Maryland Chapter
7338 Baltimore Ave Suite 102
College Park, MD 20740
To: the Howard County Planning Board, June 5, 2014
RE: Sierra Club Objections to Patapsco Heritage Greenway draft Management Plan for a Patapsco Valley Heritage Area
The Patapsco Heritage Greenway, Inc. has submitted a Draft Management Plan for a proposed Maryland Heritage Area that would include more than 5000 acres of Patapsco Valley State Park (PVSP). This Draft Management Plan is unacceptable even as a general outline for proposed development because it specifically mentions construction projects and services in and for the Patapsco Valley State Park which would be performed under the aegis of the Heritage Area and its managing entity, Patapsco Heritage Greenway.
There is no independent agreement with the Patapsco Valley State Park or the Maryland Park Service of the Maryland Department of Natural Resources that authorizes those plans. Authorization should take the form of publicly-approved state plans. In particular, the Maryland Department of Natural Resources needs to create an up-to-date Master Plan or Management Plan for the Patapasco Valley State Park, with public participation.
The purpose of Certification of a Heritage Area is "to increase the economic activity associated with tourism, creating opportunities for small business development, job growth, and a stronger tax base" through heritage tourism development.
According to the statute governing Heritage Areas (mht.maryland.gov/documents/PDF/MHAA_Statute.pdf), the counties would be obliged to conform to the Heritage Area’s Management Plan. Adopting the Management Plan will require amending the existing county plans (see the Baltimore County Council resolution, PHG_resolutions_BaltCo_1213.pdf).
The comprehensive plans of the counties don’t apply to the state land. The Department of Natural Resources (DNR) has jurisdiction over the State Park. However, the DNR has no authority to approve or disapprove the PHG’s proposed Management Plan for the Heritage Area. We have no documentation that the DNR agrees with any of these proposals, and that documentation would have to be approved independently by the public in any case.
This means that the Heritage Area’s plan, approved by Baltimore and Howard Counties, will be imposed on 5000 acres of the State Park – or, will give the appearance of being approved by the counties to apply to state land.
Existing regulations and development authority, including that of the DNR, will be influenced and/or abrogated by the Management Plan, if approved. The counties don’t have the authority to approve an economic development proposal for state land, but approving this Heritage Area with the Park in it appears to do that.
The Heritage Area will be just as effective in promoting tourism if the Area surrounds the lower third of Patapsco Valley State Park, but doesn’t include it. Any tourism-related activity that the managing entity could conduct in the Park can be done by a non-profit organization without any need of Heritage Area management status.
If the “managing entity” intends to conduct development projects or perform services that couldn’t be done by the Patapsco Heritage Greenway, Inc. as a non-profit organization, the public needs to know what they are, and know that the DNR has approved those projects and services with public oversight.
The Patapsco Valley State Park receives no benefit from being part of the Heritage Area. The Park already has a managing entity, the state. The state cannot benefit from funding opportunities that are available to the managing entity and others in the Heritage Area outside the Park, such as state grants. The Park is not going to seek “opportunities for small business development, job growth, or an explanded tax base”.
For these reasons, to protect the independent public management of the state park, and promote economic growth through heritage tourism development in the areas outside the state park, the Sierra Club opposes including the Patapsco Valley State Park within the boundary of the proposed Patapsco Valley Heritage Area.
The Sierra Club recommends excluding the Patapsco Valley State Park from the boundary of the proposed Heritage Area until an up-to-date DNR Management Plan for the Patapsco Valley State Park has been created with public input.
Joanne Heckman, Team Leader, Preserve Patapsco Valley State Park
Grassroots Conservation Campaign, National Sierra Club
joanne.heckman@mdsierra.org
Dave O’Leary, Steering Committee, Preserve Patapsco Valley State Park
Maryland Sierra Club
dave.oleary@mdsierra.org
Chris Yoder, Preserve Patapsco Valley State Park
Greater Baltimore Sierra Club
chris.yoder@mdsierra.org
Ken Clark, Steering Committee, Preserve Patapsco Valley State Park
Howard County Sierra Club
kenclark7@live.org