sonoma land trust letter regarding the NOP

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Bonnie Brown, SDC Campus Project

bonniebrown42020@gmail.com

Larry Davis is  initiating a study and research  group to analyze  the financial feasibility of SDC proposals.  If you are interested in collaborating with this group, contact Larry Davis at  davislhd70@gmail.com. 

Land use plans such as the three alternatives that have been presented by the consultants need to be financially driven by development, which brings income (property taxes or sales taxes) to the county and the developers, in order to build affordable housing and other projects that are not as financially producing. 

In 2018 the county and state were presented with the option to initiate a Trust, similar to the Presidio Trust, to plan development at SDC. A trust allows for community planning and a combination of financial streams. They were concerned about the time needed to accomplish a trust and the county did not want to run one. They decided on having an urban land use planning group make three alternatives that are before the public now, developer-driven.

Through private philanthropy, government, and foundation funding, perhaps either a trust can be formed for the entire site, or a portion of it. This provides for the features that are beneficial to people on this public land with less quantity of development.

For a deep dive into background information, read this document: Sonoma Developmental Center: Site Transformation Study (2015), prepared by The Potrero Group for Transform SDC.

Mark Newhouser, Chair, NSVMAC Emergency Preparedness Ad Hoc Committee

mnewhouser@vom.com

Nick Brown, Chair, Glen Ellen Forum Steering Committee

nickbrown12800@gmail.com

1. The threat of wildfire is foremost on our minds, yet the increasing probability of other emergency disasters, such as earthquake, flooding, and extended drought, should also weigh heavily when planning any major development in Sonoma Valley, such as those posed by the SDC alternatives. A viable development plan should include careful consideration of the increased public safety risk under all of these possible disasters. 
2. The three proposed SDC development plan alternatives – predicted to result in the doubling of the population for the Glen Ellen area – do not adequately address the increased risk posed by the plans. The large scale of all proposed alternatives is highly problematic for disaster preparedness, risk management, and emergency response. 
3. Disasters such as fire and flooding are likely to require mass evacuation. The geography of the valley with its limited road network and the historic pattern of wildfires cutting off evacuation routes make emergency evacuation perhaps the most vexing public safety issue in the North Sonoma Valley. A large population increase, such as proposed for SDC, will significantly increase the risk of traffic jams and harm to those stranded in disaster zones.
4. The proposed plan to extend an emergency road from SDC east to highway 12 appears ill-conceived as it would direct traffic toward the path of wildfires and would force southbound traffic to navigate a densely populated and far more heavily trafficked segment of highway. A more effective plan would be to expand existing arterial roads, adding lanes to highway 12 and Arnold Drive, both north and south of Glen Ellen and Kenwood. While cost prohibitive and highly improbable, arterial expansion would be necessary to solve an existing evacuation problem, much less accommodate the additional traffic burden of a large residential development at SDC.  
5. In the event of a major earthquake, we may lose all egress and be forced to shelter in place. Resources will be limited – food, water, fuel and other necessities will be in short supply. The proposed plan to double the population of the area will only exacerbate the shortages. Extended drought would also tax our limited water supply, which is primarily imported from the Russian River via an aqueduct that could fail in a disaster. Groundwater in the valley is in peril as it has been over-exploited and unable to adequately recharge for decades. Any new development will also increase stormwater runoff, which contributes to flooding and decreases groundwater recharge, further reducing water supplies and diminishing stream flow that is necessary for sustained fish and wildlife populations. Due to the vulnerabilities of our water supply, any proposed development in the valley must address the additional risk to available resources and public safety posed by the development under all possible emergency conditions.
6. Disaster preparedness and prevention must also be considered when proposing new developments. Wildfire prevention requires substantial changes in construction and landscape practices. However, the public safety demands for even greater protection have extended into our wildlands, resulting in the establishment of continuous firebreaks surrounding communities. Fuel breaks and extended setbacks are typically encroachments into wildlands that diminish wildlife habitat. The greater the footprint of the planned development at SDC, the greater the reduction of wildlands and wildlife habitat. As the firebreaks and vegetation management setbacks increase, so do the impacts on the viability of the existing wildlife corridor, which also provides a valuable community separator and greenbelt between existing developed areas within the valley. 
7. The proposed expansion of development, including new construction, installation of utilities, and additional human use will also increase the risk of wildfire. Utilities, including gas mains and power lines, and increased recreational use within the former SDC property will inherently increase the risk of fire. 
8. We can prepare for disaster, manage risk, and retain the ability to respond to emergencies by planning future development based on resource limitations and connectivity. Our respect for these limitations and interdependence of resources – the need to consider the consequences and long-term sustainability of our actions – will not only help preserve public safety, but also preserve our quality of life and that of all living things. 

Teresa Murphy, Board of Directors, Glen Ellen Historical Society 

glenellencav@comcast.net

The property was zoned H-4 (Historic District) in the 1970’s. Zoning change proposals could disregard the need for maintaining cultural and historic integrity of the property. Any future building needs to be reviewed by the County to assure compatibility with Glen Ellen and its history.

1. The only two buildings that were ever evaluated and listed for historic significance are the brick Professional Education Building (1908) and the Sonoma House mansion (1897. The GEHS has proposed a historic area that includes several other historically significant buildings. 
2. The GEHS applied to Sonoma County for Landmark status for the property over a year ago, however, no progress has been made to date.
3. Eldridge was previously evaluated by the California State Historic Preservation Office to meet the eligibility for listing in the National Register of Historic Places.
4. The GEHS has purchased the SDC library and has expressed an interest in the collection of historic artifacts assembled and preserved at SDC.
5. The GEHS has begun funding efforts to develop the buildings requested for a historic district. In addition, the GEHS proposed event center will generate funding to support the historic site. 
6. Historic preservation and climate sustainability are natural partners. Preservation and re-use of historic buildings reduces resource and material consumption, puts less waste in landfills, and consumes less energy than destroying entire buildings and constructing new ones.
7. It is well documented that well preserved and revitalized historic districts give an older area an economic boost. It is clear from many sources that historical designations affect property values in a positive way and are a boon to the communit

Susan Oldroyd, NSVMAC Councilmember

soldroyd645@gmail.com

The housing prioritization as described in the Vision State­ment and Guiding Principles came from state mandates, as well as the research and community engagement completed by the project team. A variety of housing types is being promoted to address Sonoma County’s housing needs and the State’s objectives for the site. The alternatives show a range of housing opportunities, including affordable housing, workforce housing, mid-in­come housing, housing for individuals with developmental disabilities, senior housing, and market rate housing.

Questions:

1. What is the justification for such a high density development? 
2. Please explain the Housing Density Bonus (see Page 22 of the Alternatives Report).
3. What parking requirements are being used for housing? 
4. Is there a state or county requirement for employment types of uses as well as the requirement for housing?
5. Please explain the CEQA “tiering” exemptions from environmental review for certain projects, including housing developments (see Page 6 of the Alternatives Report).

Other Talking Points:

1. The site and the community cannot support the level of density proposed
2. Proportion allotted to affordable housing is not sufficient-- how is this defined?
3. Harmony with other neighborhoods in terms of appearance and history
4. Local school/educational institutions
5. Child care facility
6. Better outreach to Hispanic community
7. Need designated housing for:

• Local work force for newly created jobs and also for those currently working the valley like farm workers
• Elderly Long- term care facility
• Co-housing for youth and elderly
• Previous residents
• People with special needs: Housing for people with special needs was promised in the state legislation for SDC transfer

Vicki Hill, Planning Advisory Team Member

vicki_hill@comcast.net

The SDC Alternatives Report published by Sonoma County includes three alternatives with high density residential and commercial development. None of the alternatives are acceptable for many reasons, including the following land use, planning, and policy issues:

• Development Density: Yes, we need housing but the SDC site is outside an urban growth area and not well suited for high density development due to the lack of services, transit, and sufficient roadway capacity. The site sits in the middle of the semi-rural village of Glen Ellen. This is by far the largest development ever proposed in Sonoma Valley. Both construction and operation will have substantial impacts on both adjacent neighborhoods and Sonoma Valley as a result of doubling or tripling the population in this small community. 
• Science and good land use planning principles should guide the parameters of where and how much development is located on the property.
• The density is in conflict with County policies emphasizing city-centered growth, open space resource protection, and General Plan policies regarding preservation of the land use integrity of Glen Ellen. 
• Assumptions that onsite jobs will reduce vehicle trips are flawed, as there is no guarantee that people who live there will work there.  
• Wildlife corridor protection means reducing density.
• Many people have requested an increase in the percentage of affordable housing, not adding to the existing housing numbers.
• The project will be growth-inducing, as the number of projected residents will need services beyond what is provided on the site. Pressure will be placed on surrounding rural lands to provide additional goods and services.
• The alternatives show typical grid like patterns and do not reflect clustering and other features to reduce the overall footprint and massing of buildings.
• The alternatives do not maintain the existing open campus feeling.
• There is no consideration of compatibility with the surrounding Glen Ellen community and open space resources; there is no buffer on the south side adjacent to existing neighborhoods.
• The alternatives are inconsistent with the Specific Plan Guiding Principles, established and presented in the report:
  • (#2) “Ensure that new development complements the adjacent communities of Glen Ellen and Eldridge.”
  • (#3) “…maintains and enhances the permeability of the Sonoma Valley Wildlife Corridor for safe wildlife movement throughout the site.”
  • (#4) “Balance Redevelopment with Existing Land Uses. Use recognized principles of land use planning and sustainability to gauge how well proposed land uses protect public trust resources and fit the character and values of the site and surrounding area, as well as benefit local communities and residents.”
• There is no State mandate or market incentive to develop a large-scale commercial zone, especially the size referenced in Alternative C. There is no guarantee that an “innovation center” would be developed, and instead we may be faced with another large commercial enterprise (big box) that causes even more impacts. Think about it. Do we really want to open the door to the possibility of an Amazon distribution center in the middle of the critically important Sonoma Valley Wildlife Corridor?

Kathleen Miller, Advocate for Individuals with Developmental Disabilities

kathleenmiller620@yahoo.com

Howard Sapper, Sonoma County Commission on Human Rights member, Executive Director, Everybody Is A Star

bo@everybodystar.org

RE- Housing for IDD (Individuals with Developmental Disabilities) on the former site of Sonoma Developmental Center (SDC): There are a number of key elements community homes for IDD need to include as follows:

1-They are single family homes that must be able to house three to four individuals with adequate room for staff. This most often means a four bedroom home with an additional office space. In the case of those with challenging behaviors this may also need to include a room where an individual experiencing difficulty may go to have quiet away from other residents. 

2-In the case of a home housing those with challenging behaviors, the most likely case due to increasing need in this area, there needs to be an ample fenced backyard where residents can go to spend time outside safely. This was proven to be critical during lockdown recently. In addition, housing in areas where there are opportunities for walking is also very important. For many IDD with challenging behaviors walking is an important part of their day.

3- Parking for multiple cars needs to be part of the picture since at any given time there are multiple staff working in care homes. Most homes also include Vans for transporting residents. There are also frequent visitors including family or outside consultants.

4 -While large single family housing sites may not be the dominant option being created for the SDC site they are an important option for homes for the IDD population.

5- The Sonoma County Board of Supervisors on July 24, 2018, passed a Gold Resolution urging all homeowners, builders, and architects to include at least basic visitability standards in all new housing construction.

Visitability is an inclusive design approach that integrates some accessibility features required under Universal Design principles:

• One no-step entry
• Doors with 32 inches of clear passageway
• At least one accessible half-bathroom on the main floor

Visitability standards are less extensive than Universal Design, but can still enable current and future residents to age-in-place and adjust to temporary or permanent mobility issues, and accommodate visitors with disabilities. 

Ideally:

• Minimum of 40 units of housing for kindly disabled community.
• Job training programs for the cognitively disabled.
• Allocated space for nonprofits serving the disability community
• Return of the historic disability summer camps that took place on STDC campus for many years
• Guarantee of all facilities being ADA compliant including transportation options. Local bus service stopping there as well as para-transit stops.
• Significant honoring of the past use of the property including the mandate from the family that originally gifted the state the property for the use of the disability community.
• Mandated quotas for employment for the disability community and all businesses on the campus including technical training programs to integrate disability community into any high-tech future.

Kate Eagles, Chair, NSVMAC Traffic and Safety Ad Hoc Committee

eagleskate11@gmail.com 

Traffic / Transportation topic includes traffic and transportation impacts and related infrastructure created, implied or required under the alternative plans. Pedestrian crossings, multi-use and bike paths within the SDC footprint are also included in this topic. 

A few points to consider from alternative plans regarding TRAFFIC impacts to Sonoma Valley: 

1. Page 61-63 - No information is provided on trips per household or assumption of people per household. No info on trips from outside SDC to commercial uses in SDC (other than employees). No information on daily truck trips, recreational user trips, hotel guest trips.
2. Page 61 - “Historic traffic volumes generated at the SDC campus during its 1996 employment level of 1,914 employees were also estimated.” NOT RELEVANT – must compare to what’s on the ground now, per CEQA.
3. Page 62 - Peak trips per day (in 1996?) were 3,800 – but what’s not said is that these trips were spread out over 3 shifts. Also, the baseline amounts of vehicle trips in 1996 were much lower than now. Alternative estimated daily trips equal 5400 (A) and 6300-6400 (B and C), but assumptions behind these estimates are not divulged. Page 67 - Too many trips are assumed for non-vehicle travel (18 to 20%).
4. Page 63 – Report admits that traffic would increase by 40% to 70% on Arnold, depending on alternative. THAT IS SIGNIFICANT and even at that, it’s an underestimate.
5. Page 64 - “The segment of SR 12 between Boyes Boulevard and Verano Avenue, however, currently operates poorly in the LOS E range and would be expected to fall to the LOS F range with all three alternatives. This roadway segment passes through the Springs communities, serving as their main street, and has high levels of pedestrian and bicycle activity as well as vehicular movements to and from side streets.” This demonstrates that not only Glen Ellen will be impacted – traffic from this high density in SDC will impact the entire Valley and exacerbate already poor conditions.
6. (LOS = Level of Service, as defined on page 63.) 
7. Page 65 – Traffic through Glen Ellen would drop to LOS D, which is unacceptable according to County operating standards. So, more congestion in village of Glen Ellen. (See LOS chart 4.3-1, page 64.) 

John McCaull,  Sonoma Land Trust: Land Acquisition Director, Planning Advisory Team Member

johnm@sonomalandtrust.org

Nancy Kirwan, Board of Directors, Sonoma Mountain Preservation

nancyeverskirwan@gmail.com

1. It's critically important that any development proposal for the Sonoma Developmental Center (SDC) property protects the wildlife corridor located there.

• The Sonoma Valley Wildlife Corridor (SVWC) is part of the longer Marin Coast to Blue Ridge Critical Linkage, which has been identified in the Bay Area Critical Linkages Project and Conservation Lands Network as a continentally important wildlife linkage.
• SVWC narrows down to a critical “pinch point” in the Sonoma Valley between the Mayacamas and Sonoma Mountain. The narrowest part of that pinch point is precisely located at SDC.
• The most important ecological benefit of the SDC property is to provide habitat connectivity across the SVWC, which has already been impacted by habitat loss and fragmentation due to an increase in vineyard planting and exurban development.
• SDC’s land sustains habitat connectivity for native plant and wildlife species. This is necessary for providing key ecological benefits to humans as well, such as forest health and water resources, and to help moderate the effects of climate change on our region. Habitat fragmentation, often caused by poorly planned development, is the major cause of extinction today and is considered by many scientists to be the largest threat to preserving the world's biodiversity.

2. None of the currently proposed SDC development alternatives describes in any detail how the wildlife corridor will be protected nor do they support the SDC Specific Plan’s guiding principles (see the full list of guiding principles below). 

• Full transparency is needed regarding how the SDC wildlife corridor is being considered and prioritized in the processes of development proposals. For example, it is only now that information concerning a proposed new road through SDC has been made available. This is the first time such a proposal has been raised and is highly problematic given the extremely short planning and approval timeline proposed.
• None of the alternative plans indicate adequate protection of the wildlife corridor. Maintaining habitat connectivity and enhancing wildlife corridors is a cornerstone of California’s State Wildlife Action Plan. Wildlife corridors that offer significant benefits to under-protected ecological communities, and that are found in “areas where substantial development is projected,” are a priority for state and federal land management and wildlife agencies to “protect from development those critical wildlife migration or dispersal corridors that cross ownership boundaries and county jurisdictions.”
• Ultimately, if Sonoma County proceeds as the three Alternatives propose, vastly increased traffic, increased lights, increased noise, increased population will interrupt natural patterns of movement and habitat. 
• Impact of demolition and infrastructure construction on SDC campus will impact the Wildlife Corridor for an extended period of time before any planned development is even built which will take an additional extended period of time. Once interrupted over that long period of time will the wildlife come back years later?
• Interbreeding caused by loss of the Wildlife Corridor through SDC will threaten the survival of already threatened species along the Sonoma Coast west of the SDC pinch point.

3. It’s clear that, this point in time, that public planning processes are inadequate to address today’s challenges. We need to start over and create a new model for how we plan SDC’s future. This can serve as a go-forward model for the County. We seek a new development plan that focuses on the wildlife corridor and meets the vision for creating a community in partnership with that corridor.

• A top priority is to determine the appropriate level of density, and create a building footprint and design standards, that are all based on the best scientific recommendations for wildlife corridor preservation and species movement needs.
• To maintain the functionality of the SVWC, it is critical to exclude from development the area on the north side of the SDC property located by Sonoma Creek. Sonoma Creek is a riparian movement passage area and fish-bearing stream. Development includes more than buildings, it includes such things roads, parking lots, lights, playgrounds and anything that will generate excess noise.
• Science should guide the parameters of where development is located on the property. To that end, Sonoma Land Trust has commissioned a scientific report that will inform the scale, density and footprint appropriate for the SDC property.

4. SDC includes over 750 acres of open space that are legislatively mandated for conservation and permanent protection for public parklands. Any reuse alternatives for the campus must also ensure protection of these natural areas.

• SDC is surrounded by 9,000 acres of parkland and conservation easement-protected properties and is the center of a large greenbelt between Sonoma and Glen Ellen on Highway 12 that creates a natural, open landscape and a buffer against growing development pressures. A 2015 natural resources assessment prepared by Sonoma Land Trust and the Sonoma County Agricultural Preservation and Open Space District concluded that SDC is “integral to the character of the Sonoma Valley, and the ecological health of the North Bay.” 
• SDC covers 950 acres adjacent to the community of Glen Ellen in Sonoma County. To the west, SDC continues up the eastern slope of Sonoma Mountain bordering Jack London State Historic Park. The eastern portion of the property extends through oak woodlands and grasslands to Sonoma Valley Regional Park and Highway 12. The remaining 750 acres of land that is identified for conservation include redwood forests, oak woodlands, grasslands rich in remnant native species, wetlands and lakes, and a lush riparian corridor along Sonoma Creek. The property is home to threatened steelhead, endangered California freshwater shrimp, bald eagles, bobcats, mountain lions, and a suite of other wildlife species. The site is a recreational and scenic resource for community members and visitors, and a place rich in history and ecological value.
• For the health and well-being of the community access to Open Space is crucial. SDC is one of the few free access points to Open Space in Sonoma Valley.
• Maintaining open space helps maintain the Valley’s rich rural character that provides our sense of community
• We need to protect the ridgetops,  hillsides, and waterways that underlie the county’s striking natural beauty.
• Open Space provides connections between urban areas, parks, and natural areas throughout the valley for both people and wildlife.
• Open Space provides a carbon sink by maintaining woodlands and meadows to preserve our air quality and help combat climate change

5. SDC has abundant water resources that are critical to the survival of salmon and steelhead in Sonoma Creek, and that support the ecological health of the entire Sonoma Mountain watershed. 

• There are significant water sources on the SDC property, including springs, wells and creeks supported by an average annual rainfall (at Fern Lake) of 47.03 inches per year. The property has both appropriative and riparian water rights, several of which are grandfathered into modern water rights statutes, and provide ample water for any modest future development of the property. 
• Asbury Creek and Hill Creek that run roughly along the north and south borders of the property respectively, provide water to the property via piped diversions at weir structures. Water is diverted from these creeks into Fern Lake. Additional water from a group of seeps known as Roulette Springs is piped directly to the water treatment plant. Water is also pumped during winter from Sonoma Creek into Suttonfield Lake. Fern Lake and Suttonfield Lake provide 840 acre-feet of combined raw water storage, which is available to be treated for domestic water supply or managed as fire suppression stores. 
• Recommendations for future water management (see 2018 WRT Report) include: 

1. Maintain upland retention and infiltration to reduce erosion and sediment transport;
2. Develop low-impact development (LID) measures within the main campus area for decentralized treatment and infiltration of stormwater; and
3. Wetland restoration and slow infiltration to groundwater in the eastern valley area of the property.

• Increased paving, hardscape and buildings reduces groundwater absorption, which is why wetlands restoration is so crucial.
• Increased paving, hardscape and buildings cause the funneling of water into Sonoma Creek and feeder streams making them run more intensely, eroding banks and digging deeper channels.