about south river federation

On July 25, 2017, National Lutheran Communities and Services submitted Special Exception plans to the City of Annapolis to construct a continuing care retirement community, called the Village at Providence Point (FKA Crystal Spring) along Forest Drive. This latest iteration of the development proposes to clear 39.5 acres of forest, retain 51 acres, reforest 16.45 acres, and convey “75+ acres” into conservation easements. The former developer from Connecticut, Hillspoint LLC, has abandoned the project. See Annapolis Capital Article here.

On August 11, 2017, the City completed its review of the plans, located on the City’s e-Trakit database as SE2017-004, and concluded that the plans were incomplete. In its comments, the City noted 25 outstanding issues to resolve. Notable comments include: the requirement that the proposed conservation easements be supported with easement documents expressing specific restrictions on the use of the property; the forest conservation plan does not delineate the 100 ft buffer to non-tidal wetlands or the intermittent stream on the property; “In addition to variances for clearing priority forest and significant & specimen trees, the applicant is required to, show how techniques for forest retention have been exhausted and demonstrate why priority forests and priority areas… cannot be left in an undisturbed condition”; and the traffic statement must address the entire proposed subdivision. The City’s final comment was “Overall the applications are inconsistent, incomplete, lack analysis and detail. Further, the plans are difficult to read and understand.”

Maintaining an Independent Voice for Crab Creek

The South River Federation remains committed to its mission to protect, preserve, restore and celebrate the South River. We do not feel that the current development proposal can be reconciled with this mission. The Federation launched its Crab Creek Initiative this year and is currently assessing the myriad issues plaguing this troubled tributary, even in the absence of clearing nearly 40 acres of priority forest in its headwaters.

For instance, the stream segment that starts across Spa Road from Annapolis Middle School has had extremely high bacteria levels the entire summer. Not once in 13 samples, did the bacteria readings meet the Environmental Protection Agency’s recommended bacteria threshold of less than 104 cfu (colony forming units) per 100 mL. In fact, the site averaged 3,200 cfu/100ml of Enterococci bacteria this past summer, over 30 times safe exposure levels.

Another tributary stream near Crystal Spring Farm Road has a tsunami of trash flowing into the stream with every rainfall. In just 6 weeks, the Federation’s trash trap collected over 679 plastic bottles, 174 aluminum cans, 212 styrofoam containers, and 1200 plastic wrappers.

It is well understood that as the amount of impervious surfaces like parking lots and roofs increases, stream health decreases. It is beyond dispute that forests protect streams by filtering out pollutants and shading water to keep it cool.From a strictly environmental point of view, any development that removes forest and increases impervious surfaces is detrimental to aquatic habitat and water quality. However, the City of Annapolis has a process to allow appropriate development by balancing the benefits of business growth and private property rights with public health benefits, reduced traffic congestion and environmental protection. The Federation is a partner with the City in the implementation of sound stormwater management practices in pursuit of its WIP goals for the next 20 years, and we will continue to work with the City to achieve the goals of clean water whenever possible.

There is further fact gathering and analysis to do on the stormwater management plans for the project to evaluate the impact of whatever additional impervious surface may ultimately be approved. Until this fact-finding is complete and the issues raised by the City are adequately addressed, the Federation opposes the development proposal.