May 8, 2004

Mr. Steven Silverman
President, Montgomery County Council
100 Maryland Avenue
Rockville, MD 20850

Dear County Council Members:

Please vote no on the forest conservation exemption for equestrian facilities. We support equestrian facilities in the Ag Reserve when they observe the same environmental standards that all other operations must conform to. There are glaring holes in the proposed equestrian standards that are outlined below setting a different set of rules for equestrian operations. We object to the loosening of the environmental standards and urge caution about the long term water quality degradation as a result of the 'new standard'.

1. Under the forest conservation law, streams without forest buffers have to
be afforested when the property is bought by someone who does not plan to farm. Those claiming the equestrian exemption would not have to.

2. Under the forest conservation law, if a landowner buys a parcel in the RDT zone with 15% forest and does not plan to farm, he would have to reforest 5 more acres to meet the 20% forest requirement. Those claiming the equestrian facilities exemption, however, would not need to reforest or afforest.

3. Under forest conservation law, a landowner in the "agricultural and resource" areas who wishes to clear up to 50% of his forest must replant 1 acre for every 4 acres cleared; above the 50% threshold, the landowner must replant 2 acres for every acre cleared. Equestrian facilities would be exempt from any replanting up to the 50% forest-clearing threshold. Under the equestrian exemption, for example, a landowner who owns 100 acres with 50 acres of forest could clear 24.9 acres of trees without having to do any reforestation. (Beyond that, he would be subject to the forest conservation law.)

You clearly are creating two different standards for land use with the proposed exemption, can you explain how this new rule fosters good environmental stewardship in large scale equestrian facilities?

Tina Brown
18201 Barnesville Rd.
Barnesville, MD


((Here is the letter that I sent in early April, the same set of questions apply to recent changes.))
Montgomery County Council

RE: Bill # 29-03, Forest Conservation- Equestrian Facilities

Dear President Silverman and Members of the Montgomery County Council,

I write today on behalf of Sugarloaf Citizens Association to ask for your serious consideration of the long-term impacts to Montgomery County’s water quality as a result of the proposed changes in the Forest Conservation Exemption for Equestrian Facilities. Serious environmental questions remain unanswered regarding the potential impact to our stream valleys if this forest conservation exemption is widely used by equestrian and agricultural landowners.

After reading the latest draft and discussing our concerns with staff at the council and Park and Planning, these questions remain:

* How will stream buffers be protected? Under the proposed exemption, horse pasturage can go right up to the stream valley bank, allowing the horses to degrade the stream bank and reducing the vegetative cover that serves as a filter for the increased sedimentation and runoff.
* Grass pastures do not hold the same filtration capacity nor ecological function as do the more diverse stream bank vegetation that is found in a forested area. What are your environmental impact projections for the eventual transition from the current vegetative/filtration system to a denuded stream bank if this exemption is widely used?
* Will this exemption for equestrian facilities encourage agricultural landowners to use their forested land for equestrian uses, in order to bypass the current stream valley guidelines outlined in the Forest Conservation Plans? Council and Park and Planning staff were unable to answer the question: Has anyone looked at projected water quality impact of this new exemption to forest conservation laws if there is widespread use by large and small agricultural and equestrian land owners in the Agricultural Reserve?
* What other environmental protection measures will you introduce to compensate for this weaker environmental standard that you will create if the Forest Conservation guidelines are lifted for Equestrian Facilities?

We hope that you will not dismiss these water quality impacts as you contemplate rolling back the Forest Conservation Laws that have provided water quality protection in the Agricultural Reserve. I understand the political pressures at work in this development decision, however the Agricultural Reserve was set to a higher environmental standard years ago. That is why it is a national model for wise land use.

Thank you for your consideration of this very important matter,

Tina Brown
18201 Barnesville Rd.
Barnesville, Maryland 20838

Sugarloaf Citizens Association
Board Member

Return to Sugarloaf Home Page