 1999 through January 17, 2000: The issuance or denial of any application(s) or permit(s) for the following: a.) Above ground fuel storage b.) Electrical permits c.) Any building renovations On Saturday, January 29, 2000 1 received a letter (document 2) with your response to the above request, the letter stated, "We have not received any permit applications for 14500 Jefferson Davis Highway from April 1999 to date." I am very concerned for the current Tidewater Fibre Corp employees located at 14500 Jefferson Davis Highway. I have first hand knowledge of Tidewater Fibre Corp "knowingly and willingly" circumventing Chesterfield County's permitting processes. I have enclosed a letter (document 3) that I sent to what I feel is one of the most respectable contractors in the Richmond area, W.J. Rapp. I have also enclosed their response (document 4). These letters will explain my first hand knowledge in addition to the building renovations that were done to that facility. The following are my concerns: The pits that were dug and reinforced at the 14500 Jefferson Davis Highway facility were not permitted nor inspected. The pit that is 60 feet long by 6 feet wide by 6-8 feet deep, has above ground sorting ~platform structures surrounding both sides that could be occupied by as many as 30 people at one time. Since no permits were obtained then there are no engineered drawing~ to assure that: (1) the pits were reinforced correctly, (:~) there is not an excessive "load bearing' on those pit walls. The entire processing portion of the facility was rewired without electrical permits or inspections. I am talking about a major rewiring job. Tidewater Fibre Corp services 204,000 households bi-weekly in Central Virginia for curbside recycling. On an average day they dump 70 tons of residential mix paper inside that facility. A facility that does not have an overhead sprinkler system. It only takes one spark or a small amount of heat to ignite paper. As an employee with Tidewater Fibre Corp I expressed these concerns to the General Manager and the Vice-President. I was basically told not to "worry about it". Unfortunately, I have worried about this from the outset. My employment came to an end with Tidewater Fibre Corp on October 14, 1999. Although, I have known about these violations for quite some time I did not know how to go about insuring the employees safety at that facility while at the same time not bringing to much attention to myself and my family. On January 11, 2000 1 was contacted by Mr. Richard (Dickie) King Jr. who is ' representing a group of Chesterfield County residents who are opposed to having some land re-zoned on Old Stage Road that Tidewater Fibre Corp owns. Mr. King told me that he heard from someone that I might have some information that could help them. He told me that he had mentioned my name to Tidewater Fibre Corp officials in an audio taped meeting. Mr. King simply asked them, "Do you know a gentlemen by the name John Weatherford." In which they responded, "Yes." Mr. King said that it wasn't their verbal response that made him believe that I had information that could help them, it was the look on their face when he mentioned my name to them. That question apparently caused some concern within Tidewater Fibre Corp. On January 13, 20001 received three copies of a letter from Tidewater Fibre Corp's corporate counsel (document 5) and they copied my father, Ashley Weatherford. I was very shocked to receive this letter because I had made zero comments about Tidewater Fibre Corp to anyone. I met with Mr. King and showed him the letter from Tidewater Fibre Corp's corporate counsel. He explained to me that I did not have to tell him anything. I told him that I was tired of being "strong armed" by Tidewater Fibre Corp. I asked him if there was a way that I could go to the Chesterfield County Courthouse to find out if what I knew Was true. After, I explained to him the violations I thought to be true', he said I could request that information under the Virginia Freedom of Information Act, which has brought me to this point. The guidance I have received from Mr. Richard (Dickie) King, Jr. has been greatly appreciated and what he is doing for the group of Chesterfield County residents is very honorable. I may be viewed as a disgruntled or vengeful former employee, however; I feel I am doing what is right. I am now relieved that I have shared the permit violations that I have known for quite some time. I am sure that Chesterfield County requires the permit process so as to insure safety of buildings and residential properties. I am confident that you will see that the right thing is done to insure the safety of the employees at Tidewater Fibre Corp. I realize that some of the information contained in this letter you did not need. Due to the circumstances, I felt it needed to be provided to establish my credibility and so it could be placed on public record. Thank you for your attention to this matter. Chesterfield County Resident Inc.documents 1-5 Sanuary 18, 2000 William D..Duper Building Official County of Chesterfield Department of Building Inspections P.O. Box 40 Chesterfield,. Virginia 23832 John A. Weatherford 6401 Trailview Circle, 103 Chester, Virginia 23831 Dear Mr. Duper: Under the Virginia Freedom of Information Act, I request the foliowing information on Tidewater Fiber Corp located at 14500 Jefferson Davis Highway, Chester, Virginia 23831 or ANY Business representing that location during the period of April 1999 to January 17, 2000. .1. The issuance or denial of any application (s) or permit (s) for the following: a.) Above Ground Fuel Storage b.) Electrical Permits, c.) Any Building Renovations It is ~ay understanding that I can expect a response from the County within 5 working days. This is of great importance to me and if there should be a cost for the printing of information please accept my willingness to pay. Please call if there is a need. Chesterfield County Resident Received by: Date: BOARD OF SUPERVISORS HARRY G. DANIEL CHAIRMAN DALE DISTRICT ARTHUR S. WARREN VICE CHAIRMAN CLOVER HILL DISTRICT J. L. McHALE, III BERMUDA DISTRICT RENNY BUSH HUMPHREY MATOACA DISTRICT EDWARD B. BARBER MIDLOTHIAN DISTRICT CHESTERFIELD COUNTY DEPARTMENT OF BUILDING INSPECTION P.O. ROX 40 CHESTERFIELD, VIRGINIA 23832-0040 WILLIAM D. DUPLER, BUILDING OFFICIAL PHONE: 748-1057; FAX:(804) 751-471 3 January 18, 2000 LANE B. RAMSEY COUNTY ADMINISTRATOR John A, Weatherford 6401 Trailview Circle, 103 Chester, VA 23831 Re: Your Freedom of Information Act Request 14500 Jefferson Davis Highway Dear Nr. Weatherford: This is in response to your January 18, 2000 Freedom of Information Act request. We have not received any permit applications for 14500 Jefferson Davis Highway from April 1999 to date. Cordially, jW-C /A:W16j,wddjaw, FOl& 14500JeffDavisHwy 6401 Trailview Circle #I03 Chester, VA 23831 (804) 334-6823 W.J. Rapp Richmond, VA Dear W.J. Rapp: During the second week of May 1999, I (while employed as Operations Manager for Tidewater Fibre Corp) was asked by Tidewater Fibre Corp to call and find a contractor to come out and give a quote on having two pits dug at the Tidewater Fibre Corp location of 14500 Jefferson Davis Highway, Chester, Virginia. I received W.J. Rapp's name from a friend who had said that you where a very reputable company. I called W.J. Rapp and asked if a representative from your company could come out to the Tidewater Fibre Corp location and give us a quote on having these pits dug and reinforced by June 1, 1999. Mr. Winder was the W.J. Rapp representative that came out to give the quote on having the pits dug. He explained that W.J. Rapp was very busy and that it would be extremely difficult to have the pits dug and reinforced by June 1, 1999. The approximate dimensions of the pits were (1) 60 feet long by 6 feet wide by 6-8 feet deep (2) 12 feet long by 6 feet wide by 6-8 feet deep. Mr. Winder also said that W.J. Rapp could break the concrete and dig the pit~s, but they would not begin to start reinforcing the pit until building permits had been secured which included engineered drawings on how to reinforce the pits. Mr. Winder stated that the permit approval process was at 5-7 days in Chesterfield County. What I need from W.J. Rapp is a letter confirming that Mr. Winder did in fact communicate the above and anything that Mr. Winder may remember regarding those days events at Tidewater Fibre Corp, 14500 Jefferson Davis Highway, Chester, Virginia. Thank you very much for your attention to this request. It is of great importance to me. 3~m~A.~~Weatherford John A. Weatherford 6401 Trailview Circle # 103 Chester. Va. 23831 1/2 Mr. Wcathefford. I have received your letter of 1/I 9/00. I coucur with the basic contour of thc letter, and will hereby trS.' Io provide file details that I remember. I did. at your request, visit tile site at 14500 Jefferson Davis Highway. To tile best of lnv rccollcction, the visit took place in May, though I can't say exactly which day. When I arrived on site. v'ou were present and a gentleman from tile equipment supplier was present. I recall that the other gentlema'u possibly was from Baltimore. but I dou't recall the name of his company. Once you had described lhe project to mc. 1 told you fllat wc were very busy. and could not meet a completion date of June l'~t. l also asked you about engineered drawings and a building permit. The drawings were necessary to obtain the permit and to ensure the proper construction of tile pits. As I rccail. you didn't have any knowledge of any existing drawings or whether or not a p~nnit process had beeu started. You placed a phone call to your boss, in Virginia Beach, and asked about drawings and permits. You told me flint your boss had told you on the phone that he would handle those items, but he did not have drawings or permits in hand. I told you that since you didn't even have drawings, there was no wav to obtain a permit and complete the project within your timeframe. I then gave you some names of e~ginccrs to contact, wished you luck and left the site. I did not have any further dealings with the project, nor with your company. Tiffs is everything that I recall about tile meeting that you have asked about. I do not have ally notes. sketches or other paperwork referring to this meeting. Sincerely,. . ,, ..c.: ..... David Winder 608 Marx. St. · Richmond, VA 23224 · Office: (804) 231-4201 · Fax: (804) 232-4844 www.wirapp.com, wjrappco@aol.com RICHARD J. TAVSS ~ R. FLETCHER' RAY W. laNG BESIAJ~E TAVSS MA/DEN J,,,YO.IAEL B. ~ KEVIN J. O'LEARY CHRISllANNA IL DOUGHERTY TAVSS, FLETCHEI , DEN KING, P.C. FIR.ST VIRC_~NIA BA~IIC TOV~.R 555/~AAIN STREET NORr-CY~, VIRGINIA 23510 TEl' 757-625-1214 REPLY TO: POST OFFICE BOX 3747 NORFOLK, VIRGINIA 23514 FAX: 757-622-7295 E MAIL: TAVSStJTAVSS.COM January 12, 2000 VIA FACSIMILE/HAND DELIVERY, OVERNIGHT DELIVERY AND U.S. CERTIFIED MAIL Mr. John A. Weatherford 6401 Trailview Circle, Apt. 103 Chester, Virginia 23831 Dear Mr. Weatherford: Re: Malicious Statements Against and Denigration of Tidewater Fibre Corp. This firm serves as corporate counsel to Tidewater Fibre Corp. ('q'FC") and its affiliated entities. Unfortunately, it has come to my client's attention that you have been circulating untruths about TFC in general and its operations in Chesterfield County in particular, including allegations of (i) questionable character and (ii) building code and/or zoning violations. Such actions are apparently motivated by a desire for revenge against TFC for your termination for cause as TFC's Operations Manager of TFC's interim facility in Chester, Virginia. You have been identified to TFC by name as the perpetrator of such malicious and false statements. As a result of your unwarranted conduct, TFC has experienced unnecessary cost and expense, as well as delays in its business operations. Please be advised that if your wrongful acts and libelous statements do not cease immediately, TFC will have no choice but to take appropriate action to (i) protect its :name and reputation and (ii) recover against you personally for the consequences of your malicious conduct. My client sincerely hopes that it will not be necessary to take such further actions. Should you wish to discuss this situation, please contact the undersigned. Very truly yourS,, Michael B. Hamar cc: Michael Benedetto Ashley Weatherford