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'Friends of Crystal Spring Forest' Continue Their Hyped Misrepresentations about Crystal Spring

July 29, 2014

In an attempt to influence the City of Annapolis's review of the Crystal Spring Forest Conservation Plan, the group known as "Friends of Crystal Spring Forest" has circulated a petition seeking signatures to “Just Say No” to Crystal Spring. Their cover memo to the petition signing request is yet another blatant example of manipulating the residents of Annapolis to express opposition to Crystal Spring based on hyped misrepresentations and half-truths. They are using these misrepresentations to serve their no-growth agenda. In its short 1/3 page request, the group has made six (6) statements that are misrepresentations geared to distort facts. Listed below, in the order they appear in the request, are the facts:

1. They say the project “will impact as much as 1.7 acres of non-tidal wetlands.” This is not true.

The fact is Crystal Spring has provided more than a 125-foot setback from all non-tidal wetlands and has presented engineering studies that demonstrate the hydrology of these pocket wetlands will not be disturbed. This group has not provided any evidence of their claim. This is reckless and irresponsible.

2. They say the project’s Forest Stand Delineation is “missing more than half of all the wetlands present.” This is not true.

The fact is the Crystal Spring Forest Stand Delineation properly identifies all existing wetlands located on the property as verified by the U.S. Army Corps of Engineers which is the body that has the jurisdiction over such identifications.

Crystal Spring has submitted the jurisdictional determination letter from the U.S. Army Corps of Engineers that demonstrates its finding. Where is their evidence backing this claim? Again, this factless claim has no merit.

3. They say that the “Crystal Spring project (emphasis added) would still be nearly three (3) times the size of Annapolis Towne Centre.” This is not only untrue – but insultingly misleading.

The fact is this group and others have been making this statement for more than 2 years and so much so that last year (based on the then proposed project scope which has since been reduced) Crystal Spring developed a comparison chart shown below. The misleading point is that the Crystal Spring total acreage is 3 times that of Annapolis Towne Centre with less than 2/3 its development. This means the Crystal Spring proposal is 1/5 as densely developed as Towne Centre and includes more than 50 acres of undisturbed property within its development compared to Towne Centre’s 14 story height and nearly 100% coverage. To state that the project (and not the acreage) is 3 times as large is purposefully misleading.

Click on this link to view the attached comparison plan.

And below are some actual comparison figures:

Project Component

Towne Centre Square Footage

Crystal Spring Square Footage

Retail

674,850

141,000

Office

91,700

24,000

Hotel

130,000

68,000

Residential

1,080,000

220,000

CCRC

0

674,000

 

 4.  They say the project will “create more pollution for the South River and the Chesapeake Bay.” This is untrue and the claim is unsubstantiated.

The facts are that (1.) current storm water management regulations require that all storm water be managed on site to avoid impacts on waterways (2.) no development is proposed in critical areas within 1,000 feet of Crab Creek and (3.) under an agreement with the South River Federation Crystal Spring will be making voluntary offsite steam restoration to remove polluting nutrients that NOW flow across the Annapolis Middle School property from over 65 acres of unregulated land and into Crab Creek.  Removal of nutrients and sediment from this source will improve the water quality of Crab Creek and the South River. This substantial voluntary environmental contribution of Crystal Spring and other initiatives has earned Crystal Spring the endorsement of the South River Federation. Read the 2013 letter regarding the Crystal Spring/South River Federation initiatives.

5.  They say with regard to impacts of Crystal Spring, “in addition to increased traffic.” This is a misleading half-truth.

The facts are there will be traffic generated by the Crystal Spring project that is much less than other potential development of the property because the dominant part of the development is the Continuing Care Retirement Community which does not generate rush hour traffic and overall produces much less traffic that almost any other type of development. The employee traffic related to retail and the CCRC are also not rush hour traffic and the vast majority of all employee traffic will be going in the opposite direction as the Annapolis Neck traffic. In addition, a new connector road is proposed on the site that will be part of a connection between Spa Road and Bywater such that traffic can avoid Forest Drive between these points.

Finally, and most importantly, their statement does not mention that Crystal Spring will be required to make significant improvements to Forest Drive and the Spa Road intersection which will more than offset the impact of traffic generated by the project.

6.  They say that Crystal Spring will create “school overcrowding.” Again, this statement is misleading.

The truth is that Crystal Spring is not the potential cause of overcrowding as the Hillsmere School is currently at or over capacity.  Crystal Spring is potentially part of the solution by being required to pay nearly $800,000 in school impact fees, which should be used for the benefit of impacted schools. To put this in perspective, according to formulas used by Anne Arundel County, only 10 elementary school age children would be generated by Crystal Spring. In addition, to avoid the entire possibility of impacting Hillsmere Elementary School, Crystal Spring, since it anticipates generating so few elementary school age children, would agree to require its students to attend one of two other elementary schools that are not at capacity and are actually located closer to Crystal Spring.

_______________________________________________________

Friends of Crystal Spring Forest are No-Growth Advocates who have pushed to deny land-owner rights. Their spokesman appeared on a City of Annapolis cable television show and stated with regard to Crystal Spring, “I would not even endorse building a bird house on the property.” Crystal Spring is a complex project and the Forest Conservation Act, coupled with Land Use Regulations, is a formidably complex set of documents. This group's perspectives are filled with assumptions and statements that at best do not have any documentary evidence and at worst are purposefully misleading to serve their no-growth agenda. Most times their statements are coupled with a phrase such as “Can You Imagine?” how bad this or that will be. This is a slick technique which insults the reader’s ability to judge for themselves.

No-Growth Advocates Continue Their Pattern of Misrepresentations

July 28, 2014

In a letter to the editor published in The Capital (July 25), writers Patrick and Elise Fleeharty demonstrate yet another example of an attack on Crystal Spring that is based on misrepresentations and factual errors either initiated by the Fleehartys or repeated from the talking points being promoted by the no-growth activists. In this letter the writers say:

1. Crystal Spring is claiming that “enforcement of the act (Forest Conservation Act)…would create an unwarranted hardship…by preventing development on virtually all of the property” and “could be construed as an illegal taking of private property rights” NOT TRUE -- this carefully excerpted reference to Crystal Spring’s statement applies to an incorrect No-Growth interpretation of the act that would be used to stop development.   

The fact is Crystal Spring embraces the correct application of the Forest Conservation Act to the Katherine Property as well as the City of Annapolis Comprehensive Plan which has designated the property as an Opportunity Zone for development. Crystal Spring has demonstrated its compliance with the Forest Conservation Act by (1.) conservation of 66% more forest than the “breakeven threshold” established by the state of Maryland and 25% higher than the more stringent City of Annapolis requirement (2.) creating a 50 acre wildlife corridor through the middle of its proposed development, and (3.) avoiding all of the sensitive environmental areas such as wetlands, steep slopes and critical habitats.  What Crystal Spring has stated would be a hardship and a potential taking of private property rights would be application of the No-Growth interpretation of the Forest Conservation Act as a tool to further prohibit development than proposed by Crystal Spring and extend its jurisdiction beyond forested areas to include development in existing meadow areas.   

2. The current plan “includes 542 housing units, a 220 square foot shopping center, a 69,000 square foot, four story hotel and spa...” NOT TRUE

The facts are that the current Crystal Spring plan calls for 118 non-age restricted townhouses that are traditional housing units. There are 362 independent living accommodations as part of the Continuing Care Retirement Community that is part of a “Care for the Elderly” category and not “housing units.” These accommodations place only a portion of the demands for public services (sewer, water and traffic) than traditional housing and are classified differently for this and other reasons.  Even if erroneously lumped with townhouses, the total would be 480 and not 542.  In addition, the total “shopping center” square footage is 141,000 and not 220,000 as the writers claim.  

3. The current proposed plan is far more extensive and environmentally damaging that the original plan proposed in 2005.  NOT TRUE

The fact is the only previously proposed plan for this property was the approved Steeplegate project which was approved prior to land purchase by Janet Richardson-Pearson. It called for 675 homes with no open space preserved or environmental feature protection and was the driving force behind Janet’s desire to protect the property.  When she acquired this property, she had the right to proceed with this plan. The current circumstances are that with the City of Annapolis annexation of her 180 acres and its proposed Crystal Spring development, a total of approximately 127 acres would  remain untouched and be protected from further development instead of there being a traditional sub-division covering the entire site.

For comparison, click on the first link below to see the previously approved Steeplegate site plan; and then click on the second link to view the current Crystal Spring plan.

Approved Steeplegate Site Plan

Current Crystal Spring Plan

A Detailed Look at How the Site Plan Revisions Reflect the Input and Questions We Received from the City and Others

July 16, 2014

The  updated Preliminary Forest Conservation Plan was developed following the initial submittal on May 24, 2013 and responded to DNEP’s June 28, 2013 letter and the comments and instruction therein. Some of DNEP’s remarks were of a general nature; others took the form of specific directives. A central message of DNEP’s letter, however, was the request that Crystal Spring Development (CSD) create a consolidated environmental mapping to show all environmental features on a single sheet and then to reconsider the ability to adjust the proposed development in light of the environmental mapping. CSD’s team, headed by Annapolis Landscape Architects, developed the consolidated environmental mapping based upon input provided by DNEP, DPZ, and others. The mapping then functioned as a new baseline for project planning. The mapping,  includes information on:

- Hydrology

- Forest Stands

- Specimen Trees

- Steep slopes, wetlands and other natural resources per Natural Resources Article, § 5-1607 (c)

- Arborist-identified individual tree stands with best survivability

Once this mapping was completed, CSD established a priority ranking of environmental resources to be retained. The ranking order established was:

1.         Intermittent Drainage Way

2.         MDE-designated “vernal pool”

3.         Non-tidal wetlands

4.         Steep Slopes

5.         Wildlife Corridor

6.         Tree stands that connect Arborist-identified tree stands

Using the consolidated environmental mapping as a guide toward potential revisions, CSD made several significant plan modifications that reflect the priority ranking established above.

In addition, DNEP requested that CSD specifically investigate alternatives that would relocate the main CCRC building from its prior location to an area of the property on the Forest Drive side of the intermittent drainage way with the aim of creating a larger wildlife corridor through the middle section of the site. This relocation was accomplished, resulting in a larger wildlife corridor which now encompasses approximately 50 acres, and removing all proposed development from potential impacts to identified environmental features in that region of the property.  See the Consolidated Environmental Mapping included herewith.

Overall site plan improvements have been accomplished by instituting the following major plan modifications as reflected in this revised Preliminary Forest Conservation Plan:

  1. The main CCRC building and the health care facility, a total of approximately 400,000 square-feet of development, have been relocated from their previous location to a portion of the retail/commercial mixed-use development section on the Forest Drive side of the intermittent drainage way. This area previously contained retail development, with age-restricted housing above retail, and also the Inn & Spa, all of which were supported by on-grade parking. The modified plan contains only the main CCRC building, health care and CCRC wellness facilities in this area with under-building parking for its residents and only limited staff and visitor on-grade parking for staff and visitors near the building entrances. 
  2. As a result of the relocation of the main CCRC building and related facilities, the previously planned access road to the main CCRC building, which included a vehicle bridge over the intermittent drainage way, has been eliminated. The existing Crystal Spring Farm Road, which will be improved, is now proposed as the main access road to the rear of the property.
  3. The portions of the Continuing Care Retirement Community to be developed beyond the main CCRC building and its health care facility have been reduced in scope and footprint. One of the three “Maison Court” 20-unit independent living buildings has been eliminated and consolidated into the main CCRC building within the Forest Drive side of the development, and the remaining two (2) “Maison Court” buildings and 24 of the 33 cottage units have all been located in non-forested areas. Only the nine (9) cottage units in Phase 1 of the CCRC development are planned within the forested area of the property on the opposite  side of the intermittent drainage way from the main CCRC building. These small independent cottages, with no basements, will be developed in a way that will insure that existing hydrology now sheet feeding pocket wetlands and the intermittent drainage way are maintained.
  4. A minimum 100-foot setback from Forest Drive has been created which will reduce the visual impact from Forest Drive.

A graphic illustration of the progress that has been achieved throughout the site plan revision process is represented on the image from a previous blog post (scroll to our July 2, 2014 post, “Crystal Spring Project, Project Statistics – Comparison of Building Footprint & Hardscape Areas”). The three plans depict snapshots of the multi-year planning process at critical points, and the evolution of the project. The first layout, from April 2011, shows the plan as proposed to and reviewed by the City’s Planning Commission during workshop sessions. The second layout, from May 2013, shows the plan submitted to DNEP as part of the initial Preliminary Forest Conservation Plan submittal. The third layout shows the current revised Preliminary Forest Conservation Plan.

See the PDF links, below, to view the Statistical Comparison Chart and the Consolidated Environmental Mapping.
 

View Statistical Comparison Chart

View Consolidated Environmental Mapping

Crystal Spring Annapolis Site Plan

July 10, 2014

Key Achievements and Site Plan Modifications in Recent Submission

July 2, 2014

On June 25, 2014, Crystal Spring filed its response to comments from the City of Annapolis with regard to its previously filed Preliminary Forest Conservation Plan. The response included significant modifications to the site plan and significant improvements to the project’s forest conservation and environmental justification under the Forest Conservation Act.

The following is a list of key achievements and site plan modifications contained in the recent response submission:

1.     The site plan was modified from the prior Forest Conservation Plan submission to relocate the main CCRC building and its related health care facilities to the retail / mixed use section of the property resulting in the reduction of approximately 35,000 square feet of retail / commercial space and 40 residential units above retail. The overall building, parking and roadway footprint has been reduced by 32.5% through a multi-year planning process with City Planning and DNEP.

2.     The Forest Conservation acreage has increased to a level 25% greater than the City of Annapolis established requirement and 66% greater than the State Forest Conservation Act requirement. The project’s forest conservation acreage plus voluntary on-site afforestation covers 45 acres and exceeds the 43.5 acre goal requested by the City of Annapolis Environmental Commission in 2012.

3.     Crystal Spring achieves greater than a 53% tree canopy exceeding the 50% tree canopy goal established in the City of Annapolis Comprehensive Plan.

4.     The Crystal Spring site plan now provides a 50 acre wildlife corridor through the middle of its property through the areas in which environmental features under the Forest Conservation Act and identified by the Annapolis Environmental Commission are located. 

5.     Forest Conservation and Open Space Easements will be placed on more than 125 acres of the property, including property retained by its current owner. This represents a larger property set-aside than all currently existing conservation easements in the City of Annapolis combined.

6.     Crystal Spring’s stormwater management program is enhanced by the project’s use of green roofs, permeable asphalt, geo-thermal heating and cooling, and bio-swales in parking and roadway areas.

Over the next few weeks, Crystal Spring will provide more details about the modifications and enhancements included in the recent submission. See our previous post, below, showing the image associated with item #1 regarding site plan changes.

Site Plan Modifications: 2011-2014

July 2, 2014

During a multi-year planning process with City Planning and DNEP, the building, parking and roadway footprint has been reduced by 32.5%.

Please click on the image below to view the pdf.

 

Today We Filed the Preliminary Forest Conservation Plan

June 25, 2014

Today we filed the Preliminary Forest Conservation Plan – a response to City of Annapolis review questions regarding plans for Crystal Spring Annapolis. We look forward to continuing to work with City officials and members of the Annapolis community as we bring a new concept in retirement living to Annapolis. Please check this website for blog posts and updates to keep the public informed as we continue through the approval process. You can also find updates on our project-focused Twitter account - @CrystalSpring_. While you might have heard opposition to the community from a small but vocal crowd of misguided activists opposed to any growth, our hope is you will turn to us for the facts and help us by sharing accurate information about Crystal Spring.

*Proposed Continuing Care Retirement Community is subject to approval by the Maryland Department of Aging.
Recent Tweets
  • Wed Jul 30, 2014 "For those who asked about @CrystalSpring_ during @MayorPantelides' #COAMP, you can find the facts here: http://t.co/47jCkPhpat"
  • Wed Jul 30, 2014 "Read about the hyped misrepresentations about @CrystalSpring_ being spread by 'Friends of Crystal Spring Forest' http://t.co/47jCkPhpat"
  • Wed Jul 30, 2014 "'Friends of Crystal Spring Forest' continue their hyped misrepresentations about Crystal Spring: http://t.co/47jCkPhpat"
  • Mon Jul 28, 2014 "No-growth advocates continue their pattern of misrepresentations: http://t.co/1fXJb9wlPA"
  • Fri Jul 18, 2014 "For facts about @CrystalSpring_ and to view the site plan, visit [http://t.co/wsC43ZLmXU]"
  • Thu Jul 17, 2014 "RT @NLCSNews: We first started in DC in 1890 ... an amazing legacy that this building still serves seniors. Here's the chapel! http://t.co/…"
  • Wed Jul 16, 2014 "How the @CrystalSpring_ site plan revisions reflect the input and questions we received from the City and others http://t.co/htEu4DF9OE"
  • Wed Jul 16, 2014 "How the @CrystalSpring_ site plan revisions reflect the input and questions we received from the City and others: http://t.co/UOMNz1Cd0i"
  • Tue Jul 15, 2014 "Visit [http://t.co/wsC43ZLmXU] to view the @CrystalSpring_ site plan and to access facts about the project."
  • Mon Jul 14, 2014 "Forest Conservation and Open Space Easements will be placed on more than 125 acres of the @CrystalSpring_ property: http://t.co/bmK0LddawR"

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