S.C.A. Position Statement:
In a February 19, 2007 memo to the Montgomery Parks and Planning Board, S.C.A. reviewed and made comments on the Final Report of the Ad Hoc Agricultural Policy Working Group, published January 2007. In that report, the Working Group outlined the Sand Mound regulations:
- Sand Mounds
- Current master plans recommends against use of alternative individual and community sewerage systems in the reserve. There is debate as to whether sand mounds are an alternative system.
- Report recommends continued use of sand mounds, but limiting their potential use.
- Most controversial of all topics in report.
- Recommended for parcel existing as of 12/1/2006:
- Allow sand mound where there is an existing house and the sand mound would not result in development of an additional house;
- When it enables property owner with approved deep trench system percs to better locate potential house to preserve agriculture;
- For child lots, provided recommendations for child lots are also adopted;
- For bona fide tenant housing wherein dwelling can never be conveyed from parent parcel;
- Pre-existing parcel defined as exempt lot or parcel;
- Properties where there has been significant investment in testing for sand mounds prior to adoption of these restrictions;
- Permitted agricultural uses;
- Purpose of qualifying for a State or County easement program.
The S.C.A. endorses the comment that states that the Functional Master Plan speaks strongly against alternative individual sewerage disposal systems usage in the RDT zone. This position was adopted to limit maximum build out in the RDT zone. Widespread use of sand mounds will undercut the goal. While the issue of whether or not sand mounds are an “alternative system” is open to debate, the intent of the master plan is clear in its effort to use sanitation management tools to limit growth in the RDT zone.