October 27, 2005
Mr. Steve Dodd, Director
Dorchester County Planning and Zoning Office
P.O. Box 107
Cambridge, MD 21613
Ms. Anne Roane, Director
Department of Public Works, Planning, and Zoning
City of Cambridge
705 Leonard Ln
Cambridge, MD 21617
Dear Mr. Dodd and Ms. Roane:
We would like to comment on the proposed increase in growth allocation for Blackwater Resort Communities. As called for by the Chesapeake Bay Program, nutrient and sediment reductions are critical to restoration of the Bay. Development designs need to be ecologically responsible to maintain important fish and wildlife habitats within the Chesapeake Bay watershed. The Little Blackwater River flows into Blackwater National Wildlife Refuge and is one of two primary fresh water sources for this ecologically important area. The proposed changes to the headwaters area from this and other development activities could have significant and long-lasting effects on the Little Blackwater River and associated natural habitats. Water quality and sedimentation problems upstream of the refuge may affect fish, wildlife, plants, water quality, water quantity, and other natural resources on Blackwater National Wildlife Refuge. Development activities that affect sedimentation and storm water management also affect our ability to restore the health of the Chesapeake Bay. Development activities that increase sedimentation and storm water further may reduce our collective ability to restore the Chesapeake Bay.
The Chesapeake Executive Council, at its meeting in January 2005, issued Directive 04-2, which was signed by all the Governors and includes a section titled "Managing Urban Stormwater" which states as follows:
"The Blue Ribbon (Finance) Panel emphasized the challenge posed by development patterns in the watershed, and the danger that growth could weaken, and possibly outstrip, our collective efforts to restore the water quality and habitat of the Bay and its tidal tributaries. The projected high costs for correcting urban stormwater pollution in the Tributary Strategies are beyond most jurisdictions' ability to fund at this time, and developments each day are adding to the stormwater pollution burden. The Panel urges that preventive strategies be fully implemented and enforced."
Little information currently exists, however, on the water quality or fisheries resources of the Little Blackwater River. Historically, the River supported both resident fish (e.g. largemouth bass, crappie) and migratory species (e.g. river herring, American shad). In the past, the River has supported a commercially sustainable diversity of species including white perch, American eel, catfish, and a host of forage species. American eel, American shad, and river herring are current species of concern to the U.S. Fish and Wildlife Service. Fish species provide a vital link in the food chain for important raptor species such as the bald eagle and the osprey. Previous research has demonstrated that when impervious surfaces exceed 10-15% of a watershed that fish abundance, recruitment and habitat declines sharply (Galli 1994, Center for Watershed Protection 2000). Fishery resources within and surrounding the Refuge are vital to the overall health of the Chesapeake Bay. If development occurs in sensitive environmental areas, we recommend appropriate monitoring to assess impacts to natural resources and we recommend using environmentally appropriate techniques for development.
The Blackwater watershed provides critical habitat for migratory waterfowl using the Atlantic Flyway. The Little Blackwater River corridor is used extensively by these waterfowl. Blackwater National Wildlife Refuge supports the largest population of nesting bald eagles within the Chesapeake Bay and adverse impacts to water quality could affect this population. Similarly, the endangered Delmarva Fox Squirrel (Sciurus niger cinereus) depends on habitat within this watershed (a separate consultation addressing these impacts is ongoing). The overall ecological health of the Blackwater watershed is critical to biodiversity and conservation of natural resources within the Chesapeake Bay.
The U.S. Fish and Wildlife Service believes additional information is needed and that a long term protective strategy should be put in place before the growth allocation is approved. Therefore, we recommend the following actions:
Implementation of this type of local development strategy would be highly beneficial and would provide significant measures to ensure the environmental quality of the Blackwater National Wildlife Refuge and the Chesapeake Bay for future generations.
Further, we request that the U.S. Fish and Wildlife Service and the U.S. Geological Survey be given the opportunity to review and comment on the proposed protocols and results of the hydrologic study to be conducted by the County before an increase in growth allocation is granted. We are also looking forward to seeing the baseline information collected for the Environmental Assessment by the U.S. Army Corps of Engineers under the 404 permit process.
We would be happy to meet with the City, County, Councils, and with Blackwater Resort Communities to provide additional information regarding this topic. Please contact us if you have any questions.
Sincerely,
John Wolflin, Supervisor
Chesapeake Bay Field Office
U.S. Fish and Wildlife Service
410-573-4573
Steve Minkkien, Project Leader
Maryland Fisheries Resource Office
U.S. Fish and Wildlife Service
410-573-4506
Glenn Carowan, Project Leader
Chesapeake Marshlands Complex
U.S. Fish and Wildlife Service
410-228-2692