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Royce Hanson
Chairman
Montgomery County Planning Board
Maryland-National Capital Park and Planning Commission
8787 Georgia Avenue
Silver Spring, MD 20910
Dear Chairman Hanson,
We represent environmental, civic, and watershed organizations who are working to protect and restore the waters, watersheds and communities of Montgomery County. We engage in this work as part of a larger effort to protect and restore the Anacostia River, Rock Creek, the Potomac River and the Chesapeake Bay watersheds.
We join with the Eyes of Paint Branch and its Vice President and Action Chair, David Dunmire in calling on you to oppose the phased construction of the InterCounty Connector (ICC) in the New Hampshire Avenue interchange and the Cape May cul-de-sac, because this work threatens the sensitive waters and the biological community of the Upper Paint Branch Special Protection Area (SPA). In its February 15 letter to the Planning Board, Eyes of Paint Branch laid out numerous substantive concerns with respect not only to the process by which the State is attempting the speed the construction of the ICC and the destruction of irreplaceable natural and social resources, but also with respect to the State's refusal to heed local agency staff's concerns about whether the State's stormwater plans will perform as well as the State asserts and assumes.
On January 29, 2009, the Planning Board reviewed whether the SHA has addressed concerns raised by county agency staff or had fulfilled 12 recommendations for compliance with SPA requirements for Upper Rock Creek. The Board found that the SHA had met only three out of those 12 reasonable recommendations.
We note that in its most recent report on the SPAs, the Montgomery County Department of Environmental Protection found that streams in three out of four SPAs had suffered degradation from development since the mid-1990s. We note also that recent reports from the Chesapeake Bay Program and the Chesapeake Bay Foundation have found that 25 years of intensive efforts to save the Bay have failed, due largely to: rampant sprawl that continues to destroy the very forests, wetlands and flood plains needed to protect, sustain and restore the Bay and its tributaries; agricultural run off; and air pollution from motor vehicles and power plants.
As you probably know, the State estimates that the ICC would trigger roughly three-quarters of a billion miles of new driving per year and roughly 5000 acres of new growth, growth this is not prescribed in local master plans. Much of that growth is likely to be sprawl, which the State estimates would destroy thousands of additional acres of forests and wetlands. Further, land use experts have estimated that the ICC could, in fact, trigger more than 20,000 acres of new growth. The inescapable conclusion is that the ICC is a $4 billion leap in the wrong direction when it comes to saving the Bay and fighting global warming.
Returning to the issue immediately before you, the Upper Paint Branch SPA no longer shelters subwatersheds or stream segments with the highest biological diversity rating; in 1994 to 1998, there were five such stream segments. ICC construction in this watershed further threatens these sensitive waters. The Planning Board and the County should redouble their efforts to restore the damaged subwatersheds rather than expedite the construction of the ICC and the destruction of these precious resources.
Upper Paint Branch was designated a Special Protection Area due to the reproducing trout populations existing there. But this issue extends beyond a single species of fish, however valuable the trout is as the proverbial canary in the coal mine, as a sensitive species that can indicate how healthy the Gum Spring and Good Hope tributaries, and how precious a resource the Upper Paint Branch Special Protection Area is. These and other waters in Montgomery County serve as nurseries to anadromous fish that inhabit the Bay. The U.S Environmental Protection Agency has stated that the forests and wetlands that sustain these waters are exemplary and irreplaceable, and our neighbors downstream must count on us, and on you, to protect them.
The healthiest waters in the North Branch of Rock Creek rival those of the Upper Paint Branch, and no one who views the moonscape that the State has made of the Mill Creek Watershed can take seriously any claim by the State that it will protect these resources. This is especially true when the State so willingly disregards legitimate concerns raised by the Planning Board and county environmental staff, who have pointed out that the State is not complying with its own conceptual plans and that the systems that State plans to install are likely to fail, would be difficult of not impossible to monitor, and very expensive to maintain, if they can be properly maintained at all.
The ICC's construction will bring a heavy footprint down on these sensitive watersheds, including reduction of summer base flows; increased stream temperatures; loss of forest cover; and increased turbidity levels. The State Highway Administration's sketchy stormwater and sediment control plans instill no confidence that these problems will be prevented, and we are highly skeptical that the proposed plans to bring construction site and highway runoff across the drainage divide to Northwest Branch will succeed in protecting Paint Branch and Northwest Branch.
You are the stewards of these resources. We urge you, therefore, to oppose the State's plans to speed and further piecemeal the ICC's construction, to halt the State's incursion on the County's parks, and to insist that the State fully resolve all outstanding SPA compliance issues and fully meet all SPA goals.
Yours for clean water,
Diane Cameron
Conservation Program Director
Audubon Naturalist Society
