In their Aug. 22 column (The Capital), the developers of Crystal Spring would have readers believe that their efforts over the past four years have been unfairly reviewed because: "The entrenched environmental no-growth agenda lead by the Annapolis Environmental Commission has infected the process." I find this characterization of the AEC to be offensive in that it attempts to conflate advocacy for the environment with absolute opposition to growth.
Under City Code 2.48.330, the AEC is required: To be concerned with the protection and improvement of the natural health and welfare of the environment; to identify specific environmental problems; and to review matters before other City bodies affecting the environment.
In submitting its recommendations and advice to city agencies, the AEC is simply fulfilling its mission as directed by the city code. The developers would do well to work with the changes suggested by the city and the AEC to meet state and city laws for the protection of forests, wetlands, and waterways rather than attack those who assure that these laws are enforced and our dwindling natural heritage is protected.
Throughout our discussions with the developers, the AEC has always advocated for smart growth (the primary tenet being redevelopment before disrupting any priority forest). The crux of the matter is that since it would require a decrease in the scale of the development, the developers consistently refuse to work within the smart growth paradigm. Their latest plan would not only destroy more than 44 acres of city-designated priority forest, it would also eliminate habitat of wildlife species which inhabit the "interior" forest (that central part of the forest that is more protected from wind, heat, and predators). Additionally, the developers include "street" trees, and other isolated tree clusters into their calculations of preserved forest. This is contrary to the instructions provided in the State Forest Conservation Technical Manual which provides guidance for complying with the State Forest Conservation Act (FCA).
The FCA of 1991 requires that when developing a forest conservation plan, priority shall be given to techniques for retaining existing forest on site. If that cannot be done, the developer must demonstrate to the satisfaction of the permitting authority "… how techniques for forest retention have been exhausted", and why "… the priority forest and priority areas specified in Natural Resources Article, 5-1604 (c)(1), annotated Code of Maryland, cannot be left in an undisturbed condition". The city, in following this mandate is not attempting to stall the project by moving the goalposts, as alleged by the developers in their guest column. The goalposts are the same now as they were in 1991.
The developers continue to insist that the proposal is for 190 acres when it is actually 111 acres as Mas-Que Farm is not part of the development proposal. This is an inaccurate description of the property, and seems intended to support their assertion that "A total of 127 acres out of 190 will now be preserved in forest conservation, open space and critical areas where no future development will be permitted. A 50-acre wildlife corridor through the middle of the property has been created."
In reality, 75 acres of this 127 acres is Mas-Que Farm which the owner wishes to continue in equestrian use and on which she must grant a conservation easement once the city approves development of Crystal Spring. Mas-Que Farm has been cleared of most of its forest and has a road running through it as well as horse stalls, riding rings, and a house. The other 52 acres to be "preserved as forest" include areas around houses, stores, parking places, and roads not directly developed. The developers are not creating a 50-acre wildlife corridor - a much larger one already exists that will be diminished by the development.
The developers have tried to discredit the AEC and marginalize all those who want to protect the environment. In doing this, they short change the public.
Annapolis Environmental Commission