A recent article (The Sunday Capital, Jan. 17) reports that the Connecticut developers of Crystal Spring believe their next forest conservation plan will meet all city requirements and should be approved. This same strategy was used when three previous plans were submitted, but all three failed to meet state and city laws and were sent back. The last plan was rejected with 33 pages of comments by city agencies. The most recent plan would exceed the footprint of the entire Annapolis Towne Center and add 1,000 new residents to the city.

Missing from the public discourse are substantial impediments that should prevent approval of this massive development. These requirements are dictated by law, the annexation agreement or by commitments made by the developers. Until they are resolved, the city should suspend all processing of plans for this development:

•The 2005 resolution annexing Mas-Que Farm and Crystal Spring into the city states, “The developer of the property will make an equitable contribution to the cost of the relief road.” City officials estimate this road from Skipper Lane through Crystal Spring and across Forest Drive to Gemini Drive will cost more than $10 million. The city needs to obtain a cost estimate, and agree with the developer on the “equitable contribution.”

•The annexation resolution also dictates that a conservation easement be placed on the 75 acres at Mas-Que Farm if any development of Crystal Spring is approved. The owner of the properties pledged this land “will be put in a preservation trust to keep it undeveloped in perpetuity.” However, the draft conservation easement submitted by the developers would permit the construction of structures and dwellings as needed for any commercial agricultural purposes and the clearing of remaining forest.

The owner and developer have publicly pledged to place a separate conservation easement on all undeveloped land remaining at Crystal Spring — about 50 acres, after development. This easement would be in perpetuity and would prevent any further development. Despite these pledges, no such conservation easement has been submitted.

•The Crystal Spring plan includes nearly 500 housing units. This violates the city’s Comprehensive Plan, which caps housing units at 140. The plan, when including the 80-room hotel, also exceeds the set limit of 167,000 square feet of retail space.

•The city has acknowledged that a new traffic study must be completed to ascertain if the road system can handle the huge increase in traffic flows from this and other developments on the Forest Drive corridor. This should occur before further processing of the development plan.

•The developers pledged to replant new forest for all forest cleared by doing the plantings on the site to the extent possible, and off-site nearby. A reforestation plan should be approved before further processing, especially since the developers would clear about 40 acres of mature forest.

•The city has repeatedly documented the serious shortcomings of the stormwater management plans, which are critically important to the health of Crab Creek and the South River. The developer pledged that stormwater leaving the site after development would be as clean or cleaner than before development, and that rate or volume wouldn’t increase. Processing should cease until the city certifies such a plan.

•The 130 homes that are not age-restricted will send more students to Hillsmere Elementary and Annapolis High schools, both over capacity. Under county law, no new developments generating students can be approved for six years. The city should adhere to the county law and not allow a bad situation to get worse, threatening the quality of our children’s education.

•The possibility that Civil War Camp Parole 2 was on or near the Crystal Spring property has been documented by historians. This requires the completion of a Phase I historical survey before further plan review.

Gerald Winegrad is a former state senator from Annapolis who now leads a citizen’s coalition against the development plans for Crystal Spring. Reach him at gwwabc@comcast.net.

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