ANNAPOLIS, Md. (July 25, 2017) – Today, the leadership and supporters of Stop Crystal Spring urged the City of Annapolis Planning and Zoning Department to reject without further review a plan filed by Crystal Spring developers, citing their use of an outdated Forest Stand Delineation, in addition to numerous unresolved issues raised related to traffic and the environment.
“Despite our best efforts to work with the developers to reach an amicable resolution, they have failed to resolve most of the concerns we have raised as well as those raised by City planners,” said former State Senator Gerald Winegrad, Stop Crystal Spring coordinator. “Clearing almost 27 acres of priority forest and replacing it with 383 more housing units, 48 assisted living units, parking for at least 500, new roads and a new intersection is going to have an immense environmental impact and exacerbate existing traffic problems.”
The Forest Conservation Plan (FCP) filed today is the first plan formally filed by National Lutheran Communities and Services (NLCS) since announcing that the original development partnership had dissolved and that they would be seeking approval for only a senior housing community on part of the property.
The NLCS FCP is critically defective as it is based on outdated information as much as seven years old. Under the Forest Conservation Act, developers are required to start with a Forest Stand Delineation (FSD), an inventory of all the forests and natural resources found on a property. This includes detailed field work about the type, age, and health of trees found on site. This FSD must be approved before the developers can submit a Forest Conservation Plan (FCP) and detailed site plan.
As part of NLCS’ FCP filing, they are using an FSD for Crystal Spring forests that was previously filed by developers as part of the prior proposal and was approved by the City back in 2013. However, this old FSD uses data field collected in 2010 and 2011. Many of the trees on the site undoubtedly have grown since that time and the forest likely has changed somewhat. The City Planning staff has discretion to require NLCS to file a new FSD and should do so.
Aside from this critical issue, there are a number of serious problems related to the development plan itself. The NLCS proposal includes the acquisition of 73 acres of the approximately 111 acres at Crystal Spring leaving open the question of development of the remaining 38 acres in the future.
Another major issue is the plan to clear 27 acres of Priority Forest that is supposed to be protected under the Forest Conservation Law. The law requires that these forests “be left in an undisturbed condition unless the applicant has demonstrated, to the satisfaction of the City that reasonable efforts have been made to protect them and the plan cannot reasonably be altered.” NLCS has not met this burden. Also unresolved is where on site or on adjoining land all forest cleared would be replanted.
NLCS has failed to provide a comprehensive stormwater management plan to address polluted runoff from the project which would meet assurances that 100 percent of stormwater is managed/treated on site so as not to increase pollutant loads. The entire 111-acre site drains directly into Crab Creek off the South River. The River is already impaired and failing to meet Clean Water Act requirements, largely due to stormwater runoff.
Traffic issues remain unresolved and are also a major cause for concern with 500 new residents planned, along with 200 employees and delivery trucks. This would increase traffic at the failing intersection at Spa Road and Forest Drive where the developers plan to flow most traffic from the development.
“We are surprised at the failure of NLCS to address these issues of which they are acutely aware. Until they are addressed, the plans must be rejected,” stated Senator Winegrad.
About Stop Crystal Spring
Stop Crystal Spring is a diverse group of citizens and organizational leaders in the Annapolis area concerned about the massive and destructive development planned for Crystal Spring at the congested area of Forest Drive and Spa Road. Our opposition is based on the adverse impact this development will have on traffic, the environment, and our quality of life.