community response to specific plan and deir

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Vicki Hill, Environmental Land Use Planner

10/5/22

Dear Planning Commissioners, 

I am a professional environmental land use planner and a member of the SDC Planning Advisory Team.  I have been involved in SDC issues for the past five years.  I submitted comments on the SDC DEIR and proposed Specific Plan on September 26, 2022 (attached). 

At the end of the September 29, 2022 meeting at SDC, the community was asked to identify what we want at SDC. This was surprising, given that Sonoma Valley residents, advisory commissions, and organizations have provided meaningful input on the types of uses and densities that would be appropriate for the site.  The Planning Commission clearly has not had the opportunity to read through all the community comments over the past 4 years that identify what the public wants at SDC.  It is unfortunate that a summary/synthesis of this information has not been conveyed to the Planning Commission. The proposed Specific Plan reflects very little of what the public has requested multiple times.  The public is extremely frustrated and burned out, after participating in countless meetings and workshops. This email briefly summarizes the common land use themes expressed by over 90 percent of the public input over the past several years. 

The question really isn't what the community “wants” – it’s what we desperately "need" to produce a specific plan that meets the state mandate AND at the same time minimizes impacts across the board (that were grossly understated in the DEIR) and preserves the qualities that make SDC, Sonoma Valley, and Sonoma County a desirable place to live and work. The Sonoma Valley community has been very realistic about the property and their requests are not NIMBY wish lists.  The community has not said "no development" or even "low development." The community and local Municipal Advisory Commissions have shown support for a scaled-down alternative plan (similar to the Historic Preservation Alternative) that still represents the largest development in Sonoma Valley in decades.  Public support for a project of this magnitude in a semi-rural location, outside of an urban growth area, is remarkable.

Here is a summary of the community's wants/needs, consistent with the overwhelming majority of public comments and comments from the NSVMAC, Springs MAC, and City of Sonoma: 

• A substantially scaled-down plan, for both residential and commercial uses, similar to the size that is reflected in the Historic Preservation Alternative (450 homes and down-sized commercial area), which is feasible and is identified as the environmentally superior alternative in the DEIR. A scaled down plan is appropriate for this semi-rural location and will reduce adverse impacts in the issue areas of wildfire risk, emergency response, traffic, biological resources, historic resources, land use, visual resources, and GHG. There is no state mandate to maximize profits of the developer and there are valid reasons to believe that bigger is not necessarily more profitable, especially when it comes to commercial uses. As mentioned above, this alternative would still provide the largest housing project in Sonoma Valley in decades. 
• Affordable housing – the community supports much needed affordable housing, at an appropriate scale, despite the fact that affordable housing is better suited in urban areas where there is less wildfire risk and more goods and services available. The community understands the importance of affordable housing.
• A plan that: meets the stated project objectives of balancing development with the existing land uses and historic resource protection;  that benefits the community; that blends in with the surrounding neighborhoods (the site is in the middle of the village of Glen Ellen); and that maintains the semi-rural character of Sonoma Valley, which is important for both residents and visitors. (See Specific Plan page 1-10, Guiding Principles #4 and 7).
• A smaller hotel (or no hotel), again one that is in scale with the site and community and ancillary to the main residential use, not one that belongs in an urban area and generates large volumes of vehicle trips.
• True open space protection, with creation of an open space land use designation tailored for the site that restricts uses to those that are compatible with the critical wildlife corridor and biological resource preservation.
• Limited commercial uses, at an appropriate scale, to serve both new and existing residents, without turning the SDC property into a new city and without damaging the integrity of the adjacent commercial uses in the village of Glen Ellen.  
• Moving away from the proposed plan's "active job center" concept - this job center will generate thousands of extra vehicle trips that are unnecessary to meet the project objectives.  The state legislation does not mandate a job center nor is it appropriate in this semi-rural location, which is not on a transit corridor.  This land use is inconsistent with the County's city-centered growth policies and rural lands policies.
• Consideration of the site's location - please stop trying to justify the size of the plan by unfairly comparing it to the previous SDC institutional use. The residents did not drive cars, there were no commercial uses generating vehicle trips, and employees were spread over three shifts.
• Strengthen proposed plan policies - despite the large number of policies in the proposed plan, there are numerous substantive omissions. Here are some suggested policy additions and modifications (see my attached letter for additional recommendations):
  • Prohibit Big Box Developments – this type of development would significantly impact the site and surrounding area and draw large numbers of vehicles.
  • Prohibit exclusionary fencing within the campus, in order to allow wildlife movement throughout the campus.
  • Establish MANDATORY project phasing programs to ensure that housing development is prioritized over hotel and commercial development.
  • Establish performance standards to guide project phasing and monitor impacts.
  • Require design features to incorporate wildlife corridor permeability.
  • Establish mandatory policies to minimize demolition impacts associated with noise, air toxics, dust, etc. This should include project phasing.
  • Change wording in policies from "should" to "shall" to make them enforceable.
  • Require uses like a hotel, resort, conference center to be subject to a conditional use permit and additional CEQA review.
  • Prohibit development in the open space area.

Regarding the schedule, I urge you to take the time necessary to deliberate and modify the proposed SDC plan. This is probably the largest project proposed in unincorporated Sonoma County and it warrants careful consideration, especially since it is in the middle of a semi-rural community.  State officials have indicated that they will not transfer the property to a developer until late spring or summer 2023. 

Thank you for carefully considering and addressing my comments. 

Regards, 

Vicki Hill, MPA 

Environmental Land Use Planner

SDC Campus Project  sdccampusproject@gmail.com

Brian Oh  Comprehensive Planning Manager  Permit Sonoma  County of Sonoma 2550 Ventura Ave.  Santa Rosa, CA 95403  Brian.Oh@sonoma-county.org

Re: Sonoma Developmental Center Specific Plan and Draft Environmental Impact Report (“DEIR”)

Dear Mr. Oh and County of Sonoma Supervisors,

Thank you for the opportunity to submit further comments on the recently issued Sonoma Developmental Center (SDC) Specific Plan and Program Environmental Impact Report (PEIR). The following comments are submitted on behalf of the SDC Campus Project.

1. Permitted Uses in Preserved Open Space

It has come to our attention that in the Draft Specific Plan, Table 4-3, Permitted Uses, under Preserved Open Space, the following uses are included as P, permitted: 

• Agricultural Crop Production and Cultivation 
• Agricultural Processing 
• Animal Keeping: Confined Farm Animals  Animal Keeping: Farm Animals  Farm Retail Sales 
• Farm Stands  
• Indoor Crop Cultivation  
• Mushroom Farming  
• Nursery, Wholesale 
• Timberland Conversions, Minor 
• Tasting Rooms

In the Draft EIR, Section 3.4.3.4 Impacts:

“Summary of Proposed Plan The Proposed Plan would include residential development in the following districts: Marker Place, Core North Residential, Historic Core, Fire House Commons, Core South Residential, Creek West Residential, Agrihood, and Eldridge North. Approximately 1,000 housing units are planned to be developed throughout these districts as well as commercial, institutional, and public land uses and an Highway 12 connector road. The existing undeveloped portions of the Planning Area would be designated as Preserved Open Space land use. Development is not proposed to occur within Preserved Open Space, where current daytime recreational uses would continue.” (emphasis added)

The DEIR concludes as follows: “3.4-1 Impact. 

Implementation of the Proposed Plan would not have a substantial adverse effect, either directly or through habitat modifications, on species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service. (Less than Significant)” (DEIR p.241)

While residential development is not proposed within Preserved Open Space, the permitted uses identified in Table 4-3, including Agricultural Crop Production and Cultivation and Timberland Conversions, clearly contemplate vineyard development. Vineyard development involves deep soil disturbance, vegetation and tree removal, with likely significant habitat impacts for Special Status Species Yellow Legged Frog and California Giant Salamander, listed as present on SDC land in DEIR Table 3.4-1. The deep ripping of the soil to plant grape vines will be especially harmful to salamanders, who live part of their lives in underground tunnels. 

“Agricultural Processing” likely is meant to permit wineries. This reading is supported by permitting tasting rooms. These uses, in addition to habitat destruction, will also involve construction activities, vehicular traffic. Farm retail sales will generate vehicular traffic. Keeping farm animals raises concerns about impacts on wildlife. The Relevant Policies and Implementing Actions listed in Section 3.3.3.3 of the DEIR, do not adequately address the reasonably foreseeable significant impacts on wildlife likely to result from these permitted uses. Allowing these permitted uses is not consistent with the reasonable understanding by the public of what is meant by protecting the preserved open space.

While the SDC Campus Project supports organic food crop agriculture in a specifically designated approximately five -acre area in the southern end of the east open space, we do not support the permitted activities in the Preserved Open Space listed in Draft Specific Plan Table 4-3. Food agriculture in this limited area will provide a public benefit without significant impacts on biological resources.

Respectfully submitted by,

Jerry Bernhaut

Attorney for the SDC Campus Project

Law Office of Jerry Bernhaut

Email: j3bernhaut@gmail.com

 KATHLEEN FERRIS

Attorney

kathleenferris22@gmail.com

September 26, 2022

Via E-Mail to Brian.Oh@sonoma-county.org

Brian Oh

Comprehensive Planning Manager

Permit Sonoma, County of Sonoma

RE: SONOMA DEVELOPMENT CENTER SPECIFIC PLAN AND DRAFT EIR

Dear Mr. Oh:

I write as a Glen Ellen homeowner and a water policy expert. I served as Executive Director of the Arizona Groundwater Management Study Commission, Director and Chief Counsel of the Arizona Department of Water Resources, and Executive Director of the Arizona Municipal Water Users Association. I am currently a Senior Research Fellow at the Kyl Center for Water Policy at Arizona State University.  

As explained below, the Draft Environmental Impact Report (EIR) for the Sonoma Development Center Specific Plan (Project) inadequately evaluates the potential hydrologic and water supply impacts of the Project. 

The potential impacts on groundwater are not fully examined. 

The Project and Valley of the Moon Water District (VOMWD) are located within the Sonoma Valley Subbasin that is designated under the California Sustainable Groundwater Management Act as a high priority basin because of the density of wells, groundwater reliance and documented impacts of declining groundwater levels. Water users in the Subbasin have already reported wells going dry and many residents are concerned about the long-term sustainability of the Subbasin’s groundwater. As water levels drop and wells dry up, some Sonoma County officials have suggested a moratorium of new well drilling may be needed. Following a ruling by the California Court of Appeals, Sonoma County must now adopt standards for new well permits to ensure that new wells “do not harm resources that belong to everyone, including future generations.”

The Draft EIR acknowledges at page 296 that “there could be a significant impact on groundwater if it were drawn to serve the needs of new residents, visitors, and businesses in a way that would substantially impede with groundwater recharge.” But the potential impacts are dismissed because “future development at SDC would use surface water . . . and not be reliant on groundwater.” Yet the Draft EIR fails to analyze what might happen to those surface water supplies as drought and climate change continue. Additionally, because the Project is not well-defined, it is impossible to know if its development will impede groundwater recharge. Impacts on the fragile Sonoma Creek seem all but ignored.

The Planning Area is insufficient to consider the impacts of the Project.

The Draft EIR limits its evaluation to the 945-acre SDC Specific Plan Planning Area. But water supplies for the Sonoma Valley are inter-related. As the Sonoma County Civil Grand Jury advised in 2020:

“Today there are more water users in the Valley than ever. Valley residents still depend on surface and groundwater resources throughout the Valley. These resources are not sufficient to sustain current population without importing additional water from the Russian River. Water resource planning, development, regulation and use take place primarily in four local organizations: the City of Sonoma, the Valley of the Moon Water District, the Sonoma Developmental Center, and Sonoma Water. These are separate entities, but they all depend on the same limited resources. The actions of each affect all the others.” (Emphasis added)

Estimated water use and impacts on VOMWD are not fully considered.

The projected water use of the Project, 342 acre-feet per year at build-out, seems significantly underestimated for 1,000 dwelling units, 940 employees and 390,000 square feet of commercial, hotel, office, public and institutional space. For example, the Proposed Plan contemplates a population of 2,400 at build-out, with an estimated residential water use of 172 acre-feet per year, which amounts to about 64 gallons per capita per day (GPCD). However, VOMWD had a potable water use of 102 GPCD in 2020 and there is no explanation why the estimated residential per capita water use for the Project would be 38 gallons per capita less than VOMWD’s 2020 GPCD.

Of concern is that the Draft EIR admits that VOMWD will see “shortfalls” in being able to meet future demands within its service area during “single dry years,” which VOMWD will address through its Water Shortage contingency Plan—meaning existing customers will bear the brunt of these shortages. Even under current conditions, VOMWD has already declared a Phase 2 shortage seeking a 20 percent cut in water usage.

Further, the Draft EIR Water Supply Assessment looks at projected water demand only from 2025 through 2045, a mere 20 years. That might be all that the law requires, but it is not an acceptable standard for sustainable large-scale planning in a time of increasing water scarcity. What’s more, the Water Supply Assessment conclusion—that sufficient water is estimated to be available to the VOMWD to meet future demands within its service area and the Project—is based on past water supplies available to VOMWD and several assumptions, including future supply augmentation and increasing state-mandated efficiency and drought requirements. This is not a confidence-building conclusion given the questionable nature of these assumptions and the likelihood that water supplies will be reduced going forward.

The recent drying of the Colorado River has painfully illustrated that it is unwise to base our projections of future water supplies on the past. Climate change, mega-droughts, aridification, and overuse have radically altered the Colorado River, which now is freefalling towards “dead pool” when no water can be released from Lakes Powell and Mead. In the space of less than a year, Colorado River water managers have crossed the divide from “we have this handled” to “our Colorado River water may be cut off completely.” This and other stark realities must alter how we look at managing our finite and threatened water supplies moving forward.

I urge Sonoma County to take the time necessary to conduct an in-depth assessment of how development of the SDC will affect the entire Sonoma Valley’s water resources in the long-term (100 years), considering the impacts of climate change, population increases, groundwater overdraft, and other stresses on our finite and inter-related water supplies. This is a time to be cautious and conservative about the level of development our threatened water supplies can support, as the crisis of the Colorado River has proved to us all.

Thank you for considering my concerns. 

Sincerely,

Kathleen Ferris

1 Draft EIS, Appendix D at 35.

2 https://www.sonomamag.com/as-wells-run-dry-sonoma-valley-reckons-with-new-water-regulations

3 Id.

4 https://permitsonoma.org/sonomacountyproposesrulechangesforwellpermitstoprotecthealthoflocalwaterways

5 http://sonoma.courts.ca.gov/sites/all/assets/pdfs/general-info/grand-jury/2019-2020/FinalConsolidatedGrandJuryReport2019-2020.pdf, at 72-73

6 https://www.vomwd.org/_files/ugd/f7204b_928f2c92199b4ad389bc930ec96ffc95.pdf

7https://www.vomwd.org/_files/ugd/9232b1_c430c3d43be64018962c2846193fce71.pdf

Michael Schiffer

mschiffer48@gmail.com

9/26/2022

Via E-Mail to Brian.Oh@sonoma-county.org

Brian Oh

Comprehensive Planning Manager

Permit Sonoma, County of Sonoma

RE:  MASSIVE SDC DEVELOPMENT WILL INCREASE DANGEROUS TRAFFIC PROBLEMS

Dear Mr. Oh:

As a Glen Ellen homeowner, I am deeply concerned about highway safety dangers that have not been looked at or addressed in the Draft Environmental Impact Report (EIR) for the Sonoma Development Center Specific Plan.  

Clearly, wildfire emergencies could cause traffic backups and bottlenecks on Arnold Drive and Highway 12 that would hinder evacuations and put local residents in peril. While major incidents might be infrequent, even one such event could trigger a nightmare scenario that cannot be dismissed. 

Beyond that, however, over-development of the SDC property would add so many new vehicles to existing traffic on some of our critical local roads that their daily dangers would multiply, triggering even more serious injuries and deaths than are happening now. Yet, in a major oversight, the Draft EIR limits its analysis to the 945-acre SDC Specific Plan Planning Area and does not consider the impacts of the Project on surrounding areas. Unfortunately, the Project is not an island and travel on many local roads not evaluated in the Draft EIS will be dangerously impacted by the Project.

Consider, for example, Warm Springs Road, which intersects with Arnold Drive in Glen Ellen, just one mile from the SDC Project area. I drive on Warm Springs and Bennett Valley Roads from Glen Ellen to Santa Rosa four times a week and have personally witnessed two serious accidents in the past year. 

The first involved an armored truck whose front right tire slipped off a shoulder-less stretch of Bennett Valley Road heading north. Trying to stabilize his heavy vehicle, the professional driver veered hard left into the descending southbound lane -- at a blind curve -- crushing the pickup truck of the elderly man driving it. 

This crash was horrific to witness. With the roadway blocked, many of us got out of our vehicles to offer assistance until the police arrived, and the whole experience was unnerving.

The second accident occurred just this past week, when a sedan lost control speeding down the southbound lane of Bennett Valley Road -- careened hard left across the northbound lane -- and smashed into a hill, backing up traffic as first responders tried to sort things out. 

A few miles north, at the small bridge just before the Bennett Valley Golf Course, a sign indicates how many accidents have occurred there in the past six months (currently 5 and counting), and the numbers in the past few years have been a lot higher.  

Why are these roads so dangerous?

• There are at least 34 blind curves on the 9.7 mile stretch of Warm Springs Road and Bennett Valley Road, heading north from Arnold Drive to the Bennett Valley Golf Course. 
• Southbound cars and trucks speed so recklessly around the last blind curve entering Glen Ellen, it is often terrifying just trying to turn into or out of our driveway.
• Many cyclists use these roads -- solo and in groups, without any bike lanes -- and the combination of bicycles and blind curves is extremely hazardous. Vehicles that slow down behind the cyclists invariably wind up getting tailgated as lines of traffic stack up behind them into the distance.  
• And the double yellow lines down the middle of these narrow twisting roads accomplish nothing, since frustrated drivers eventually ignore them and pass the cyclists anyway, accelerating to reckless speeds as oncoming traffic appears from around the approaching blind curves. 

This is not a rare occurrence. It happens all the time.

• Winding through the beautiful hilly landscape, Bennett Valley Road and Warm Springs Road are already filled with traffic at peak hours and many of the drivers create serious dangers themselves. Some drive extremely slowly and cautiously, while others race far above the posted speed limits in their rush to get to and from work. 

To make matters even more dangerous…

• There are at least 17 speed limit changes along this narrow up-and-down road, and the speed limit changes are posted so erratically and unclearly, drivers often can’t tell what the speed limit is for certain stretches of the road they are on. 

Finally, and perhaps most importantly…

• There are no shoulders along many of the twisting stretches of Bennett Valley Road, with side drop-offs ranging from a few inches -- to 3-5 feet -- so the slightest slip of a tire can pitch a vehicle into a ditch or send it careening across the road into oncoming traffic, as described above. 
• This is not a theoretical or victimless problem. The dangers of driving on these roads -- with 34 blind curves and no shoulders for long stretches -- is so serious, my wife refuses to drive on these routes at all and has to limit her north/south driving to Highway 12.

All these existing dangers are putting people at risk right now. 

But if the proposed 1000 new units are added to the SDC development site, Bennett Valley and Warm Springs Roads will become a nightmare of unsafe traffic. Construction workers and trucks will be speeding to and from Santa Rosa during the construction phase, while future residents and the work force of the over-developed SDC site will add to the daily traffic to and from Santa Rosa, compounding the dangers, in perpetuity.

Simply stated, that is not a good or safe plan. 

We are senior citizens, as are many of our neighbors, and the possibility of even more dangerous traffic conditions on our doorstep is extremely threatening. We love it here but feel as if our personal safety and well-being are in jeopardy and are being ignored.

We understand the mandate to reconceive and modernize the former Sonoma Development Center facility. But over-development will lead to unforeseen, irreversible consequences that will cause immediate harm to those of us who live here now, with negative impacts that will haunt us for the rest of this century.  

Modest development that minimizes the dangers to local communities and residents is essential, if the livability, safety, and character of this corner of Sonoma County is to survive.

Thank you,

Michael Schiffer 

Sharon Church, Glen Ellen Resident

Comments on Draft EIR

GLEN ELLEN, NOT ELDRIDGE.  The area south of the SDC is Glen Ellen, not Eldridge.  Eldridge was the SDC only and they had their own post office.  The SDC and post office are closed.  As such, the SDC property is the donut hole of Glen Ellen and should be considered a part of Glen Ellen, not a new urban area to divide our community.  The development should be in scale that fits the character of the existing community and open space.  The proposed scale is simply too much.

·  EVACUATIONS.  Claims that adding up to 1,000 housing units (2,400 residents) with an estimated 2 vehicles per household plus 940 jobs in the commercial area would not impact our ability to evacuate during the next emergency are irresponsible.  The “models” used defy common sense, ignore the already burdened two lane roads (Highway 12 and Arnold Drive) and are clearly a transparent attempt to move past this life or death matter.  The draft EIR has not sufficiently considered the cumulative impact of development at the SDC, the Highway 12 corridor, and Arnold Drive on our ability to evacuate.  A highway 12 connector would only serve to send people in a futile circle which could make evacuation even worse.  Note that the Elnoka Senior Community project on Highway 12 in Santa Rosa was recently reduced by 60% (from 676 units to 272 units) to address concerns raised by the community and to address potential traffic impacts. 

·  CLIMATE CHANGE.  CalFire is updating the Fire Hazard Severity Zones Maps for the first time since 2007.  The new maps are to be released before the end of the year.  Have these been taken into consideration?  What analysis has been performed on flood risk?  Risk Factor now lists properties near Sonoma Creek as having MAJOR risks of flooding.  Last October, per Sonoma Water, 9” of rain fell on Sonoma Mountain, causing waste water collections systems to overflow in several locations, including all along Sonoma Creek and notably, at Burbank Drive in Glen Ellen.  Climate change is here and affecting us now, with forecasts to get much worse.  This must be addressed!

·  PARKING.  Parking policy 3-27 in the draft Specific Plan says there will be NO free parking within the campus.  What a disaster for the neighborhood to the South!  People will park and store vehicles along Martin, Lorna, Cecelia, Burbank, Sonoma Glen Circle and Marty due to lack of parking spaces and to avoid charges.  In addition, the concept of shared parking between residential and commercial is not realistic in practice.  This is clearly an attempt to burden an existing neighborhood to allow for increased development and profit for the developer.  Unacceptable!