Comments made to Montgomery County Park and Planning on the need to revise certain aspects of our Zoning Code in order to harmonize with, promote, and remove barriers to, Environmental Site Design.
Please accept this email letter as the comments of the Audubon Naturalist Society
on the Montgomery County’s Zoning Code “Sustainability Audit.” Your email requested specific comments on “the priority pieces of the audit that should be incorporated into the new zoning code.” You had set today, June 1, as the deadline for your receipt of comments that will be presented to the Zoning Advisory Panel at its June 16 meeting.
Regarding the Sustainability Audit, (attached), we support the provisions of the Stormwater matrix, pp. 19 through 22, with the exception of the item concerning the proposed inclusion of green roofs for the “green area” requirement. As ANS has previously testified, we support green roofs for several reasons, but they do not serve as ground-level green areas. We support the amendments to the definition of green area contained in ZTA 08-01 proposed by Councilmember Elrich, and we see this definition as being conducive to our stormwater/ESD, Smart Growth, walkability, green street, and other County sustainability goals.
As I requested during our May 24, 2010 meeting at the Planning office, we ask that you incorporate all of the attached Biohabitats and Horsley-Witten Group consultants’ comments into the Zoning Code revisions. These consultants’ comments are aimed at helping the County to fulfill its stormwater permit mandates for:
* elimination of barriers to use of ESD practices;
* identifying specific opportunities to promote use of ESD; and
* correction of gaps in the code where ESD could be better enabled
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