Additional Comments on the Sugarloaf Treasured Landscape Management Plan,

Addressing the Area to be Covered by the Plan

Submitted to the Frederick County Planning Commission by Ingrid Rosencrantz, December 11, 2021

 

I’m following up with some additional information on the “speculative” I-270 interchange at Park’s Mill Road and asking that the Planning Commission apply planning principles in a consistent way and fix the boundaries of the Sugarloaf Plan.    

 

I was on the Citizen’s Advisory Group for the Sugarloaf Plan and more than a year ago, I made comments asking the boundary be changed to Route 270 extending from the Montgomery County line to the Monocacy River. At that time the proposed boundary was Route 80, which bifurcated the historic village of Hopehill and set up the possibility for development on the west side of 270 – something the County had previously not supported. At first, I heard: “we can’t change the boundary because the maps are already made.” Then, after release of the most recent plan, I saw that the boundary had been changed. On September 8, County Executive Gardener kindly met with some of the members of the Citizen’s Advisory Group at our request and we discussed the proposed boundary among other issues. I explained to County Executive Gardener that I mostly grew up on Baker Valley Road, at my grandparent’s house, which was a pre-Civil War log cabin directly across from the Monocacy Battlefield, and how proud we were that my grandfather had found a cannon ball on his property, and how important it is to preserve this area. I felt like County Executive Gardener listened carefully to my personal story and her reaction gave me the impression that she was open to moving the boundary. Attached is a current picture of the view from my grandparent’s house. (See image 1)

 

As the process moved forward and the Plan went to the Planning commission, I again asked why not use Route 270 as the boundary, and a member of the planning office, by way of explanation, said there is a possible interchange at Park’s Mill and 270. This made no sense to me at the time and now, with additional documented information, makes even less sense. I have had the chance to do some additional research and feel it’s important for the Planning Commission to review and understand points made based on fact vs. those based on what I suspect is fairly extreme speculation. As I see it, the research throws into question the reality of any future I-270 interchange at Park’s Mill as least in the timeframes being addressed by the Sugarloaf Plan.

 

I reviewed the most recent Frederick County Transportation Needs and Priorities Review Report (https://www.frederickcountymd.gov/DocumentCenter/View/333603/20201-TPR-Report-Final-21721?bidId= ) and find absolutely no reference to this possible future interchange anywhere in this official document. This imagined interchange is not on the Highway Needs Inventory included in this document nor is it on the Vision 2045 (Constrained Long-Range Plan).  How is it sensible to exclude an area that would otherwise be in the plan due to a very tenuous speculative possibility that maybe there would be an interchange at some point in the future, after the year 2045? How is this good planning practice?

 

Currently the area of the speculative interchange at Park’s Mill Road between 270 and Route 80 is zoned agricultural and is farmed for corn and other agricultural products. In fact, I used to help make hay on this land back when I was a teenager many years ago. Also just a few years ago, there was a lovely produce stand there, and I enjoyed stopping to buy fresh (very) local tomatoes and other vegetables. This specific area also has a beautiful view of Sugarloaf. How lucky we are to be able to enjoy this view whenever any of us drive along Park’s Mill Road. (See image 2)

 

I think the Planning Commission would agree with me that it is important to base their decisions on facts, as best they can, and understand the entire story. This speculative possibility of an interchange in the very distant future (again, this interchange is not identified on the Transportation Needs and Priorities Review) is not a sufficient reason to move the well-established no-development line from I-270 to Route 80. It only makes sense, from a policy perspective, to include this area, between Route 89 and I-270, in the Sugarloaf Plan:

  • This area it abuts the plan area and frankly, is integrated culturally as well as physically,

  • This area is to the west of 270 where, as Tim Goodfellow’s testimony has demonstrated, the County has historically limited development,

  • This area fits into the goals of the plan,

    • with beautiful views of Sugarloaf, (see image 2)

    • it’s at the headwaters of part of the protected area (see maps 1 and 2, and images 3 and 4),

    • it comprises agriculturally zoned property,

    • it is covered by fields or woods with no commercially-zoned property,

    • it abuts the Monocacy Battlefield, and area of historic and cultural significance (see images 5 and 6),

    • it abuts Hopehill, an historic village with cultural significance (see image 7).

    • it includes farms along Baker Valley Road, some of which are already being preserved on an ad hoc basis (see image 8 and 9),

    • there is no actual 270 corridor that includes a real interchange at Park’s Mill Road at any point in the non-speculative future.

    • there is no other plan where it will better fit,

    • the land area is small relative to the land area of the entire Sugarloaf Plan.

 

The Planning Commission has the opportunity to fix this ill-informed mistake, apply planning principles consistently, and fix the boundary by moving it to I-270. Certainly, the community overwhelmingly supports this change (reference the new and old petitions) and also supports the existing commercially zoned businesses at the I-270/Route 80 interchange near Urbana. This boundary change would meet the needs of the citizens in the area as well as folks that come to visit two of the County’s main tourist attractions, the Monocacy Battlefield and Sugarloaf Mountain. This boundary change would prevent the “camel’s nose under the tent” issue of allowing development to the west of 270. How can that balance required by good planning be thrown off only by a speculative future interchange that is not even officially on the County’s radar through 2045?  Or is there more to it? We shall see… and as good and involved citizens, we will be watching.

 

Background – Some Supporting Information Provided in Prior Comments

 

The Sugarloaf Plan is the best plan for the area between Route 80 and I-270

 

The area between Route 80 and 270, from Urbana to the Monocacy Battlefield National Park is currently farmland and woods and there is no other area plan that would better fit this area than the Sugarloaf plan. Part of this area has been preserved on an ad hoc basis by individual landowners and much of this area abuts the draft plan boundary, is in the viewshed of Monocacy Battlefield National Park and/or the historic community of Hopehill. As shown on the map below, this area is a small fraction of the total Sugarloaf Plan area and abuts the Sugarloaf Plan area. There is no good reason to not include this area in the Sugarloaf Plan. See map below.  

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

History of Using I-270 as a Limit to Development in this Area and the Value of Open Space 

 

Frederick County should continue to use I-270 as the boundary between developed areas to the east and undeveloped areas to the west. 

  • Frederick County planners have long used I270 as the boundary to distinguish the developed areas and public services on the east from the open space and undeveloped areas on the west.Both areas are important in their place.The maps in the July 2021 Sugarloaf Plan (A-15 to A-18) show I270 as this long-held boundary.

  • Development of any kind engenders more development and causes “change in the character of the neighborhood,” creating precedent to justify more development.

  • The lasting cost to communities of permanently losing open space – unique and irreplaceable areas that cannot be replicated – is steep.

  • Livable Frederick’s “Making Our Environment Vision A Reality” includes “Category: Land: Goal: …The natural environment and its habitat provision and ecosystem services are critical to our quality of life, and so they should be the primary consideration in all land planning and governmental decision-making processes.”

 

 

 

Changes in Assumptions – Employment-related Traffic, and Other Considerations  

 

As noted below and in other comments provided by others, some of the assumptions used in the Livable Frederick plan are out of date or obsolete, specifically with regard to transportation expectations and technology corridors:

 

  • Employment-related traffic will continue to change as more technology workers work from home, some local and some in locations where high-speed internet is more robust.(DC reports only 25% of pre-pandemic workers have returned to offices in downtown.)

  • Technology advances and business expansion are no longer dependent on transportation corridors, making TOD (transportation-oriented development) outdated.The City of Frederick and nearby areas have evolved as a research and development and high-tech employment hub independently of northward business expansion along the I270 corridor from Montgomery County and the Washington Metropolitan region.

  • Frederick County should focus on its own local employment development efforts and be flexible to changing economic and technology conditions.Its planning efforts need not depend on Montgomery County’s “High Tech Corridor,” which was conceived decades ago as a competitive location for bricks and mortar offices and labs, close to key federal labs and regulatory agencies, but has been superseded by internet-enabled management and dispersed research and development.Technology development has slowed in Germantown and is minimal in Clarksburg.

  • The previous metropolitan area planning concept of “wedges and corridors,” focused on employment along the transportation corridors leading to the Washington core, is obsolete and its influence should be retired.

  • Transportation infrastructure and networks will still be needed in the future but primarily as distribution networks for goods rather than for commuting workers.Distribution centers should be located in areas with adequate transportation and other infrastructure, not in open space.

  • As internet activity continues to grow, the need for data security and redundancy grows.Data centers should be located in areas with adequate electricity and water supply infrastructure, not in open space.

 

Fairness

 

Fairness is an issue and all land west of 270 from the Monocacy Battlefield to the Montgomery County

Line should be included in the plan and provided the same protections. Splitting this area by using Route 80 as the boundary and by continuing to preserve the cutout at Thurston is blatantly unfair to landowners in the area. By supporting new development on one side of Route 80 or in the Thurston cutout and not allowing it on the other side, the County is making a choice to reward some landowners and unfairly penalize others. When a community is integrated in terms of neighbors and land use, and then that community is split in half, with benefits going to landowners on one side while penalizing landowners on the other, it is blatantly unfair. 

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