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February 27, 2001

Queen Anne’s County Commissioners
107 North Liberty Street
Centreville, MD 21617

RE: Four Seasons Growth Allocation Request

Dear Commissioners:

Please accept this comment letter for consideration in your decision on the proposed Four Seasons project request for growth allocation.  The Chesapeake Bay Foundation requests that the commission require the applicant to correct various areas of non-compliance with critical area requirements pertaining to growth allocations to IDA, and resubmit its growth allocation application.

In summary, pertaining to IDA growth allocations, the Queen Anne’s County Critical Area Program requires that:

1. expansion of IDA into RCAs be minimized;

2. new IDA be located in order to minimize impact to habitat protection areas that;

3. new IDA converted from RCA be located 300 feet beyond the landward edge of tidal waters and wetlands;

4. development is clustered when new IDA is converted from RCA;

5. the design of the development enhances water quality and resource and habitat values; and

6. public access to the shoreline be established or maintained

In our view the following areas of noncompliance with the foregoing requirements exist with the Four Seasons concept plan:

1. The extent of the proposed IDA is excessive and could be significantly reduced by clustering the proposed development to a much greater degree.

2. New IDA is located within 100’ of tidal waters.  The plan should be revised to relocate IDA to a distance of 300’ from tidal waters and wetlands.  This could easily be accomplished by clustering the proposed development.

3. The Cox Creek road crossing is likely to impact wetlands. A clear-span bridge structure should be used to minimize wetlands impacts.

4. Stormwater management ponds are located in buffer areas.  They should be removed from the buffer in all cases.

5. Forest cover, including FIDS habitat, will be lost.  Clustering the development could avoid the loss of existing forest cover.

6. The project includes more impervious surface area than necessary, which will negatively impact water quality and stormwater management.  Clustering the project would minimize these impacts.

7. Public access to the shoreline is minimal.  Public access should be provided to and along the entire length of tidal shoreline.

The large size of the proposed development offers the developer a great deal of flexibility in developing the site in a manner fully consistent with critical area requirements.  Well designed clustered development should permit the applicant to fully comply with habitat protection and stormwater requirements and preserve extensive tracts of open space.  The concept plan as submitted falls far short of capitalizing on the advantages of well designed cluster development.

Thank you for this opportunity to provide comments.


George J. Maurer, Senior Planner

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