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Chesapeake Bay Foundation (410) 268-8833 Fax (410) 280-3513
May 23, 2000 Re: 98-NT-0680/199860874 Dear Ms. Broersma-Cole: I am writing to express the concerns of the Chesapeake Bay Foundation regarding the proposed development of Arundel Mills in western Anne Arundel County and to submit the following written comments regarding the additional impacts to wetlands and forested lands associated with this proposal. As stated in our previous comments to the Army Corps of (see attached comments), CBF is concerned by the extent of proposed impacts, the apparent lack of an analysis of cumulative and secondary impacts and the sprawl-inducing, auto-dependent nature of this development. The Chesapeake Bay Foundation (CBF), with over 80,000 members, is the largest environmental education and advocacy organization dedicated to the protection and restoration of the Chesapeake Bay. The recent announcement to impact an additional 11,594 square feet of wetland, 9,238 square feet of regulated buffer and 1,689 linear feet of stream due to State Highway proposed interchange modifications only highlights the unacceptably high ecological impacts associated with this sprawling development. Proposing additional wetland, buffer and streamside impacts, well after construction has commenced, limits the public’s ability to comment on the project in its entirety, and confirms that no meaningful assessment of the cumulative impacts of this project have been considered. This project has raised much public concern due to the relative remote nature of the project site, the extent of the forest clearing, the nature of wetland and stream impacts, the improper use of air quality data, and the additional sprawl that will be accommodated by the initial development. Although the project is located in a purported priority funding area, the State’s acquiescence to this project flies in the face of all it has done to promote Smart Growth and natural resource protection. Authorizing additional impacts after project commencement threatens to undermine citizen confidence in the State’s regulatory review process, especially where particularly contentious projects are concerned. Furthermore, it is unclear from the notice specifically what necessitates the redesign of the interchange and additional left-turn lane, and what steps, if any, have been taken to avoid the associated wetlands, buffer and stream impacts or to demonstrate the impacts are unavoidable. Has the applicant underestimated the project’s traffic projections? An added left turn lane strongly implies this is in fact the case. We believe the applicant can and should institute a transportation management plan focused on alternatives to auto travel to avoid expanding road capacity for a project that is already one of the region’s largest generators of auto traffic. We request that you provide us with documents relevant to this permit that contain information about the applicant’s efforts at impact minimization and avoidance. The Chesapeake Bay Foundation also requests that a public hearing be held on this permit, during which MDE and the State highway Administration should present information regarding the necessity for the road design changes and additional resource impacts. MDE should also outline the applicant’s efforts to avoid and minimize proposed impacts, as well as the agency’s assessment of cumulative impacts. Effective public participation and informed public comment is not possible without this key information. Thank you for your immediate attention to this matter. Sincerely, Theresa Pierno |
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Baltimore
Regional Partnership · 512 Orchard Street · Baltimore, MD 21201-1947 |
