ESLC’s Letter to The Queen Anne’s County Commissioners, 8/22/2022
Dear Commissioners,
Thank you for the opportunity to submit comments on the citizen-sponsored text amendment application TACO #22-03. As one of the Eastern Shore’s leading conservation organizations, we respectfully submit the following statement regarding the citizen-sponsored text amendment application TACO #22-03.
TACO #22-03 would repeal the woodlands provision (§.18:1-66) of the Queen Anne’s County zoning code, which specifies woodland disturbance limits that are not subject to the Critical Area Law and the Forest Conservation Act. As is stated in the Department of Planning & Zoning’s memorandum from June 9, 2022, “Removing the Woodlands provision in its entirety would allow for a greater loss of woodlands . . .” And in the staff memo dated August 23, 2002, it is made clear that despite the stated priority of the sponsor, this change would have an outsized impact on larger parcels, including a 10% increase in potential woodland conversion on parcels zoned agricultural.
According to the Maryland Department of Natural Resources, Queen Anne’s County and Kent County are the least forested counties in the state of Maryland. Forests and woodlands offer many benefits including wildlife habitat, temperature control, carbon sequestration, and contribute to a healthier environment. Considering the potential loss of intact forestlands, Eastern Shore Land Conservancy does not support repeal.
This amendment is contradictory to the County’s vision in the recently approved 2022 Comprehensive Plan (Chapter 5, Environmental Resources). The purpose of the Woodlands provision is to ensure that high-quality forested areas are retained while also ensuring that forest resources are considered early in the design phase of development projects. Existing regulations include exemptions to woodlands through transfer development rights, forest mitigation, and payments in lieu. The provision does not prevent development, but instead ensures consideration of the environmental resources that benefit our county’s economy, surrounding waterways, and climate resilience.
Eastern Shore Land Conservancy supports the recommendation from Planning and Zoning staff that “rather than favorably considering this text amendment in isolation, this review occur in the context of the update of the County Zoning Code,” which per the 8/23/2022 staff memo is already in process. Therefore, Eastern Shore Land Conservancy encourages the County to clarify the language in the Woodland provision to avoid any future confusion rather than voting to repeal.
Thank you again for the opportunity to provide comment.
Steven K. Kline
President and CEO