November 16, 2020,

Anne Arundel County Chamber of Commerce
General Development Plan Comments

Overview

The Anne Arundel County Chamber of Commerce represents over 400 businesses located throughout Anne Arundel County and we are pleased to present these comments concerning the draft of the General Development Plan.  The comments presented in this document were prepared by the Chamber’s Legislative Committee with input from the Board of Directors, Chamber members and through an virtual Town Hall meeting.

This document will present broad comments about the General Development Plan and specific recommendations for the goals, policies and strategies of the Planning for a Healthy Economy section.  The draft GDP document seeks to guide the blending of land development regulations, environmental protection, certain social policies and promote economic growth.  From the Chamber’s perspective, the draft GDP has not placed enough focus for the economic aspects of the various goals, policies and strategies and their impact to support small and large businesses that will provide jobs for hundreds of thousands of Anne Arundel County residents.

The GDP creates long lasting guidelines and will ultimately result in a comprehensive re-zoning that can make the County a less attractive place for businesses to operate if economic impacts are not fully considered.  We believe that there should be an increased focus about the economic consequences from any goal, policy and strategy in the GDP since it will impact employment opportunities for the  residents of Anne Arundel County and tax revenue for local, county and state governments.

General Comments

The draft GDP Plan is out of balance weighing heavily against market-driven growth in favor of preserving agricultural lands and environmental conditions. There is no question that the environment must remain a priority, and it can remain so while also allowing the market to dictate where economic and population growth should occur.

The Plan proposes that development and growth should occur only in specific policy areas such as Town Centers, Critical Economic, and Transit-Oriented.  These designated Development Policy Areas only make up a small fraction of the overall County, and fail to incorporate the existing framework of infrastructure and economic demand throughout the remainder of the County. The overwhelming majority of the County is designated as either Rural and Agricultural, Peninsula, or Neighborhood Preservation policy areas.

The impact of limiting areas of Targeted Growth spaced apart throughout the County will result in increased strain on the County’s aging transportation infrastructure, which is contradictory to the goal of minimizing existing and new traffic congestion. Too much separation of commercial and employment centers from residential areas will force residents into their car and on to the roadways.

It appears that the Plan treats the County as urban in certain respects and suburban in others. The urban concept relies heavily on “multimodal” transit that does not currently exist within the suburban County. The overwhelming majority of transit is, and will remain, auto-centric. In addition, the movement towards electric vehicles (EV) is accelerating and many auto manufactures are offering EVs and their will be an increased demand for the required infrastructure to support these vehicles which is not addressed in the Plan.

In an effort to shift away from the existing transit uses, the Plan calls for new alternative transit options that would likely take several decades of planning and hundreds of millions, if not billions, to construct. It is uncertain where the funds for these transit options would come from and it should be noted that improving and expanding existing roadways and traffic corridors receive funding through fees from new development.

If the Plan limits where that development and growth can occur, then certain congested areas are likely to remain unimproved for the foreseeable future. By promoting pockets of mixed-use growth into Town Centers, the County will end up with mini-urban areas sprawled throughout the County that rely heavily on automobile traffic.

There are several suggestions in the Planning for the Built Environment section of the Plan calling for “flexibility” and a “form-based code” to allow for a variety of development types, but they are limited to only those Development Policy Areas that the County has selected for growth.  The idea of flexibility is extremely important and needs to be implemented County-wide.

Environmental protective and restorative measures, along with preservation, can and should be incorporated into growth, development, and redevelopment areas, but the market should dictate where that occurs. By limiting where growth can occur, the Plan is inherently isolating and overburdening those areas throughout the County that lack infrastructure. Regulations can be implemented to ensure environmental protection and adequate infrastructure in all parts of the county.

The County plays a dual roll as regulator and administrator of the land development process.  All too often, the regulatory function overshadows the administrative function and “by-right” or compliant job creating projects (many of which are for small businesses) are significantly delayed by too much regulatory oversight.  Strategies should be incorporated into the Built Environment section of the Plan that call for the establishment and on going monitoring or metrics to measure the time from plan submission to shovel in the ground.

Planning for a Healthy Economy Comments

A primary goal of the Chamber is to ensure that our member companies have a strong and growing local economy in which to do business.  To accomplish this, the Chamber believes that local and state government policies should support and encourage business and not create an excessive tax burden, implement cumbersome and costly regulations and when possible, help create sustainable private sector jobs.

The Planning for a Health Economy section supports the primary goal of the Chamber and we would like to offer a series of specific comments about he goals, policies and strategies contained in this section.  It is important to have reasonable development regulations along with adequate infrastructure in the County to ensure that businesses have the tools to provide sustainable jobs for the residents and tax revenue for the county.  Therefore, the goals, policies and strategies of the GDP should be fully thought out and the mechanism to implement them should not be not be short changed.

Over 75% of the strategies in the Health Economy section of the GDP have listed the Anne Arundel Economic Development Corporation (AAEDC) as the lead.  We are concerned that too many strategies have been assigned to the AAEDC and they will not be able to implement them in a timely and meaningful fashion.  The AAEDC has done an outstanding job with limited resources during the COVID-19 crisis and we are concerned that too much is being asked of them in the draft GDP under current staffing levels.

Policy HE1.2 could push an employer or entrepreneur away from the location best suited for a job creating project. It must be noted that there are times when an employer or entrepreneur will need to locate outside the targeted areas and they must have access to the same resources, particularly if they meet all the regulatory requirements.

Policy HE1.3 seeks to promote the redevelopment of brownfield sites but seems to omit the property owner or business from the process.

Policy HE2.2 seeks to direct business expansion to Target Redevelopment and Revitalization Policy areas to minimize sprawl and take advantage of infrastructure that is already in place.  The City of Annapolis should be included as an area to target business expansion.

Policy HE2.4 promotes the concept of increasing business innovation and entrepreneurship and lists several strategies to support this policy. There are many organizations providing support to the small business and entrepreneurial community.  What is lacking, is an overall coordination of these services in such a fashion that would make it much easier for a business or entrepreneur to find assistance.  “Strategy a.” should be amended to call for the development of a plan to inventory and coordinate business support services.  This would be similar to “Strategy d” of Policy HE2.5.

Policy HE2.4 overlooks the important role that financial institutions such as banks and Community Development Financial Institutions (CDFI) play in supporting business development and entrepreneurship.  Many of these financial institutions have certain requirements under the Community Reinvestment Act (CRA) to provide financial support to the small business and entrepreneurial communities for the areas they serve.

Policy HE3.1 supports the coordinated development and redevelopment around Fort Meade.  The strategies talk about seeking out partnerships to support the infrastructure, education, housing, and transportation needs of the area.  There is specific mention of partnering with the private sector to advocate for resources, but this should be expanded to include the Maryland’s Congressional delegation since they could help secure federal funding.

Policy HE5.1 seeks to push development into designated areas such as Sustainable Communities, Commercial Revitalization Areas and Opportunity Zones.  The policy hampers property owners and employers to seek out the locations best suited for their needs and job creation efforts.  The Strategies supporting Policy HE5.1 do not seem to include property owners and promote government and the community to lead the drafting of boundaries, zoning ordinances and related policies. It is important to ensure that property owners and employers, who will invest private funds, are recognized as an important part of any develop or job creating activity.

Policy HE5.2.  While it is important to ensure adequate resources and incentives for infrastructure projects in targeted areas, it is important that these same resources are available to property owners and employers who are providing job creating projects in other areas. The term resources should be defined in this policy (capital vs. operating) since it seems to be calling for undefined increase of staffing which could result in long term fixed costs for the county.