September 29, 2008

Dear Chairman Bunting and members of the Planning Commission,

I noted with interest, a recent editorial cartoon in the O.C. Today newspaper. The cartoon depicted the Worcester County 2006 Comprehensive Plan as a bottle that had washed up on a beach after a storm, with a note inside the bottle that said "Help".

I'm glad to see the general public is now recognizing, just as Assateague Coastal Trust realized earlier this summer, that our award winning Comprehensive Plan is in trouble.

ACT was very disturbed by Ed Tudor’s August 26, 2008 memo to the Commissioners, in which he gave them just the opportunity they were looking for to:

• avoid having to deal with the E-1 down zoning component of the plan, which is necessary to control growth outside of the designated growth areas, as well as protect our water resources and also keep development out of flood prone areas;

• drop the language that would require Environmental Site Design (ESD) implemented at the conceptual drawing phase of subdivisions in order to mimic natural hydrological run-off characteristics and minimize impact of land development on water resources;

• ignore Nutrient budgets and trading which is needed to implement state required TMDL's (Total Maximum Daily Loads for nutrients into our waterways;

• remove an Adequate Public Facilities Ordinance that would make development outside the designated growth areas pay for itself.

In the past three years county Planning Department staff and Comprehensive Planning staff have had more than enough time to draft appropriate language, so that by Sept. 2, 2008 Mr. Tudor should not have asked the Commissioners to gut these important components from the Comprehensive Plan.

On September 24, I attended a listening session in Salisbury on Smart Growth, sponsored by the Maryland Department of Planning. During the audience participation portion of the evening I asked MDP if there was anything they could do to 'assist' counties that were not implementing their Comprehensive Plans in a timely manner.

From their response to the question, it appeared MDP is trying to find ways to use a carrot/stick approach to remedying this problem state-wide.

Worcester County Counsel Sonny Bloxom was also at this meeting in Salisbury. He rebutted my question by stating to MDP and the audience that Worcester County had limited staff and resources and thus could not implement the plan in a timely manner.

This was quite surprising to me, given that Worcester County is fortunate to have one of the most talented planning staffs in the State. This was also surprising to me, given that in a recent meeting with MDP officials I learned that much smaller counties such as Somerset and Dorchester are much farther along in the process than Worcester County. Indeed while Worcester County has not updated its water and sewer plan since 1994 these smaller counties have managed to meet the required three year updates every cycle.

Regarding implementation of Worcester County's Comprehensive Plan, Mr. Coyman and his Comprehensive Planning Department have access to ordinance models and the language necessary to draft these new ordinances so that all the components of the Comp Plan could be in place for review by the Planning Commission and eventually the Commissioners and the public.

The members and Board of Directors of Assateague Coastal Trust hope the Planning Commission will request that these missing components of the adopted 2006 Comprehensive Plan be written and brought back to you for review, and then sent along for final public comment hearings.

Thank you for your consideration of this matter.

Best Regards,


 Kathy Phillips 
Executive Director
Assateague Coastal Trust