March 10, 2023
To: Frederick County (MD) Planning Commission, Craig Hicks, Chair
Winchester Hall
12 East Church Street
Frederick, MD 21701
Re: SGAFC letter of support for Sugarloaf Treasured Landscape Plan Overlay
Dear Mister Hicks:
The Smarter Growth Alliance of Frederick County is a coalition of local and state organizations with numerous members and supporters concerned with application of smart growth principles in Frederick County. The undersigned groups provide this letter of support for your consideration of the Sugarloaf Treasured Landscape Plan boundaries heretofore defined, as well as approval of the full overlay at the earliest time possible.
As you confirmed last year by your approval of the Sugarloaf Treasured Landscape Management Plan and Overlay boundaries, I-270 is the long-recognized boundary between development to the east and preservation to the west and remains by far the best line for planning purposes. The Plan must continue to maintain the west side of I-270 as Agricultural/rural and Resource Conservation. No high-intensity development should occur west of I-270 in the Sugarloaf Plan area.
If the I-270 boundary is crossed and more intense development is allowed in the Sugarloaf Plan area, there will be a race to the bottom. Rural neighbors will opt to appeal current zoning, cash out and move rather than tolerate the overwhelming impacts of commercial, industrial or high-density development. As Sugarloaf Alliance has demonstrated (https://www.sugarloaf-alliance.com/amazon-data-centers), and articles in the Frederick News Post confirmed (January 27, 2023, “Amazon to invest $35B, expand data center campuses,” and Feb. 9, 2022, Amazon proposal was worth billions”), Amazon Web Services had intended to build one or more data centers to the west of I-270 in the Sugarloaf Plan area. We continue to be concerned about the potential placement of industrial facilities in the Sugarloaf Plan preservation area.
As we know from watching the development of Quantum Loophole’s large data center campus near Adamstown, the data center goldrush is on. We respectfully request that the County Planning Commission consider the balance between allowing some industrial development on a brownfields site and the residents’ desire for preservation in appropriate and very important natural areas of the County.
We understand that the county is interested in data centers because data centers provide property tax dollars and have limited new demands on schools and roads, but the equation is not that simple. Data centers:
– do not pay business equipment taxes in the county or in Maryland, as they do in Virginia;
– consume large amounts of power and water, leading to new power line and access installations;
– create run-off and surface water impacts due to their enormous impervious surface areas;
– produce noise, light, and other negative community impacts.
Frederick County is one of only 49 counties in the nation to earn AAA bond ratings from all three bond rating agencies in 2021 and is not a “poor” county in terms of resources, whether financial or environmental. The keys to smart development are to maintain a sustainable balance of development and preservation and to scrutinize realistically the actual long-term costs and benefits of development. Livable Frederick provides for development in many nearby growth areas including the South Frederick Triangle, the Urbana Growth Area and others. The balance is to provide preservation in the Sugarloaf Plan area and extend the good preservation work of the Agricultural Reserve in Montgomery County, which the Plan area abuts.
We repeat: the Sugarloaf Treasured Landscape Plan area must be preserved, and the Overlay should be approved to protect the Sugarloaf area from industrial or other development inconsistent with the agricultural and rural nature of the Plan area. A full Overlay will redeem the county’s half-century commitment to preservation; to renege on that long-standing “compact” with Sugarloaf area residents would be dereliction.
We understand that data center owners and developers need redundancy and security and want to maximize transmission speed. We see that the Planning Commission has a stark choice. The Commission can vote either to prevent data center development in the Sugarloaf preservation area by supporting the Overlay to the I-270 Plan boundary, hopefully encouraging siting at more appropriate industrial-zoned areas like the former East Alcoa site, or the Commission can choose to open the rural southern part of the County to an unbridled rush of data center sites as the developers grasp for more land.
The Sugarloaf Treasured Landscape area, including the Monocacy National Battlefield, is, has been, and should continue to be an area designated for preservation, not an area where data centers, other industrial facilities or dense developments can be constructed without regard to environmental and community concerns. Community concerns include:
Preservation
The approved Sugarloaf Plan and its proposed Overlay District are preservation plans, not development plans. Open space, including agricultural, forested and conservation lands, is not merely undeveloped space. In the context of climate change, as well as the county’s continued need to control and balance development pressure, open space should be considered the optimal use of the entire Sugarloaf Treasured Landscape area. The I270/80 interchange has been called the “Gateway to Sugarloaf Mountain” and as such is under very heavy development pressure. It needs MORE protection, not less. The land east of Route 80 is at the head of the watershed into the Sugarloaf area. Contaminants associated with development, such as heavy metals from vehicle traffic and sediments and discharge from whatever infrastructure might be built, would negatively impact the quality of streams as they flow into the protected area.
Monocacy Battlefield
If high-density development is allowed west of I-270, the Monocacy National Battlefield will be further threatened. There is only one property (and 600-700 yards of distance) currently between developer-owned land on Route 80 near Park Mills Road and the Park boundary. The developer continued to acquire property in this area after this planning process commenced.
Sugarloaf Mountain
The mountain is a unique and irreplaceable feature of southern Frederick County. The Sugarloaf Plan and Overlay are designed to protect the mountain, its rural environment, and its natural resources, for now and the future – including after the land trust expires in 2046.
Transparency
The developer and the county have been secretive about their development discussions and intentions for the properties on the west side of I-270 in the Sugarloaf Plan and Overlay area. Residents and those who love the Sugarloaf area have a right to know what has been considered and what is being planned. County Planners and residents put a lot of work into the Livable Frederick Master Plan and the Sugarloaf Plan is the first of several small area plans to go through the process. As with the initial version of the Plan you recommended last year, please continue to listen to the residents, hold the line at 270 for the Overlay, and do your best to make decisions in a thoughtful and transparent way to re-establish the Sugarloaf Planning process as a good model for the plans that are to follow.
Again, as you confirmed last year by your approval of the Sugarloaf Treasured Landscape Management Plan and Overlay boundaries, I-270 is the long-recognized boundary between development to the east and preservation to the west. The Plan and Overlay must continue to maintain the west side of I-270 as Agricultural/rural and Resource Conservation. No high-intensity development should occur west of I-270 in the Sugarloaf Plan area.
Thank you for moving this forward to final resolution at the earliest possible time, and, for hearing the position of the citizens and residents of the area.
Sincerely,
Clean Water Linganore
Citizens for Responsible Growth ,
Climate Change Working Group,
Friends of Rural Roads,
Montgomery Countryside Alliance,
Plant the Light,
Potomac River Keeper,
Sierra Club, Catoctin Group,
Sugarloaf Alliance,
Sugarloaf Citizens Association,
Sunrise Movement Frederick,
CC: Honorable Frederick County Council: Council President Brad Young, Council Vice-President Kavonté Duckett, Council Member Steve McKay, Council Member Renee Knapp, Council Member MC Keegan-Ayer, Council Member Mason Carter, and Council Member Jerry Donald
Honorable Frederick County Executive Jessica Fitzwater
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Smarter Growth Alliance for Frederick County 