Mr. James R. Tokar, P.E.

Structural Engineer/ Project Manager

Montgomery County Public Schools
Division of Construction
2096 Gaither Road, Suite 203
Rockville, MD 20850

October 7, 2010

Dear Mr. Tokar,

Thank you for enabling Jack Gleason and me to review the site plans for the McKenney
Hills Elementary School project this past Monday on behalf of the Audubon Naturalist Society.
We have assessed those plans in relation to the Forest Conservation Plan (FCP) submitted to the
Montgomery County Planning Board for review and hearing on October 28, 2010. I write today
to urge Montgomery County Public Schools (MCPS) to postpone the letting of bids on this
project until the FCP and related Plans for this project have undergone the thorough vetting they
will get later this month at the Board.

While MCPS is entitled to time the bidding process as it sees fit, doing so now is
premised on the assumption that the Board will approve the FCP without any significant impact
on the reliability of the bids you will receive thereafter. Making that assumption is an overly
optimistic appraisal of the viability of the FCP as submitted, and could very well require you to
start over with the bidding process after Board action on it.

Please allow me to elaborate on why we believe that the proposed FCP will need to be
changed. Like Montgomery County Public Schools, (MCPS), Audubon Naturalist Society is a
landowner in the Lower Rock Creek watershed. About half of our 40-acre Woodend Sanctuary is
forested, and we recognize the importance of mature trees to the health of Rock Creek. As forest
losses upstream from our property have accelerated in recent years, we’ve witnessed the steady
decline of this treasured waterway.

The McKenney Hills forest is part of a larger contiguous forest, including parcels
preserved through Legacy Open Space that is roughly 50 acres in size, and over a century old.
The forest on the school property comprises over 8 acres of oak-hickory-beech dominated forest
directly adjacent to Park Property. There are a significant and a generally unprecedented number
of specimen trees, with many mature trees exceeding 40 inches in diameter at breast height
(DBH). This forest rates High Priority for retention based on an approved Natural Resources
Inventory/Forest Stand Delineation, and is of exceptional quality due to its age, composition and
proximity within the “Down-County.” Mature, publicly-owned urban forest is a scarce
commodity in Montgomery County.
Letter to Mr. James Tokar of MCPS
From Diane Cameron of ANS 10.7.10 2

Damage to the McKenney Hills Forest will result in the degradation of the entire
interconnected ecosystem, particularly of the Capitol View Branch stream, of which this forest is
an integral, and, indeed, a critical part. As a fellow owner of a crucial forest parcel in the Lower
Rock Creek watershed, MCPS has the opportunity, through design control over the McKenney
Hills school project, to maintain and protect the existing forest. The school plans make clear to us
that modest, reasonable changes to the project will achieve a full level of protection, avoiding the
loss of, or damage to, any of the existing, high-priority woods that surrounds the existing clearing
on the McKenney Hills Site. The FCP proposes to remove a total of 55 mature trees and to
damage the critical root zone of an additional 24 mature trees. These are tremendously significant
losses, wholly apart from additional losses of other trees by the edge effects of forest clearing,
soil compaction, invasive plants and hydrologic changes.

These planned losses lead us to the inescapable conclusion that the plans for the school
were driven by considerations that were insensitive to forest impact. Thus, the FCP stands more
as an inventory of destruction than as a plan to minimize forest damage. This is especially
disheartening to us, because, like MCPS, Audubon Naturalist Society has an educational mission
that we take very seriously, and in which we have long partnered with MCPS for joint programs.
We are environmental educators who use our own woods and meadows as our outdoor
classrooms for the students who come to our Sanctuary every week. At the McKenney Hills site,
MCPS has the opportunity to utilize as an outdoor classroom, a healthy, mature forest ecosystem
-- a very rare situation in the Downcounty Consortium. In preserving and utilizing this forest as a
classroom, the McKenney Hills Elementary School will be able to give its students a rich
experience in meeting the new Maryland Environmental Literacy Standards.

But if the current site plans are not adjusted to minimize the incursion into these woods,
MCPS will have damaged an important part of this forest, and its teaching potential. We intend
to present these considerations to the Planning Board later this month. It is our understanding
that the Forest Conservation Law at both the State and local levels requires MCPS to demonstrate
to the satisfaction of the Board that all reasonable options for protecting the high-priority forests
at the McKenney Hills school site have been exhausted, prior to being allowed to remove or
damage any portion of such a high-priority forest. We also understand that the Forest
Conservation Law requires an individual variance, demonstrating exhaustion of reasonable
alternatives, before the Board will allow removal or damage to the root zone, of any individual
tree with a diameter at breast height of 30” or greater. There are 29 such trees among those MCPS
plans to remove, and 13 additional such trees proposed to sustain root zone impact, again without
showing that all reasonable alternatives enabling full preservation of these trees have been
explored and exhausted.

We think it is manifestly clear that this required burden of proof has not been met by
MCPS, especially since a few modest yet crucial changes to the site plan and associated FCL and
SWM plans would fully preserve and protect the woods and all the individual trees. These
changes would not affect the building itself, and may in fact save MCPS money in avoided hard
infrastructure costs. Indeed, the changes are so modest that they can be made without material
delay in the project schedule, i.e., completion in the summer of 2012.

More particularly, the following set of reasonable changes would enable MCPS to shrink
the sites’ footprint -- and in so doing, fully preserve all of the existing high-priority woods on all
sides of the project:
Letter to Mr. James Tokar of MCPS
From Diane Cameron of ANS 10.7.10 3

1) Use the existing paved basketball court, and other recreational facilities at the adjacent
public park, enabling MCPS to avoid the expense and space required to build new
recreational facilities on the school grounds;

2) Relocate and/or downsize the proposed geothermal unit, from its present planned
location underneath the playing field;

3) Take all proposed stormwater facilities out of the woods, in recognition that the mature
trees such facilities would replace, are far more effective – and cost-effective –
stormwater management devices;

4) Utilize sustainable landscaping techniques on the school grounds, that employ porous
paving and trees and native vegetation to infiltrate stormwater.

Our request that the Planning Board require changes to the proposed FCP is coupled with
our request for changes to the project’s Stormwater Management Plan (SWM Plan) as well, in
that the latter is needlessly intrusive of the forest requiring protection. The proposed SWM plan
for this site would cut down trees and damage root zones of trees, in order to install stormwater
bioretention units. This is inadvisable, and we request that you adopt a principle of “first, do no
harm” to the existing forest, including for the selection, placement and design of any stormwater
facilities. Attached are stormwater documents describing examples of sustainable landscaping
stormwater practices that incorporate trees and other native vegetation (generated by the Center
for Watershed Protection in cooperation with the USFS). They show how MCPS can produce
more effective stormwater management within the site’s existing cleared footprint, adjacent to the
existing forest. These and other elements could also incorporate a native plant-based
environmental education program and classroom (in addition to the outdoor amphitheatre already
planned for this site).

Mature trees in a healthy forest are the single most effective stormwater facilities known
to science. They require less maintenance than any engineered facilities, and are significantly
more effective across the spectrum of target stormwater, hydrologic, carbon sequestration,
temperature, air quality, wildlife habitat, and educational functions.

While we recognize that it may take some time for MCPS to give our proposals serious
consideration, the timing of the letting of bids is clearly something under your control that can be
changed immediately. Considering all the variables, we hope you will agree with us that delaying
the bidding until after FCP and SWM Plan review is the prudent and sensible thing to do.

Regards,

Diane M. Cameron
Conservation Program Director
Audubon Naturalist Society of the Central Atlantic States, Inc.