The Mid-Shore Coalition’s
Response to the
Queen Anne’s County Draft
are a coalition of people who love Maryland’s Eastern Shore, and are determined
to protect the region’s unique quality of life. We are deeply concerned
with the poorly planned growth that is consuming our communities, beautiful
countryside, and sensitive habitat of the Eastern Shore.
believe in economic development that is sustainable and capitalises on
the unique characteristics of the Eastern Shore. We believe in a
thriving economy, built upon high paying jobs and a rich quality of life.
Such a future is impossible unless we protect and promote our historic
and natural treasures and unique quality of life.
many of us live in Kent, Caroline, and Talbot Counties, the Queen Anne’s
County Comprehensive Plan is of concern to us all. While some parts
are very positive, we are deeply concerned that the Draft Plan fails to
address the central issues of our time. Therefore, we present the
following list of both the things that concern us and the things that we
are glad to support.
I. Our Concerns About The Draft
The Draft Plan Fails to Ask “How Much Growth is Too Much?”
The Draft Plan takes our current amount of growth as a given, and ignores
the issue of whether this is too much. We believe that our current
rate of residential and non-residential growth is the absolute maximum
that the County can handle without the significant deterioration of its
quality of life, and that the Plan should state this explicitly.
The Draft Plan Tries to Accommodate, Instead of Limit, Growth.
The Draft Plan should attempt to limit growth to a responsible amount,
instead of trying to accommodate all growth. Yet, aside from the
Adequate Public Facilities Ordinance (APFO), it does little to actively
curtail new construction. The Plan should call for (1) a cap on building
permits, (2) a cap on sewer hookups, and (3) rural downzoning.
The Growth Areas Cannot, On Their Own, Protect Quality of Life.
The Draft Plan assumes that the Growth Areas will preserve community character
and quality of life. We do not feel that they will, despite the fact
that they are based upon boundaries drawn by the community plans.
Without careful action to the
contrary, the growth areas will create a continuous strip of development
from the Bay Bridge to Centreville. This will replace the unique,
distinct towns that currently exist with a string of highway developments.
Our towns must remain separate, and buffered from one another by farms
and forests, as they have been for 300 years and as was contemplated in
the 1993 Comprehensive Plan. To do this, we must (1) improve clustering
restrictions on parcels between Growth Areas, as described below, (2) target
easement acquisitions to create greenways around our growth areas, and
(3) prevent the extension of the KN/S/G sewer line to Centreville, which
will generate pressure to develop properties between our towns.
Kent Island is (1) isolated
from the mainland, (2) split in two by a major highway, (3) already inundated
by beach traffic, (4) bisected repeatedly by creeks that curtail navigation,
(4) has soils that often fail perk tests, and (5) contains large amounts
of sensitive habitat. Aside from the fact that it is attractive to
developers, Kent Island is not an ideal spot for massive development.
In fact, the 1993 Plan called for only one third of all growth to take
place on the Island, when in fact one half has actually happened.
The County should make it a priority to use federal, state, and local land
acquisition dollars to acquire undeveloped land and development rights
on Kent Island, while they are still available.
The Draft Plan Does Not Protect Rural Land From Sprawl Development.
While it does suggest that we should “consider” several options, the Draft
Plan lacks decisive action.
Centreville will nearly triple
in size. If we do not create attractive, walkable new communities,
then sprawling subdivisions and strip malls will spill out along Routes
213 and 304, which the Draft Plan already says should be widened to four
lanes to accommodate growth. Where these roads intersect with 301,
the Draft Plan calls for “Rural Business”, which really means highway-oriented
strip retail at the edge of town, resembling Route 50 near Easton.
This historic and treasured County Seat deserves better treatment.
Our current Transfer of Development
Rights (TDR) and noncontiguous development policies are well intentioned,
but must be improved. Noncontiguous transfers have slowed standard
sprawl, but have replaced it with clusters of sprawl. As things stand now,
they end up producing too much poorly-designed development in rural areas
and Critical Area Resource Conservation areas. It makes no sense
to have two different transfer mechanisms - we need one coherent system
for transferring all development rights, so that all TDRs go to designated
receiving areas. The TDR program must also (1) have designated and
receiving areas, designed such that those who accommodate additional growth
can benefit from nearby open space, and (2) require a sending parcel to
show some evidence that it could actually be developed, such as a perk
test or a soils map that indicates the soil would probably perk.
The Plan should call for a more
meaningful definition of “cluster” development that minimizes the footprint
of new developments. These developments should be built like Stevensville,
Church Hill, and other attractive, walkable rural villages.
The Draft Plan Places the Desires of Newcomers Over the Needs of Existing
Residents. For example:
The Plan should not call for
the rezoning of key intersections for business parks. It makes no
sense to draw business away from our downtowns, into places that generate
lots of car traffic. These mistakes will only worsen our existing
problems, and create new demand for further development in the future.
The Draft Plan calls for seven
new schools. Our money would be better spent improving our existing
schools instead of creating new ones to handle a booming population.
Land Use Policy 2A gives “new
job-producing and public uses” priority for new sewer construction.
Land Use Policy 4A calls for
the County to actively market itself for “upper end executive housing”,
and “second home and retirement location.” Meanwhile, many lifelong
residents can no longer afford to live in the County.
The Draft Plan Ignores Much of the 1993 Comprehensive Plan.
The new plan should explicitly incorporate more of the 1993 Plan, not contradict
it. Moreover, it should be clear which items are unchanged, and which
policies have proved to be inappropriate. For example, there should
be a chart indicating what changes have been made, and why. Specifically,
the following points must be addressed:
The issue is not whether, with
effort, we could afford to accommodate all new growth. The question
is whether this is worth the effort.
The 1993 Plan contained lengthy
policy discussions, which are absent from the current plan. The Draft
Plan contains a description of existing conditions, and a separate list
of suggested policies, with little intermediary discussion.
The 1993 Plan explicitly said
that we should take development pressure off of Kent Island. Yet
the new plan encourages even more building on Kent Island.
The 1993 Plan called for clearly
separated towns that preserve view corridors, green space, and individual
community character. Yet, as mentioned before, without greater emphasis
on the design of Growth Areas, we will end up with one large, sprawling
developed area from the Bay Bridge to Centreville. Land Use Policy
2A even calls for “contiguous” development along water and sewer lines.
Contiguous development is not the same as compact, walkable development
in clearly delineated towns.
The Draft Plan Gives Little Guidance for Rewriting Zoning Ordinances and
Subdivision Regulations. Although it is supposed to provide
a vision for zoning changes, the Draft Plan contains no discussion or guidelines
for proposed zoning ordinance updates, and no detailed zoning map.
The 1993 Plan said that the
County should not finance sewer projects by burdening the whole population.
Land Use 5A calls for changing
the TDR and non-contiguous ownership provisions but there is no clarification
of why and how changes are to be made.
Land Use 6A:1 proposes a new
rural crossroads commercial district zoning without discussing why and
where such districts may be necessary.
Land Use 6A:5 , 7A:2 and
7A:3 call for MALPF and various commercial zoning changes for which
no justification is given.
Land Use 8A contains a proposal
to change the whole performance based system that the county’s development
regulations have been based on for fourteen years without any mention of
why such a major change is necessary, except that the current system is
complicated, or what better alternatives might be available.
Other highly specific ordinance
changes are called for in Land Use 8A, Sensitive Areas 2A:1 and Mineral
Resources 1A :1,2, and 3. There is no attempt to justify or discuss
many of these proposed changes, and one is left with the impression that
this is not a comprehensive plan but a highly technical agenda for legal
and regulatory change in the County, presented, without public discussion,
under the guise of the planning process. This impression may very well
be incorrect. If it is, we believe that the next draft of the Plan should
provide enough discussion of each of these proposals to justify, inform
and guide the ordinance update process.
The Draft Plan Calls for Too Much Road Expansion. Constantly
expanding our narrow country roads, and building big new ones, will only
make it easier to build new developments, which in turn will only generate
more traffic. The solution to our traffic problems is to prevent
scattered development, not to build bigger roads. Attempting to solve
traffic gridlock by simply building bigger roads is not a sign of progress.
We also believe that the next
draft of the Plan should state explicitly that: (1) agricultural land should
be downzoned, (2) residential development within appropriately-sized growth
areas should be consistent with the small, walkable, neighborhood-oriented
building styles of our historic towns, (3) the County should do more than
just “consider” design standards for development that “improve the quality
of rural design and preserve rural character”, and (4) we should be using
our zoning to protect sensitive areas.
The Draft Plan Lacks Measurable Goals. The document lacks
quantitative benchmarks, measurable goals, or timelines for accomplishing
these goals. Without these, there is no way to be sure that our stated
goals actually happen. Instead, the document is riddled with language
like “consider”, “encourage”, and “consider encouraging.” Meanwhile,
the vast majority of policies are categorized as Priority 1, rendering
this definition largely meaningless. This plan tries to be all things
to all people; Queen Anne’s County needs more decisive leadership.
II. What We Like Best About
the Draft Plan
The Draft Plan Calls for Moderately Priced Housing. We trust
teachers, police officers, fire fighters, and County employees with the
care and safety of our families. Yet these and many other hardworking
people can no longer afford to live in the County, because housing costs
are skyrocketing. We applaud the requirement that new development
should include housing that normal, hard working people can afford.
The Draft Plan Says to Stop Building if We Don’t Have Infrastructure to
Support It. By tying subdivision plans to an Adequate Public
Facilities Ordinance (APFO), we can grow in a fiscally conservative and
socially responsible manner. An APFO says simply that a developer
can build only if there are existing and funded services to support the
development - or if he or she is willing to pay the cost themselves.
This makes a great deal of sense, so long as the amount being paid is
the true full cost for roads, schools, utilities, and other infrastructure.
We support the APFO, but with caution, because it alone can’t take the
place of a cap on development.
The Draft Plan Calls for Better Design Standards for Developments.
For hundreds of years, the Eastern Shore has been the home of beautiful
rural villages. These towns are compact, walkable, and clearly bounded.
They are distinctive, and do not look like “Anywhere, USA”. Our new
construction must uphold this legacy.
The Draft Plan Calls for Better - Not Just Bigger - Roadways.
Our neighborhoods are now choked with cars, roaring by at speeds that endanger
our children. At the same time, there is rarely room for walkers
or bicyclers to travel safely. We agree that:
New roadway designs can make
roads safer, more attractive, and more useful for people who want to enjoy
the beauty of the outdoors. Traffic calming devices are also important
to keep traffic traveling at a safe speed in our neighborhoods. We
are glad to see that the needs of people are finally being taken into account,
instead of just cars.
Providing a road network with
multiple connections between destinations reduces congestion on bigger
roads, makes it easier to avoid traffic, and reduces the distance we all
have to travel. This makes much more sense than having every development
empty onto the same highway, producing huge bottlenecks.
Better bicycle and pedestrian
policies, like a comprehensive sidewalk policy and new trail construction,
will allow people to get out of their cars and enjoy their travel.
The Draft Plan Calls for a Historic Preservation Ordinance.
This is an excellent way to help make historic preservation more affordable.
It will allow eligible property owners to receive substantial historic
rehabilitation tax credits from the state, preserving our distinct heritage
for future generations.
Streets in our Growth Areas
should not be massive, and our neighborhoods should not become superhighways.
We should do everything we can to make our streets safe for families.
The Draft Plan Calls for a Coherent and Sensible Policy for Allocating
Critical Area Growth Allocations. These kinds of important
decisions should not be made on an ad hoc basis, where the rules change
with each proposal. They must be based on clear standards, sound
reasoning, and foresight. We support a transparent and publicly-available
set of guidelines for allocating growth within Critical Areas.
The Draft Plan Calls for an Honest Definition of Open Space.
Currently, “open space” is subject to change over time, and can eventually
be built upon.
For example, 35,000 square foot
building should not be considered open space, as has been proposed on Kent
These open spaces should be
protected permanently through deed restrictions and other mechanisms.
At the very least, we should not delude ourselves through the misuse of
by the following participants and supporters of the Mid-Shore Coalition:
Chester River Association
Crumpton Civic Association
Kent Island Civic Confederation
Kent Island Defense League
Millington Quality of
Life Preservation Coalition
Talbot River Protection
Queen Anne’s Conservation
1000 Friends of Maryland
Thomas T. Alspach, Easton
Ellie Altman, Queenstown
Stephen and Cindy Anderton,
Lemuel “Bo” Benton, Sudlersville
Todd and Carrie Bittner,
Joe Gannon, Church Hill
Jan Graham, Galena
John B. Jessup, St. Michael’s
Holly Johnson, Chestertown
Lucille Villabona Kuntz,
Charles E. Mason, Easton
Mary Lee Mason, Easton
Eugene B. Mechling, Jr.,
Frank and Bea McCann,
Rick Moser, Stevensville
Ford Schumann, Chestertown
Dorothy Villabona, Sudlersville
Dick and Loretta C. Walls,
For more information about
the Mid-Shore Coalition, please contact:
1000 Friends of Maryland
1209 N. Calvert Street
Baltimore, MD 21202