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The Mid-Shore Coalition’s Response to the
Queen Anne’s County Draft Comprehensive Plan

We 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. 

We 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.

Although 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 Comprehensive Plan

1. 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. 

2. 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.

3. 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.  For example:

  • 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. 
  • 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.
4. 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. 
  • 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 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.
5. The Draft Plan Places the Desires of Newcomers Over the Needs of Existing Residents.  For example: 
  • 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 issue is not whether, with effort, we could afford to accommodate all new growth.  The question is whether this is worth the effort.
6. 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 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 1993 Plan said that the County should not finance sewer projects by burdening the whole population. 
7. 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. 
  • 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. 
  • 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.
8. 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.

9. 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

1. 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.

2. 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. 

3. 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.

4. 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.
  • 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. 
5. 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.

6. 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.

7. 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 Island.
  • 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 language.

Respectfully submitted by the following participants and supporters of the Mid-Shore Coalition:

Chester River Association
Crumpton Civic Association
Haztrak Coalition
Kent Island Civic Confederation
Kent Island Defense League
Millington Quality of Life Preservation Coalition
Talbot River Protection Association
Queen Anne’s Conservation Association
TriCommunity Preservation
1000 Friends of Maryland 
Thomas T. Alspach, Easton
Ellie Altman, Queenstown
Stephen and Cindy Anderton, Millington
Lemuel “Bo” Benton, Sudlersville
Todd and Carrie Bittner, Sudlersville
Joe Gannon, Church Hill
Jan Graham, Galena
John B. Jessup, St. Michael’s
Holly Johnson, Chestertown
Lucille Villabona Kuntz, Sudlersville
Charles E. Mason, Easton
Mary Lee Mason, Easton
Eugene B. Mechling, Jr., Easton
Frank and Bea McCann, Crumpton
Rick Moser, Stevensville
Ford Schumann, Chestertown
Dorothy Villabona, Sudlersville
Dick and Loretta C. Walls, Millington

For more information about the Mid-Shore Coalition, please contact:
Brad Rogers
1000 Friends of Maryland
1209 N. Calvert Street
Baltimore, MD 21202
(410) 385-2910      brogers@friendsofmd.org     www.friendsofmd.org

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