Stormwater Partners Network comments on Montgomery County Climate Action Plan
On March 19, 2021, the Stormwater Partners commented on the Montgomery County Climate Action Plan (CAP).
The network has historically worked towards implementing stronger regulatory measures to strengthen our stormwater management and infrastructure, increase infiltration of water on site instead and decrease stormwater runoff into our precious local waterways. Flooding is one of the major drivers of habitat and infrastructure degradation in the county, and one of the costliest impacts. With more frequent and heavier rainstorms due to climate change, we applaud that the CAP climate action plan highlights the urgent need to take a close look and an immediate action on our stormwater management and infrastructure. We also strongly support the incorporation of equity into every element of the CAP and encourage the County to continue working with communities of color, low-income communities, and others likely to be most affected by the hazards and harms that climate change will bring, including with flooding and heat stress.
We support many of the stormwater-related goals and policies included in the CAP, including extensive natural solutions related to soil sequestration and forest carbon. Although these natural solutions to climate resilience are a great start, we need to do more to protect these valuable natural resources. We recommend the addition of “a no net loss of forest” policy in the CAP as part of updating the county’s Forest Conservation Law (FCL). Such a step would also follow other counties around the state which have strengthened their FCLs. The Chesapeake Bay TMDL “pollution diet” rests on a fundamental assumption that Bay wide, and statewide in Maryland, we are maintaining existing forest cover levels and not losing forest. Since the FCL only applies to development projects covered by its calculation requirements, the county can suffer forest and tree canopy loss even if "no net loss" is achieved under the FCL. Therefore, in addition to no net loss under the FCL, we propose a county-wide policy goal to increase total tree canopy cover and total forest cover.
Furthermore, the CAP needs to have specific budget allocations and metric requirements to ensure that the policies and actions stated in CAP are enforced and meet the county’s climate goals. The CAP needs to work closely with the new General Plan (Thrive 2050) and Master Plans, as sustainable land use is closely linked to many of the actions listed in CAP. Enforcement and strengthening existing laws protecting our forest and waterways must also be highlighted in the final CAP.
We look forward to working with the County Executive, DEP, and other county agencies in the creation of strong policies and actions around stormwater that will create resilient communities around the worst effects of climate change.