Many new details continue to emerge about the National Lutheran Communities and Services’ (NLCS) plan to develop a continuing care retirement community (CCRC) at Crystal Spring, which they are now calling Providence Point. While NLCS has said they will not formally submit their plan to the City until later this spring, they have published a sketch on their website along with some additional details. Here’s what we know so far…

NLCS, one of three developers involved in the original proposal for Crystal Spring, recently announced that the partnership was dissolved and that they would be submitting a  “new” proposal to build 393 senior residences and 48 assisted living units on 48 acres of land at Crystal Spring. The plan would destroy 27 acres of mature, protected priority forest. The plan is not really new in that all along NLCS has been proposing a similar senior living development of nearly the same number of units, including single family homes with carports, two free-standing two-story apartment buildings, a large CCRC three-winged building, and an assisted living building. The primary difference is that the retail or commercial components of the original plan and the non-age restricted housing are not being proposed at this time.

In some respects, this “new” plan is worse than previous plans for the CCRC. For example, the CCRC apartment building, originally planned to be six stories, has been changed to two four-story wings nearly doubling the footprint and taking down many more trees. The purpose seems to be to keep the building at or under 45 feet, which enables NLCS to seek approval under a special exception process, thereby avoiding Planning Commission review. This is particularly concerning because the special exception process provides much less opportunity for public review and comment.

STILL THE LARGEST DEVELOPMENT EVER PROPOSED IN ANNAPOLIS ASIDE FROM THE TOWNE CENTRE:

• 393 senior housing units and 48 assisted living units, to be built over two phases*
  • 361 independent living apartments (between the main building and Maison Court buildings)
  • 26 single-family cottages
  • 6 duplexes
  • 48 assisted living suites
• Multiple dining venues, common spaces, a swimming pool and fitness areas, and a chapel
• Above and below ground parking areas

*Formal plan has not been submitted. Project totals subject to change.

MAJOR ENVIRONMENTAL IMPACT:

• 27 acres of Priority Forest will be destroyed
• NLCS had committed to replant all forest cleared on a one-to-one basis, but has now reneged and will only complete reforestation required by the City Forest Conservation Ordinance, which is much less stringent.
• NLCS has committed to on-site stormwater management, but their plans show a large retention pond and drainage pipe on Mas Que Farm property, which the City has already said will not be allowed. That entire 75-acre property is to be placed under a conservation easement per the Annexation Agreement.

TRAFFIC REMAINS A CONCERN:

• The senior housing project is expected to generate less traffic than the original proposal, but because the intersection at Forest Drive and Spa Road is already failing according to recent studies, any increase will exacerbate this dangerous issue.
• NLCS is planning to build a parallel (to Forest Drive) road that will run from Crystal Spring Farm Road through the property to Spa Road, but it is not clear what other improvements they will make to alleviate traffic.
• NLCS has said they are planning to use the intersection at Spa Road as the main entrance for the community with a traffic light. With traffic coming onto Spa Road from Forest Drive, this is clearly going to be a hazard.
• They have also said they are planning to have an entrance at Crystal Spring Farm Road, but are not planning to have a traffic light, which means people exiting the community will not be able to turn left onto Forest Drive.

In addition to all of these concerns with the NLCS development plan, there is still the question of whether there will be more development sought later on the remaining land at Crystal Spring. NLCS is only planning to acquire 48 acres on the northeastern part of the 111 acres at Crystal Spring, which will leave the entire western half of the property (about 66 acres) free for further development by the owner. NLCS continues to say that they have “no dog in the fight” for this remaining land, but according to City officials, including Mayor Michael Pantelides, they will be required to submit a master plan for the entire 190 acres.

It is also unclear whether there will be future development on one part of the 48 acres being acquired by NLCS. The small piece of land closest to Forest Drive is zoned commercial and, per their drawings, does not appear to be part of the conservation easement or senior development. They have not given a clear answer about what will be done with this land.

As NLCS seeks to win public support for their new plan at Crystal Spring, we’ve presented them with the following list of eight major actions that need to be taken before we can even consider withdrawing opposition. This list was also shared with City officials:

1. Conservation easement restricting further development on the remaining 66 acres on western portion of Crystal Spring and any undeveloped land on 48 acres being acquired by NLCS
2. Reduce footprint of NLCS development – clearing 27 acres of Priority Forest for approximately 400 units is still unacceptable and contrary to the law
3. Replace all trees cleared on at least a one-to-one basis, on the site or on property adjoining the site
4. Manage all stormwater on the 48-acre site with a plan guaranteeing no net increase in the rate, volume or pollutant loads from a 20-year storm event
5. Finalize exact location and terms with stringent development restrictions for the required 75-acre conservation easement on the adjoining Mas-Que Farm property
6. Resolve location of the parallel (to Forest Dr.) connector road and cost-sharing to pay for it – will it extend from Skipper’s Lane behind the CVS as planned to relieve traffic on Forest Drive?
7. Traffic resolution to prevent exacerbating problems at area intersections that are already failing – the City’s policies and guidelines prohibit new development from being approved unless traffic improvements are made
8. Complete a Phase I Archaeological Assessment for Civil War Camp Parole 2 and/or at a minimum, have archaeological monitoring during excavation