EIR Comments on the Russian River Redevelopment Plan

Submitted: January 12, 2000
Written by: Brenda Adelman for RRWPC

Russian River Watershed Protection Committee (RRWPC) represents approximately 1500 property owners in the lower Russian River area. We have been in existence since 1980. In that time we have developed expertise in water and wastewater issues and other environmental concerns. Many of our supporters are summer home owners who come from all over the Bay Area. I am also a member of the Citizens Advisory Committee for the Redevelopment Project but I do not represent the committee here and my views are not necessarily shared by other committee members.

Identification of the Planning Area as an Urban Corridor

In the description of the nature and purpose of the project, the planning area is identified as urbanized land. The Notice of Completion refers to the planning area as a predominantly urbanized Russian River corridor.

In actuality, as one approaches Rio Nido on River Road the dominant view is of an incredible valley surrounded by rolling lush hillsides thickly coated with redwood trees. While it is true that the ancient virgin forests have been mostly logged, the secondary and tertiary growth we now see is quite lush indeed. Much of the so called urban development is in well hidden valleys and canyons that remind one of a rain forest. Many of these hideaways cannot even be imagined from the main road, let alone seen.

If one were to walk on almost any residential street in the redevelopment area, the predominant features are not urban concrete forms but rather hills, trees and often dense vegetation with very little concrete evident. Abundant wildlife resides in our hills. Deer, opossums and raccoons are frequently seen in yards and on decks. Most driveways, where they even exist are usually gravel or dirt rather than cement. The streets are often narrow, curvy, and hilly and in some places two vehicles can barely pass one another. Vacationers and full time residents enjoy wandering the streets of our canyons on lazy summer days and evenings. Except for the downtown business area, there are no curbs or sidewalks and the streets are often ill defined. In the winter our streets run like rivers with as much as two inches of water hiding the concrete beneath. The 1990 Census of Population and Housing characterizes our area as nonfarm rural.

And that is how we want it to stay. References to irregular and inadequate street patterns (Preliminary Report, p. I-8) seem to imply that the possible intention of this plan is to widen, straighten and urbanize our streets. What assurances do we have that this is not the case? Furthermore, the environment is noted as being damaged, and while this may be true in some specific instances, our area is in far better environmental shape than the urbanized communities further east along the Highway 101 corridor. Does the term damaged here refer to irregular and uneven?

The consultants provide a definition of a Predominantly Urbanized Area that might possibly meet the strict legal requirements for a Redevelopment Area but they have ignored the spirit and ambiance of our place which is in few ways urban at all. (See page II-2 of the Preliminary Report.) Some of the conditions they call blighted, many residents see as rural, similar to old barns providing atmosphere and charm to rural scenes.

They also state, "The Russian River corridor, including the river and adjoining redwood forests, has provided the setting for extensive recreational uses, including beaches, resorts, second homes, and visitor-serving commercial development." (Page 4-1) The natural environment of the study area should not be viewed as a setting for the community rather than what it is, a geographical and ecological wonderland that also happens to contain human habitation and recreation. In fact, the very delineation of the Planning Area itself artifically separates the community from its fragile environment which is then portrayed more or less as a backdrop for a so called urbanized area. Protect the rural environment.....

The EIR states that this is a recreational area whose natural features should be preserved, but the definition of precisely what should be preserved is ill defined as most of the surrounding natural area is not included in the plan. This does not mean however, that the project won't have an impact on the surrounding area. The natural environment is after all interconnected, as is the level of human activity. The danger of identifying our area as urban tends to diminish the importance of the trees, the hillsides, the wildlife, and the streams to that of only secondary importance. It also limits the amount of care given to their protection.

It is concern for retaining these rural values that leaves some of us wary about the vague and generalized plan for redeveloping our area. In fact, the precise project is rather amorphous. In the beginning of the redevelopment process, as well as in the appendices of this document, there was an emphasis on residential blight serving as justification for the project. Yet why did the consultants predetermine that funding allocations would allow only 20% for housing rehabilitation when 20% is actually the legal minimum? Most of the remaining funds would be allocated to visitor and tourist serving opportunities. Who ultimately determines the precise amount to be used by any category? What was the basis for this initial proposed allocation?

I want to note here that the CAC was asked to rank predetermined categories of expenditures. The 20% for housing was a given fact and not a choice. I have no problem with developing a program that will help people rehabilitate their homes or businesses. I have real problems with a development proposal that will help make a few people rich and leave the rest of us suffering from the long range consequences of this action. Who will benefit directly from this project? That is, who will qualify for the available funding? I am greatly concerned that the way this proposal is framed, the latter will be the case. Along these lines, I wonder why this document quotes the General Plan almost exclusively and none of the administrative regulatory documents that protect the environment of our area? Is this project simply being defined by what the General Plan will allow at total buildout? Why even bother with this EIR? Why not use the EIR for the General Plan? Also, why was the General Plan EIR never mentioned?

This document fails to give credit to the vast amount of rehabilitation that is already occurring. The consultants, themselves from an urban area, used extremely subjective criteria for evaluating the degree of blight. In many cases they have cast negative value judgments on the simple, more natural life some residents have consciously chosen. They also failed to acknowledge that with Sonoma County's rising housing prices and decreased availability more and more people are investing in our affordable area and private rehabilitation is very much on the rise.

The Citizens Advisory Committee for this project voted unanimously to request that the Board of Supervisors retain a citizens committee to oversee the implementation of this plan. It is difficult to foresee all of the issues that will arise as a result of this project. Can this document recommend the establishment of a permanent citizen's advisory committee?

Demographic analysis....

The demographic data for the no project alternative indicates current population at 9206. That will grow to 11,445 with the project. (p. 18-7) Does this represent the winter or summer populations? If it is winter, please give summer numbers and visa versa. Please explain which set of numbers formed the basis for environmental review (summer or winter) purposes. If the impacts were based on winter numbers, what are all the various environmental impacts with the significantly increased summer population?

We thought it would be appropriate to analyze population from another source and ran across the 1990 Census for the Russian River County Sanitation District (RRCSD) which comprises approximately 60% of the redevelopment project area listed population at 4358 and number of households at 1907. Probably about 25% of these are not included in the redevelopment study area. So we start with 3270 people living in 1430 housing units and add on 40% to account for nonRRCSD areas in the project area.

If these assumptions are correct, then the 1990 population in the study area was about 4580 and the households numbered about 2000. According to the EIR there are currently 9206 people in the entire study living in 3836 housing units. If all numbers are correct, this comes out to about a 100% increase in populations and households in the last ten years without the project. Based on the analysis in the EIR, population would grow by 953 people in 20 years without the project and 2239 with the project. How can we trust the projections on pages 18-4 and 18-7? Please explain the discrepancies. (I have included a copy of the demographic study I used.)

Page 5-6 indicates that the projections in this report are the worse case. If the actual numbers we presented from the 1990 Census are correct, the numbers you have presented may be far from the worse case. If your estimates are way off, how does this affect your analysis of environmental impacts? Furthermore, the plan assumes that there has been a trend toward full time habitation of housing units. What data can be provided to show the extent of this change? How might the extent of the change (ie. differences between summer and winter populations) affect the environmental impacts addressed in this document? For example, water consumption and wastewater discharge have already become major issues of an increased population.

Assurance of affordable housing....

Besides the incredibly beautiful Russian River environment, the most attractive draw for low income working people is the amount of affordable housing in the study area. This is in the context of location in a County where housing costs have escalated through the roof in the last 20 years. How will this project assure the continued affordability of this area? How will the guarantee (page 3-15) that, "...prohibits any redevelopment action that would displace a substantial number of low-income persons or moderate income persons." be implemented? What programs and policies will assure this indeed happens?
Will developers be able to apply for funds to upgrade housing and turn around and make a pretty profit? What mechanisms will be in place to assure that the vast majority of the housing funds won't price out the low income working people who are currently living there? Can some of these housing funds be used to construct brand new housing? What percentage can be used for new projects? Is there any limit on use of funds for new housing? How can housing blight be effectively eliminated if there are no funding standards? How will use of funds on new development improve blight?

What jobs will become available as a result of the economic development aspects of this plan? Are the new jobs capable of raising the living standard of the people in the community? What percentage of the jobs will be under $10 an hour? Will the rehabilitated housing stock be priced in an affordable range for those taking the new jobs? How do you define affordable housing? How do current incomes in our area rate on the income scale? What percent are low, very low, etc.? Will the housing be affordable commiserate with the pay scale of the new jobs being made available? What mechanisms will be in place to allow low income working people and single moms access to low interest loans to fix up their houses?

No meaningful assurances have been provided to guarantee that economic opportunities will be balanced equitably between those serving local residents with those serving the tourist economy. Already the locals have to put up with unbearable traffic problems during many summer weekends and this EIR assures us that in some areas things will get worse. General Plan Obj. LU-13.3 is quoted on page 4-12 as an assurance to maintain a balance between tourist serving and local serving businesses but we have no clue as to how it will be implemented to achieve its goal. What proportion of the new funds available will serve current year round residents? What type of new businesses are envisioned that could benefit current residents? How is this assured? Can the rezoning of the Monte Rio Theater property cause us to lose our one local movie theater?

This EIR may supplant future environmental studies....

The California Environmental Quality Act (CEQA) states that "An EIR on a redevelopment plan shall be treated as a program EIR with no subsequent EIRs required for individual components of the redevelopment plan unless a subsequent EIR or supplement to an EIR would be required by Section 15162 or 15163." In response to my concern that a specific project in a redevelopment area might avoid CEQA analysis, the consultants respond, ".....Sections 15162 and 15163....provides adequate assurance that any significant adverse environmental impacts associated with a future individual "component" of the redevelopment program (i.e., any discretionary action facilitated by the redevelopment program) will be identified and addressed through the County's environmental review process." We submit here for the record the letter sent to us by Wagstaff and Associates.

This brings us to a sticking point with this EIR process. We are nervous about the actual implementation of the redevelopment program in regards to environmental review. (Please explain the statement in Appendix 21.1 "Four, the redevelopment activities would be comprised of various individual activities carried out under the statutory authority of the Sonoma County Community Development Commission that would generally have similar environmental effects that could be mitigated in similar ways.") Please help us understand. For example, there is a potential for 1100 new motel units being built in the next 20 years with the project as opposed to 115 units in that time period without the project. The cumulative environmental impacts of the difference between those two circumstances can be potentially considerable. Will individual projects be required to conduct expensive cumulative review of the entire redevelopment area? Is the current program EIR seen as adequate, when certified, for this circumstance? Precisely what kicks in environmental review process?

It is not clear to us how the determination to require further CEQA review would function in reality. On page 1-5 it is stated that current environmental conditions serve as the baseline. How and where are those current conditions described? Do any inventories exist that define existing conditions? What can guarantee that County agencies provide adequate review when, in our experience, some agencies commonly rely on outdated information.
Because of that experience and because of our need to file lawsuits to prevent CEQA abuse that we question the role of future environmental analyses for specific projects. What happens if further CEQA documentation is not required once this project is implemented? Who will study the cumulative specific impacts of the combination of all projects if new requirements are placed on this area by the Endangered Species Act and other new regulations?
Will the Community Development Department be the lead agency for environmental review of all redevelopment projects? Does staff have the expertise to do this work? Does staff have the time to do this work? Will you have to farm it out? To what extent will the inconvenience of environmental review give rise to decisions that determine no environmental effect? Why is there so little mention of State and Federal Water Law and the Endangered Species Act in this document while the Sonoma County General Plan is cited extensively?

We are especially concerned about the possibility that no further traffic impacts will be analyzed for the Dubrava project. Would any new traffic studies be required of the 150 unit Dubrava hotel, should it move forward? We do not believe that this EIR's traffic analysis should in any way be viewed as complete. For one, traffic patterns during major events were not considered. (See section on Traffic starting on Page 9 of this document.) The Dubrava project will be built in an area with the most serious traffic problems and the proposed mitigations do not appear to offer much relief. This EIR should in no way be allowed to substitute for a serious analysis of the impact of adding 150 new hotel rooms in that area. Furthermore, we are concerned that this document asks us to accept a Level E traffic situation there. The truth is, there may be no effective mitigations for that problem. Rather than tell the community we have to live with a further degraded condition, perhaps the project should not be allowed because the impact is too great. Is that a consideration?

Should any new projects want to cut more than a few major trees, would that trigger additional environmental review? Will projects within 300 yards of a federally protected river or stream have to provide additional environmental studies and mitigations? In other words, how and when is it decided that additional environmental review is necessary? What will be the criteria to determine it that will happen? Will the public be informed? What public process will be available to initiate environmental review or to challenge a decision made not to require it?
Another issue to be addressed is the public process in regard to the six General Plan Amendments proposed with this project. Citizens were told at the Planning Commission Public Hearing that their comments about possible future project impacts were inappropriate. We do not understand why. Please explain. What would be appropriate in a hearing about a rezoning if specific potential impacts (such as increased traffic) are not allowed? It seems as though the increased intensity of use coming from a General Plan amendment would be very appropriate indeed.
Citizens attending the Planning Commission hearing were told they could only address the EIR even though the General Plan Amendment was also being considered. Under the circumstances, since some people were limited and inhibited from speaking to the Amendments, shouldn't the Planning Commission Hearing be renoticed? Shouldn't the date for comments be extended? Shouldn't there be some clarity about what comments are acceptable and which not?

Land use issues...

What kind of monitoring plan is in place to assure that General Plan requirements are adhered to?

On Page 4-11 under landscape units, redwood groves and the river are mentioned but there is no mention of our very distinguishing steep hillsides. Why not?
The as yet unauthorized Monte Rio EIR calls for a land use overlay that would limit housing development to ten units a year in proposed wastewater district. Is it possible to apply more restrictive limits on development than occurs in the General Plan? If so, how would this proposal, if approved, affect redevelopment in the Monte Rio Area? Would adoption of such a limitation be consistent with the General Plan?

This plan calls for 254 new units in Monte Rio. If the sewer guideline is implemented, only 200 would be allowed. How would this change affect the validity and consistency of this document?

On page 4-13 Policy LU-9a calls for established maximum densities in scenic landscape units and scenic corridors. What are the maximum densities in the study area generally? Does the estimated growth projections factor in this density limitation?

On page 4-13 Policy OS-2e calls for screening new structures in the scenic corridor. Several new buildings have gone up since that policy was put in place that have no screening. How can we be assured that future new structures will be screened? Also, can the same requirement be made for major rehabilitation work? Does this policy apply to both residential and commercial structures?

What is meant by the phrase at top of page 4-17, "....would reverse current land underutilization trends and stimulate cohesive patterns of future development and visual improvement within the Project Area." Which areas are underutilized? What is meant by a cohesive pattern?

Please consider adding the following to Suggested Additional Requirements on Page 4-30: A ten member citizens advisory committee will be established to periodically review and advise on new projects and implementation measures of the District.

Population, Housing and Employment....

Please see Demographic Analysis on Page 3 of this document. The Russian River Area has a very large share of the affordable housing in Sonoma County. As the Santa Rosa market tightens more each year and prices go through the roof, more and more working people are looking to our area for affordable housing.

Because of this, the analysis on page 5-3 and 5-4 regarding required percentages for affordable housing requirements is very misleading for this redevelopment project. On page 3-2 under Redevelopment Plan Objectives it is stated that, "....improve substandard housing conditions, and provide an increased supply of affordable housing through new construction or rehabilitation."

Could you please describe how the increase in affordable housing will occur. What is the range of values of the current housing stock? What are the values of the housing most likely to be rehabilitated? How will you make low cost housing stock remain affordable after spending money on rehabilitation? How will you assure that low income people get access to low cost housing? How will you assure that a large segment of low income people are not displaced by this project as guaranteed by this plan? What programs and policies are in place to assure that this will not happen?

It is hard to imagine that the cost of housing would remain as affordable as it is now. This would be a major impact on many low income people living here now. How will the community deal with that? Also, how will rents be affected in rehabilitated housing? Can you give some examples of housing recently rehabilitated in our area and the differences in rent charged before and after? Can you give the range of affordable housing costs currently and estimate what they will become after rehabilitation? What kind of new low cost rental housing will bebuilt in our area as a result of this project? How do you define affordable? How does this compare to actual charges?

On page 5-4 it is stated that the average household is 2.4 people. How do you explain that school attendance is going down and there seems to be a decrease in young families in our area? It is stated that Russian River area population is 1.8% of the county population. How many people per acre does that come to as compared to other urban areas? It would be interesting to have a qualification of the term urban.

In regards to the jobs/housing balance, please indicate the income levels of jobs to become available by this project. Will the cost of the housing be affordable to those likely to obtain those jobs? Would people currently employed in Santa Rosa but living in affordable Rio Nido and Guerneville be likely to quit their jobs and work in this area? Please provide a demographic analysis in answering these questions. Even apart from this discrepancy, the jobs/housing balance after this project will only go from .57 to .61 (Page 5-5). Seeing this is the prime motivation for this project, the projected results are far from spectacular! Please explain how phasing might assure a better balance between jobs and population. (page 5-5)

Have you considered a worst case analysis that assumes that all new residents work somewhere else and all new jobs are filled by people living elsewhere? What would be the impacts, especially on traffic, with such a scenario?

Transportation, parking, and traffic.....

Traffic is one of the major impacts on current conditions by any new development. One of the major questions that comes to mind is whether additional traffic created by new developments will have to be addressed in future environmental analyses? Or, will this document suffice in its level of detail in most instances? How will the determination on the need for future analyses be made?

In regard to peak volumes, two times have been identified in this document as the worse; 4:00-5:00 pm Fridays and 1:00-2:00 pm on Sundays. While I can agree with the first time, my own personal experience has found traffic far worse between 11:00-12:00 pm on Saturday (heading west from Rio Nido) and 4:00-5:00 pm on Sundays (heading east from Monte Rio). The only Saturday counts were taken on June 6, 1999. Between about 10 am and 1 pm on that date there was a parade down Guerneville's Main Street (Hwy 116) and the street was closed. How does this affect your traffic analysis? The street was closed during the period of heaviest Saturday traffic.

In addition, usually at 2:00 pm on Sunday afternoons in the summertime, people are still recreating and town is pretty quiet. It's unclear how that could have provided the highest count. It would have been much better if several weekend counts had been taken. By the way, I've lived in Guerneville since 1975 and have had a little experience with traffic in that time.

It is unfortunate that the counts were based on five days only, hardly a scientific sampling and totally inadequate for developing conclusions. Furthermore, traffic gets much worse when summer vacations begin in July and August. This study refers to these early June counts (before many schools are out and family vacations begun) as happening during peak tourist conditions. While June is a busy month, it should not be termed the peak tourist season. Downtown Guerneville has always had a severe parking problem, so much so that for a long time new business were prohibited from opening until the problem was resolved. While not as severe as it was, parking is still a problem. Please analyze the Guerneville parking situation and its impacts on traffic. Also, it would be helpful to recommend specific solutions to the downtown parking problem such as recommended locations to develop more parking and other possible solutions (such as frequent jitney service).

It should be noted that projections for project traffic impacts are estimates only, based on the inadequate June, 1999, traffic counts. Further, only the questionable peak times of late Friday and mid-Sunday are analyzed. What would traffic flows be like in late August? Does this document assume all weekends are alike? Were any local residents or the local Chamber of Commerce consulted to verify traffic flows?

Has there been any study on what proportion of the traffic going through Guerneville stops in Guerneville? I have heard Guerneville merchants complain that a large number of cars are simply heading out to the ocean and don't even stop in Guerneville. This document seems to be saying that heavy traffic will encourage people to go into local businesses. (Page 6-15 states, "However, based upon the expected high traffic levels associated with the magnitude of new restaurant/retail uses, these activities would become their own attractive destination for regional tourist traffic." Please interpret this statement. Is it sheer conjecture? What is it based on?)

Remove Highway 116 widening in Monte Cristo as mitigation....

The most alarming mitigation in this document and one in which the Citizens Advisory Committee voted unanimously would create far more environmental problems than it would solve is the widening of Highway 116 in Monte Cristo, about 1/2 mile west of Monte Rio. It is our opinion that the mitigation would not even help traffic flow in Monte Rio anyway. We ask that this mitigation be removed from the EIR. This is a highly sensitive area which is considered a treasure by people in our area; it must not be altered. Please remove this mitigation from this plan.

This is a prime example, and others are recommended in this document, of urbanization measures being recommended to replace features that give our area charm and desirability as a tourist destination. Widening and straightening roads may appear in the General Plan as a mitigation for traffic impacts but that would not only decrease the appeal of our rural area, but in some cases would help to increase dangerous speed where things should be slowed down.

What are the various impacts on year round residents by an increase in summer traffic flows provided by this project? Page 6-14 states, "Local residents would have proportionately more local employment, shopping and services opportunities than currently exists. The resultant net increase in local residential traffic traveling to/from external to the Project Area would be less than the percentage increase in residential development."

Please explain this statement. Has there been any consideration about the widespread nature of the residential community in relation to the downtown area and the need to travel across one of the bridges? I do not currently even go into Guerneville from Rio Nido during peak traffic times on summer weekends. Many local residents I know consider it easier to go to Forestville or Sebastopol to shop than Guerneville. I'm having difficulty with the fact that the consultants do not know our area and apparently have not talked to local people about the reality of our traffic situation. One friend took thirty minutes in the summertime to go four miles because he had to cross the Guerneville bridge during a peak traffic time (Is that LOS F?). This is not unusual but has not been discussed in this document.

Providing 8 foot paved shoulders on the Rio Nido strip on River Road east of Guerneville to alleviate traffic stagnation is not going to help much. How would this improve traffic to so-called acceptable LOS D levels? (I do not accept LOS D.) Are the shoulders to serve as lanes? for parking? The strip is fairly wide already except in Rio Nido where an east bound left turn lane is desperately needed. Traffic is backed up to the east of the bridge on the Rio Nido strip (sometimes almost as much as a mile) because of the traffic lights in Guerneville. The bottleneck occurs just between the two signals where the steep hillside comes down to the road and there is probably not enough room for the proposed widening. Mitigation is probably impossible here. (Did the authors of this segment make any visits to the area or talk to any local people about traffic problems?)

How do 8 foot shoulders affect traffic flow in Impact T-1, especially LOS impacts on Hwy 116? How do shoulders cause Fri. LOS levels to be reduced from significant operation impact to less than significant for Hwy 116 with Mitigation T-1? Then right after that mitigation, it states that 8 foot shoulders would not improve operations.
Please explain.

We have grave concern that this limited traffic analysis be deemed sufficient for the 150 unit motel being planned for the Dubrava site. Please comment on whether this analysis is fully adequate for that project. What additional information would be necessary?

In general, this analysis has not given me a clear picture of the difference between traffic impacts with and without the project. As mentioned earlier, because of the limited validity of the data used we question most of the conclusions in this section.

Drainage and Water Quality.....

On Page 7-2 it is mentioned that Warm Springs Dam has reduced peak flood levels. It has been widely acknowledged that increased development in the Santa Rosa plain, along with Sonoma County Water Agency management of the Laguna and other tributaries as storm drain channels has caused a vast amount of both increased flows and much faster drainage from that new development. What are the flooding impacts on the study area of both recent and anticipated increased development in the Santa Rosa Plain (ie., Santa Rosa, Rohnert Park, Windsor, Cotati, etc.)? How do you define impervious surfaces? How do you quantify them? How was the 930 acres arrived at?

The top of page 7-3 alludes to the General Plan's allegation that septic system failures have degraded water quality in the Russian River and specifically refers to the lower part of the study area as problematic. We have written extensive comments on this section in our reply to the Monte Rio EIR which will be released in final form in mid March. We cite the Monte Rio EIR as reference and include here applicable sections from our reply. The following is lifted directly from our comments on the EIR. We believe they are pertinent to this redevelopment project.

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Problems with Water Quality Analysis and Need for Project.....

While we believe that some septics fail some of the time, and we are not trying to stop a project here, nevertheless the water quality analysis is in much need of improvement. Most of the failing septic claims are conjecture and remain to be documented. Justifications are technology-based and, in most cases, not ascertained from direct experience. While we agree that parcels immediately adjacent to the river give cause for concern, these parcels represent a minor percentage of the project. You appear to overly rely on the statements of others but don't present much data to back it up.

Lack of monitoring data is a principal weakness of this document; no allocations of pollution can be made with absolute authority. There are so many upstream sources of contamination in the river that it would be almost impossible to separate out Monte Rio's contribution based on current data available. Furthermore, there are seeming contradictions in this EIR regarding water quality and the impact of failing septics on our environment.

The following statement occurs on page 84: "For most water quality parameters, there has been a general improvement in the Russian River since the early 1970's to the present." This is followed by, "Bacteriological monitoring over many years....have shown fecal coliform levels that continually approach or exceed established and recommended limits for water contact recreation...The highest sampling results...are from the mid-1970's, before sewers were installed in Guerneville. However, sampling of the River during the recreation season in the 1990's continues to indicate bacteriological levels of concern."

RRWPC has studied the coliform data from 1991-94. We have concluded that the data is regularly erratic at all beaches. Monte Rio beach had two >2400 readings in 1992 and three readings at 1100. In 1993 and 1994 the high readings were expressed as >230 (which could be ANY number greater than 230, including >2400) There were three >230 readings in 1993 and five in 1994 (with missing data for five weeks). This hardly represents a trend of improvement. (data included) We wonder if bacteria left in the sediments from upstream sources might be stirred up at various times and cause the higher readings? What is the possible contribution to this problem by Santa Rosa's wastewater discharges and the agricultural community?

Furthermore, if this were considered a serious problem, why hasn't Dept. of Health Services or County Health Dept. ever closed the beaches after a high reading? At a minimum, why have they not immediate retested upstream and downstream of a high reading monitoring point to try and determine where the pollutant was coming from and address the problem then and there? Either there is not a serious problem OR health officials have acted irresponsibly. Which is it?

Data presented by the consultant indicates similar inconsistencies. (page 84) The authors conclude: "The high coliform readings have not been traced to septic systems in Monte Rio; however, they are a possible source. Within the Monte Rio study area there has been evidence from time to time of ponded or surfacing sewage effluent in local drainage ditches; but no comprehensive water quality sampling effort has been completed to document and quantify the water quality effects."

This lack of data reduces the credibility of the basis for this project. If there were a serious health problem all of these years then the County should be culpable for not studying and identifying the problem much earlier. In fact, if public health problems were rampant, we are sure there would have been a community outrage! A few instances of ponding during high river flows do not necessarily justify a major pipeline solution, especially since all major Sonoma County systems fail during flood periods. RRCSD isn't alone; Santa Rosa, Healdsburg, and Windsor and others have all had system break downs during high water periods.

In addition, if we look at the total coliform readings at Casini Beach, about a mile downstream, we see inconsistencies in the trend (There really is NO trend for coliform in this data.) It would seem logical that readings should be higher downstream if Monte Rio septics were polluting the river. Over the course of the four years (1991-94), readings were higher downstream on ten occasions, lower downstream on eighteen occasions (sometimes MUCH lower), the same on ten occasions and inadequate data for comparison on four occasions.

A similarly contradicting statement can be found on page 85 regarding nutrients. "Monitoring has shown that nutrient concentrations in the River have decreased with time, but they continue to show a pronounced increase from upstream to downstream monitoring locations." According to the document, this is based on data taken at the Hacienda Bridge, at least ten miles upstream of Monte Rio. What conclusions can be based on this data for Monte Rio? Could this increase represent a cumulative effect from ALL upstream discharges, especially Santa Rosa's 20 million gallon a day average discharge?

On page 109 the statement is made, "....monitoring data collected by the RWQCB do not indicate any substantial changes in nitrate concentrations in the Lower Russian River, and any flow variations are not likely to change the result to any significant degree." If this is true, wouldn't it indicate that so-called failing septics are not causing a problem in the lower river? Yet the next paragraph states, "...the existing systems clearly are a source of nitrate addition to the groundwater and River." Now which is it? Are the septics causing a nitrate problem, or not?

We also question where the data indicating these trends were taken. We believe the trend was identified by USGS through testing the main stream flow. Yet other nutrient samples may have been taken near the banks in stagnant water where degradation is more likely to occur. The circumstances of collection of most of the available data is generally not noted and the question of monitoring consistency could be a valid one.

What conclusions can be fairly drawn for Monte Rio from the information presented in these pages? How does this information indicate whether or not and to what extent Monte Rio septics contribute to nutrient pollution in the river? After stating that nutrient readings are higher in the lower river (p.85), the document then states, "However, to date there have been no studies completed to document the influence of septic systems on the nutrient levels in the Lower Russian River, nor are there known to be widespread nuisance algae problems." How can we determine whether any of the proposed projects will improve pollution in the river if we really don't know what we are starting with?

In discussing dissolved oxygen compliance, the EIR again alludes to the Hacienda Bridge data. We wonder why none of RRCSD's monitoring data was examined? This location is only about a mile upstream of Monte Rio rather than nine miles (page 109 states the distance from Hacienda to Monte Rio is 5 miles but I believe is 8 or 9 miles.). Also no mention was made of data taken in the Estuary Study a few years back. All of this data (or at least meaningful samples of it) should be reproduced in this document. Why wasn't it? Will you add it?

The author's allude to the North Coast Regional Water Quality Control Board (Regional Board) looking at lowering the Dissolved Oxygen (DO) median lower limit objective. Rather than lowering the standard, why shouldn't this be listed as an impairment under 303(d), especially in light of the endangered species listing for salmon and steelhead, and a tmdl (total daily maximum load) developed? Isn't this potential change fall in the realm of speculation? What is this statement based on? The document alludes to high temperatures in the river but data is not cited. Is it true that a Section 303(d) listing for temperature in the Russian River might be established? On what data is the conclusion based that low DO is a factor of higher temperatures in the lower river? Does the term lower river include the estuary which probably has cooler water temperatures? What other factors contribute to a low DO reading? In fact, what is the status of DO in the Russian River?

Why is there no data presented on temperature, turbidity, and pH? We know the Regional Board has studied these parameters from time to time in the lower river. Also the Estuary Study looked at several of these perimeters. Further, Santa Rosa regularly takes readings at Burke's Beach, only a few miles upstream from Hacienda. If Hacienda is a valid point of study, surely Burke's can be just as useful. We just don't know what the data at Hacienda indicates for Monte Rio. Please explain.

Status of Monte Rio Septic Systems.....

Statement is made on page 87, "Systems which have been installed recently do not meet current code. Most are believed to consist of cesspools, seepage pits or other substandard septic tank-leachfield systems." Is this a mistake? Why would new systems have problems and not meet code?

On page 88, the EIR discusses problems with septics during flood periods. Why is there no mention that the RRCSD breaks down regularly not only during times of heavy river flow, but during periods of heavy rain as well? In February, 1998, there were thirty days of violations at the plant, but only one or two days of flooding all month. We will address the expansion as a separate topic, but it is already admitted that with this option, Monte Rio would have to take its effluent somewhere else during high flow periods. What is not clear are the scenarios under which that would occur. Please review the conditions of Feb.,1998, and explain in detail what Monte Rio would do in those circumstances if they were hooked up to RRCSD.

There are many requirements for siting septic systems. Are the number and size of redwood trees in proximity to the system ever taken into account? What is known about the amount of water taken up by a redwood tree next to a septic system? Could it be that many supposedly substandard systems are actually functioning properly because the local trees take up most of the water?

There is concern expressed, on page 103, that nitrates from the septics will move quickly into the groundwater and then into the Russian River. What evidence do you have that this is happening? To what degree is it happening? The statement is made on page 109 that, "....since monitoring data collected by the RWQCB do not indicate any substantial changes in nitrate concentrations in the Lower Russian River..."Can you quantify the extent to which redwood and other large trees prevent this from happening? Many of the statements in the EIR are conjecture about what is happening and are not connected to the reality of our local environment. At a minimum, can you please look at data taken at the RRCSD and at Duncans Mills or the Estuary to examine whether conclusions can be drawn as to its quality?

Again in regard to nitrates on page 109 it says, "Based on monitoring at the RRCSD irrigation site on the Silver Property....groundwater flow increases in the winter months and also carries a higher percentage of the nitrate that accumulates in the soil during the summer irrigation-disposal period." The City of Santa Rosa irrigates almost 6000 acres (about one billion gallons a year) near the Laguna de Santa Rosa, also the stream into which they discharge millions of gallons of wastewater daily in the winter time. This waterway is severely impaired (and on the 303(d) list) with nutrients. Also the river backs into the Laguna at flood time and even backs into the City's Delta Pond. To what extent is Santa Rosa's operation affecting nutrients in the lower river? How far can nutrients travel? In other words, is it possible for Santa Rosa to be blaming Monte Rio for a river condition that they are causing themselves?

The statement is made on page 103 that, "Sewage discharges may also increase the potential for introducing xenobiotic estrogens into the River." While it is true that household waste may create some risk for this problem, nevertheless, the chlorinated discharges from the RRCSD, especially during high waters when dechlorination does not always properly occur, is a far more likely source of this pollution. In fact chloroform has been elevated in some samples. Please explain what you mean by this statement and also, in the appropriate section, explain the level of risk present through a hookup to RRCSD. In other words, what are the relative risks in direct river discharge by RRCSD as compared to septics?

We are not trying to say Monte Rio's problem, if there is one, should not be addressed. We believe that the true scale of the problem should be identified and appropriate local solutions found. We want to avoid a one size fits all mentality (ie, centralized sewer systems that regularly fail during wet weather).

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These comments above partly serve to challenge the statement (page 7-3) that, "...the lower reaches of the Project Area are still on septic systems, most of which are adversely affecting local surface and groundwater quality." As we point out, this statement is simply unproved. While many septics are not up to current standards, there is virtually no monitoring data to prove there is an ongoing pollution problem from septics in the lower Russian River. I might add that a friend of mine who has a Ph.D. in limnology has a house on the Russian River in Duncans Mills. He has reported that the river there has been crystal clear and much, much cleaner than the river in the Forestville area, downstream of the Mark West Creek confluence.

Furthermore, it can probably be demonstrated that most of the water quality problems are coming from upstream practices except when the Russian River County Sanitation District, credited with solving water quality problems in our area by your document, has one of their regular spills and/or permit violations. This whole section on water quality says almost nothing about water quality. What about nutrients, temperature, bacteria counts, pH, phosphorus, turbidity, parasites, toxic pollution, etc.? Where is the data describing current conditions? How can you assess and address future impacts if you have not presented any baseline information?

The list of General Plan objectives and goals sound good but they are not mandatory. How will they be protective of water quality if they do not have the force of regulation behind them? Also, can you provide a copy of newly approved County Ordinance #5167 in the final EIR? Seeing as the RRCSD violates its permit regularly, how can this redevelopment project be implemented before the ongoing problems are solved? (We will go into more detail on this in the section on infrastructure.)

EIR does not address use of toxic building materials in the floodplain....

There is one issue we want to raise here that goes entirely unaddressed in the EIR. FEMA projects require the use of pressure treated woods on all exterior areas. Will these materials be required in any of the redevelopment projects covered under this EIR? If these materials are to be used at all, their toxic potential for contaminating the environment needs to be addressed. It is not uncommon in certain circumstances for arsenic, chromium, and copper to leach from these materials.

Our group, in association with architect Dennis Davis addressed this issue with the County last year. There are several situations when the toxic elements in pressure treated woods are released into the environment. These include burning, cutting, and sanding of the wood. Pressure treated decks have been known to leach as well. I submit here letters and articles produced for discussions on this matter in 1998. We ask that the final EIR thoroughly address the impacts of use of this material on the Russian River, local soils, human health, etc.

It is unfortunate that the General Plan says little about riparian and slope stability protection. Many people come to our area lacking any knowledge about the importance of trees and vegetation for the prevention of erosion. Unless the natural environment is adequately preserved, the repair measures advocated as mitigations will be of limited value and after the fact. Why is there nothing in here about minimizing tree and vegetation removal on and near stream banks and hillsides? Why is there no mention of the National Marine Fisheries Service and the Endangered Species Act? Why is there no mention that the Russian River is listed on the EPA 303 (d) list as an impaired water body for sediments? It is likely that sediment pollution will be a big issue with ESA requirements which are barely addressed in this document. The necessary measures for protecting what little is left of threatened salmonid species should certainly be deserving of consideration in this document.

Soils and Geology....

Why is there no analysis of the importance of maintaining vegetation and trees for preserving slope stability? Why are there no measures in place to limit tree removal in sensitive areas? In general, I found this section and mitigation totally inadequate given the geologic sensitivity in our area; the proposed mitigation is totally inadequate. Please see questions on pages 33-35 of this document.

Infrastructure and Public Services.....Water Service.....

This EIR (Page 9-2) states that growth in the Sweetwater Springs Water District (SSWD) has been slow. What are the numbers? Is EVERY parcel in the study area also served by Sweetwater Springs Water District (SSWD)?

The EIR makes the statement that SSWD uses 80% of its allotment of 12,030 ac.ft. per year. What are the impacts on SSWD's water supply if the Eel River diversions are diminished and/or stopped? It is my understanding that about a 15% decrease has occurred already. How is this expected to impact summer water supplies? Are there daily diversion limits? What are they? What percentage of the daily allotment is used at peak periods in the summer time?
The Sonoma County Water Agency is facing a crisis with peak summer flows. What is the status of summer flows with the SSWD? Please give some specific information. For instance, in the last two years, on at least two occasions, Santa Rosa was within 12 hours of completely running out of water. What is the best case and worst case estimates for SSWD?

There is no evidence in this document that the authors spoke with the National Marine Fisheries Service (NMFS) on this matter. What kinds of change does NMFS anticipate? Is the minimum streamflow requirement at Guerneville in Decision 1610 adequate? Is there any change that can be lowered? What impact will stopping the Eel River diversion have on summer flows? Is the 12,030 ac.ft. allowance guaranteed? What diversions limits are placed on the system in the summer time, if any?

It is important that this document answer these questions. While I realize it is a program EIR, it is not likely the individual future projects will have the resources to analyze these issues. The cumulative impacts of inadequate water supply is a significant issue. Water districts in general have been known to assure adequate supply to new development. They let a crisis develop and then they are hope for the support of the community for expanded facilities. Merely stating as in Mitigation PS-1 (Page 9-7) that a statement from the District on any development project regarding water supply adequacy, is not a mitigation and does not address the issue.

How can it be determined that a given project will require additional entitlements for water supplies? What is the guideline or determining factor that will trigger such a need? I have heard Dept. of Health Services state that any situation threatening a lack of adequate water for fire suppression or drinking water needs could trigger a growth moratorium. How close are we to that trigger? What mitigations are in place to meet an emergency?

The statement is made on page 9-6 that, "If current conditions of Russian River water availability continue, additional water demand generated by project-facilitated growth could likely be accommodated, and it is anticipated that additional water rights would be granted by the California Water Resources Control Board (WRCB), is that growth is consistent with the Sonoma County General Plan."

At a minimum, this statement is Pollyannish to the extreme. The key deciding factor in this does NOT lie in the Sonoma County General Plan. The State is under extreme pressure to take action to save the fishery. I can't quite picture them saying, "Well, the General Plan says its okay, so we will give you an increased diversion." Those days are long gone!

The authors go on to allude to possible future constraints in consideration of the fishery but provide no details as to what might occur. There is no mention of NMFS, the biological assessment currently going on, the listing of Chinook Salmon, the status of the Potter Valley Project and future water diversions from the Eel, current legal actions on proposed facility expansion by the SCWA, etc. This document is totally inadequate in its analysis of water supply issues in Sonoma County and/or the lower Russian River.

Please describe in some detail the anticipated SSWD capital improvements planned and their phases over the next twenty years. Why is there no analysis of the amount of water needed per hookup? It is mentioned that restaurants use more water than other commercial uses. How much water do restaurants use? How does this compare to other uses, commercial and residential? How do temporary lodging use compare to restaurants and full time residences? Please provide a detailed analysis of the amount of water needed by new development for both summer and winter use.

Infrastructure and Public Services.....Sewer......

Please note that the Russian River County Sanitation District (RRCSD) Citizens Advisory Committee (CAC) has not met for nearly a year. As far as I know, and I was a member, it no longer exists.

Only a small portion of the annexation area being studied and alluded to on page 9-11 is part of the Study Area for this project. Please identify on a map which parcels are part of the District, and which are not. Is there a chance that parcels in the study map can be added to the Redevelopment Plan? Top of Page 9-10 states that septic systems,"....have also been described as a source of public health problems and water quality degradation." Please see my comments and questions on pages 11-16 of this document.

Statement on page 9-10 claims that the tertiary treatment of the RRCSD removes some nutrients, such as phosphorus and nitrogen. Does it remove some or all of these nutrients? If only some, what portion is removed? What damage is caused by those that are not removed? What is considered a significant amount of these constituents? What increase will occur from added development?

On page 9-10 you state there are 3133 ESDs in the RRCSD. On page 9-12 you state there are 3321 parcels in the district and 2414 of these are hooked up to the sewer. Does that mean there are 907 developable parcels in the District? If not, how many are developable? How many of the developable parcels are in the Study Area? Also, if there are 3133 ESDs and 2414 parcels are hooked up, does that mean there are 3133 ESDs on 2414 parcels? How many are commercial ESDs?

It would be helpful if you provided a map of the Waiver Prohibition Area and show where it does or does not coincide with the Project Area. RRWPC has laid out all of our concerns about problems with Monte Rio and other communities hooking up to the RRCSD in our comments on Monte Rio's Wastewater EIR. We include these comments which have not as yet been responded to in final draft. We would expect you to respond to any of these questions that are pertinent to the RRCSD and this redevelopment project. We have edited this document to be pertinent to the project on hand. This issue is so critical to any new development in the Russian River area that we believe it should be resolved BEFORE any redevelopment is contemplated.

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Alternative 5: Connection to RRCSD Plant....

This is the alternative that holds the most concern for RRWPC for many reasons. While we are appreciative that it has not been selected as the preferred option, we are concerned that it is being considered at all. The mere fact that it even appears in this EIR, gives rise to the concern that the Board of Supervisors will override the consultant's recommendation and select the RRCSD option despite the recommendation. Project fragmentation....

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Guerneville's long range project EIR was set aside last March because of its fragmented description of a regional wastewater collection and distribution system. The document (six volumes and over two years in the making) failed to address the impacts of expanding the system and allowing hookups from Occidental, Camp Meeker, Monte Rio, and 750 Guerneville annexations. Rather it promised that those impacts would be individually addressed in the EIRs as they were developed by each community. But CEQA does not support fragmented analysis. In any case, neither EIR has adequately analyzed the impacts of a regional project.

So Monte Rio and Occidental were left the burden by default of addressing long range cumulative impacts of all reasonably foreseeable projects hooking to RRCSD. The above mentioned communities were clearly indicated in the discarded EIR as being possible additions to the Guerneville system. It was the duty of the RRCSD to address impacts from all of these potential projects which it did not. In Dotty LeMieux's Mar. 18, 1999 letter, she noted (page 2) that while the RRCSD EIR admits that additional capacity will allow for new hookups, they (ie SCWA) nevertheless conclude that "...project will not have any growth inducing impacts because the project...does not include potential future flows from outside the District's existing service area boundaries."(RRCSD EIR Page 6.2-7)

Understandably the authors of the Occidental and Monte Rio EIRs do not wish to carry the burden that belongs to another entity. While Monte Rio's document attempts to address some cumulative impacts, we do not see that it has done so fully.

Third Unit Processes Project and system capacity....

Soon after setting aside RRCSD's EIR last March, the District's Board of Directors (Supervisors) elected to authorize the Third Unit Processes Project based on a 1976 EIR. This involved adding components to the plant that would basically add capacity for new hookups while they formally stated that the additional capacity was needed by current ratepayers. RRWPC has been forced to file suit against the RRCSD.

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In short, the Third Unit Processes was part of an EIR done 23 years ago for District ratepayers only. If any capacity created by that addition is now utilized by other Districts, then the impacts of its addition must be FULLY and cumulatively analyzed for environmental impacts. We believe that the Board of Directors have illegally approved this project.

EPA Audit: Additional Cost Concerns....

On January 22, 1996, Ernie Carpenter as Chair of the Board of the RRCSD received the final audit from the EPA, an audit that had been going on for over ten years. The problems surrounding the construction of the RRCSD were so complex and convoluted it would make any expert's eyes glaze over to have to look at the details.

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Perhaps even more importantly, the statement is made on page 32, "If the District (RRCSD) sells capacity outside the service area of the grant funded project, the District must repay EPA and the SWRCB the proportional federal and state shares." We wonder if EPA repayment has been figured into project costs? What would that amount come to?

Repairs and Storage Needed for Current RRCSD Ratepayers....

Guerneville's system MUST be repaired to serve current ratepayer needs during high flows. While the Third Unit Processes addition would provide extra treatment capacity during high water periods to current users, it would be of minimal help at these times to avoid future permit violations without new storage. This latter is especially important since our current emergency storage is only operating at half its capacity according to Regional Board staff. In other words, this project does not serve Guerneville's problem, let alone provide solution to the needs of other communities.

This problem becomes exacerbated if new hookups are to be added from other communities and/or new annexations to the District. The impacts to the Russian River and surrounding communities during flood periods cannot be ignored. If Occidental's and Monte Rio's systems are hooked to Guerneville, all of the ramifications must be studied.

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Regional Board's Cease and Desist Orders.....

RRCSD is under heavy Cease and Desist Orders from the Regional Board. The impacts of our discharge are many. The OEIR assumes that the planned additions (third unit processes) will solve not only Guerneville's problem but would support capacity to Occidental without any adverse impacts. Similar promises were made by SCWA staff in a letter to the Planning Department concerning Monte Rio's proposed project (enclosed). Yet as early as 1997 the North Coast Regional Board noted (Order No. 97-96):

8. The lack of adequate storage capacity and/or inadequate operation of storage facilities threatens to cause future violations of the discharge prohibition contained in Waste Discharge Requirements Order No. 92-51 and Waste Discharge Prohibitions contained in the Water Quality Control Plan for the North Coast Region.

Even the SCWA, in their Board transmittal packet to the Board of Directors (Supervisors) of May 25, 1999, stated, "District staff has identified the need for equalization storage and increased disinfection capacity at the District's treatment facility to address high winter inflows and flood related issues." The Directors of the RRCSD have openly refused to provide more storage capacity at this time because it was not covered in the 1976 EIR and would require a new EIR before being built. Yet it is probably the storage capacity that is most needed and most clearly identified to meet the terms of the Cease and Desist Order. The May 25th action was clearly an attempt to circumvent CEQA and to piecemeal part of a project that had been thrown out partially for this same reason only last March. While Occidental and Monte Rio may not want to jump into this quagmire, nevertheless, by including the option in the OEIR, it behooves both entities to fully analyze all of the impacts. After all, it is the Supervisors (also sitting as Directors of the SCWA, the RRCSD, and Occidental) who have jurisdiction in this matter and with whom the ultimate decision lies.

Long range cumulative impacts....

It is of extreme concern to RRWPC that no one is taking responsibility for adequately addressing the long range cumulative impacts of all of these hookups (ie, Occidental, Camp Meeker, Monte Rio and 750 Guerneville annexations). How will each and all contribute to Guerneville's discharge problems under all flow scenarios. While individual contributions might be small, the contribution of all new flows together could increase RRCSD influent flows by as much as 40%, and no one is looking at the impacts of that in any detail.

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What are all the possible wet weather flow scenarios over the projected life of these projects? How will RRCSD manage these higher flows from Occidental, Camp Meeker and Monte Rio to prevent bypass operations at the plant? What is the worse case scenario for managing the system during the worse wet weather? How might this interplay with potential bypass operations at the plant?

Comments on Project Description: Alternative #5......

Subsection A of this alternative considers that all of Monte Rio's wastewater would be treated and disposed of by RRCSD. This would appear to mandate, as per CEQA, that all impacts affecting both systems get addressed, since capacity for Monte Rio does not currently exist. We have already mentioned several issues in this regard and more will follow.

There are some inaccurate statements in this section that begins on page 7-16 of the MREIR. They include:
Storage ponds have been determined by Regional Board staff to have a 4 mg capacity rather than 4.5. This is because there has been siltation in the smaller emergency pond.

On page 7-17 the statement is made that, "Presently the flows at the plant average about 300,000 to 350,000 gpd under dry weather conditions." This is simply not true for all years. While some years may have less dry weather flow than others depending on how many summer tourists show up, the data for 1995 indicates a dry weather flow close to 400,000. Further, the Draft EIR of September, 1998, states it treated an average reclamation flow (summer) of 3.9 mgd. In other parts of the document it is estimated that flows will go to about 4.2 once everyone in the District is hooked up. This is before all of the remaining properties in the RRCSD have been hooked up as required. Please adjust esd calculations on page 7-18 in light of this higher usage.

As the Russian River redevelopment project proceeds and new development is encouraged in the lower river area as tourism increases, the RRCSD can expand on its own without any additional help from Monte Rio. If all the current and anticipated flows were projected correctly, it is hard to imagine there could be enough excess capacity for Monte Rio.

"The Plant's ultimate design capacity of 710,000 gpd is the equivalent of roughly 5,900 ....(ESD's)." Surely this capacity estimate is based on summer use only and assumes adequate spray irrigation area and storage is available. In light of actual flows of 400,000 gpd, how would this estimate change? How might your other calculations be altered?

Note: capacity of storage is overestimated as mentioned earlier. Please adjust calculations on page 7-18 under Emergency Storage Capacity.

Order # 97-76 of the Regional Board does not order the construction of 201,000 gallons of storage; that was the amount of the illegal discharge in May, 1996. They ordered the District to seek a long term solution to the problem of illegal discharges since that had been the second in two years. In fact, it has been estimated that as much as twenty-five million gallons of storage might be necessary to accommodate all flow scenarios although the most that could be constructed at the plant site is six million gallons. The statement that an additional 400,000 gallons of storage would serve ultimate design capacity is entirely incorrect.

Further, we wonder why this document only looked at the spill from 1996. There were spills in 1997, 1998, and 1999, far worse than the one in 1996. We request that you discuss the impacts of all Regional Board Orders in that time period.

The SCWA has made absolutely no public plans for additional storage at this stage and is not likely to for at least a year. Since actual construction of new storage would not occur for at least two or three years, how would this affect Monte Rio's plans should it be decided to hook up to RRCSD?

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Under Scenario B it is important to carefully define the circumstances under which MR would have to pipe effluent back to Sheridan in summer or hold sewage during high winter flows. What design changes need to be made to allow MR to function during at least a month of RRCSD break down as in Feb., 1998?

If both primary and tertiary effluents flow through the same pipelines at the different times (ie., back to Sheridan for disposal), how would tertiary effluent be affected after this exposure? What could mitigate this?

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Geology: Section 3.1.....

Page 73 (top) discusses possible impacts of ground shaking on the collection system and project facilities. There is no mention of the RRCSD plant site specifically. In the RRCSD Project Upgrade and Expansion there was an engineer's report that recommended special seismic stabilization measures for any new storage ponds or basins. But that document was thrown out and instead new facilities are being contemplated under the 1976 EIR. Is seismic engineering planned for Third Unit Processes Project?

Given the fact that the cost of the Third Unit Processes Project has been estimated at $2.5 million, it is unlikely that this work is going to be done. Since Monte Rio couldn't hookup until it IS done, shouldn't there be some analysis in this document to acknowledge the potential problems at the RRCSD plant which is subject to liquefaction during seismic events? Please address whether seismic work on new facilities is included in cost estimates for the RRCSD alternative. Describe. If not, why not?

Furthermore, in 1998 there was a serious landslide at the plant site which affected operations of the system and was one of the reasons for the 30 days of NPDES violations in February. How will Monte Rio be affected in such a scenario if it happened again? How can the situation be mitigated? What are the potential fines MR would have to be fined if the situation continued?

Hydrology and Water Quality: Section 3.2....

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The section on impacts with wet season disposal at RRCSD is totally confusing for many of the reasons earlier described. There is mention of treatment plant upgrades at RRCSD but these are not really defined. There are no distinguishing descriptions of the discarded Facilities Upgrade and Expansion Project EIR and the Third Unit Processes Project authorized under a 1976 EIR and now in litigation.

The contradictory statement is made (page 115) that, "The treatment plant has sufficient hydraulic and treatment capacity for this amount of flow increase and, thus, would be able to accommodate the Monte Rio service area once the upgrades to the facility are completed." Either the capacity is there now or it isn't. What needs to happen for capacity to be adequate so that there are no violations of the NPDES permit and that adequate capacity exists for ALL COMPONENTS UNDER ALL OPERATIONAL SCENARIOS?

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Isn't it speculative for Alternative #6 (5B?) in this EIR to assume that additional storage would be provided at RRCSD since there has been absolutely no public discussion about how and when this would occur since the March, 1999, EIR was discarded? Furthermore, you have stated (I can't find the page at this moment.) that since the RRCSD is relatively new, the inundation problem is caused by inflow and not infiltration of the pipelines. The most recent Administrative Civil Liability Order #99-51 from the Regional Board states, " River water enters the collection system through plumbing fixtures of flooded homes, ajar manholes, illicit connections, and other sources. Elevated ground water also seeps into the collection system." (my emphasis)

The statement is made (p.116), "Presently, monitoring data for the RRCSD effluent and the receiving water (ie., upstream and downstream in the River) show no violation of discharge limits and no measurable impact on River water quality." This is simply not true. In Feb., 1999, 1.41 mg was bypassed and that 1.125 mg of that was discharged to the Russian River. There were 3 coliform violations, 2 turbidity violations and 1 total suspended solids violation. Furthermore, I believe that it was after the Feb., 1998, illegal discharge, the Agency failed to do any downstream monitoring. I request that you examine the record at the Regional Board carefully through the current date and make the appropriate corrections in your draft document.

Where you state that monitoring data, "....show compliance with established standards and no apparent deleterious effects on the River." which data did you examine? Please specify. Further it states (page 116), "There are no effluent limits or receiving water conditions that seem to be in jeopardy of violation from the current river discharge permitted under Order No. 92-51." How can you make this statement in light of violations every single year since the SCWA took over management of this system? Please revise this whole section to reflect true circumstances.

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Vegetation and Wildlife: Section 3.3....

The Monte Cristo area is so unique and so fragile that it deserves special and very detailed analysis, and possible additional studies BEFORE EIR certification. The analysis should address tree removal and slide potential as well as loss of important habitat. Should Monte Rio hookup to RRCSD and a big spill occur, what would be the impact on endangered steelhead and salmon?

Traffic and Circulation: Section 3.5...

What would be the impact of the plant expansion on Neeley Rd. traffic? How many extra trips in and out of equipment, chemical and other deliveries, operational services, and employee entrances and exits? How many of these trips would be by trucks and other large vehicles? Water: Section 3.9...

Sweetwater's manager doesn't think there will be a problem getting an increase in the District's water rights since they are moving close to their limit. Yet we wonder if there might be a problem in a drought year and that the District might be forced to develop expensive storage? Please address this by examining flows from 1977 in this analysis as well as growth projections for RRCSD and Monte Rio (including redevelopment plan).

Public Health and Safety: Section 3.15....

This section addresses the septic issue again. All of the points we mentioned before regarding a lack of evidence of failure apply here. There is an assumption that the project will provide a benefit so there will be no impacts. Yet there is no information provided regarding people's health in the area indicating any problem. Why not survey local doctors and public health records to determine if there is evidence of a problem? What hazards exist during rainy periods either with or without a project? Given the mitigations for discharge of primary effluent at Sheridan during flood periods, how might public health be improved with a RRCSD project?

Furthermore, with septics, if there is a pipeline break due to slope movement, the damage is limited. What is the extent of potential mainline pipe breakage and consequent health impacts if they carry raw sewage? What will be the fate of the material? How will the public be prevented from contact with it? Impact 3.15-B on page 185 just talks about containment at the point of generation. We wonder what happens enroute to Sheridan?
What are the potential impacts if power outages last longer than two days? The mitigations on page 186 seem kind of tenuous. What if they don't get enacted but the project goes in without them? What is likely to occur? How much environmental damage might result? Impact 3.15-A makes the claim is made that the project would improve water quality. As we have discussed earlier, this has just not been demonstrated through analysis of water quality data.

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Impact 3.15-B: Failure of pipelines or pumps could result in discharge of raw sewage.

We are very nervous about how these grinder pumps will hold up under adverse circumstances and whether property owners will take responsibility for maintaining them. Will there be any governmental oversight to make sure things function as they should? Who is culpable if they are not properly maintained or replaced when necessary? What is the risk of pipe breakage in slide prone areas? Does this kind of system have a track record in any environment similar to ours? Have the proposed mitigations been factored into the cost estimates?

We wonder if the potential for failure over time will be as great as for septic tanks given the unreliable geography. As these pumps reach the end of their life, what are the guarantees they will be replaced in a timely manner? What if a person can't afford the $3000 + to replace the unit (plus labor)? It seems as though these units should only be used on a very limited basis in the flood way and lower floodplain and on-site technology alternatives used for those houses outside of the flood plain.

Disinfection....

It is mentioned (page 190) that disinfection would be with UV technology. Where would this occur? Will the barn be large enough to contain this process? Please describe in more detail.

Management Oversight During Flood Periods.....

One of our great concerns is the point at which it gets decided that Guerneville cannot treat Monte Rio's waste and they have to revert to storage and discharge at Sheridan. How will that work? Who will decide? What will the lines of communication be and how will the transfer work? What circumstances determine the point at which it goes back to Guerneville? What if storage at Sheridan is inadequate as we believe? What will be the risk of discharging primary effluent at that site? In light of SCWA management problems (see Krepack report) what are the opportunities for break down here? This Agency is known for poor communications and confusion as to the chain of command. Workers often are ill-informed of their responsibilities.

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Cumulative Impacts....(page 207)

Mentions impacts of "...recently approved upgrades to the RRCSD Treatment Facility." Is the Third Unit Processes Project upgrade or expansion or both? Please give justification for response. Why is there no mention that this project is under litigation?

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Treatment capacity of RRCSD is again discussed on page 209. This document uses the SCWA's explanation of the need for the Third Unit Processes Project as completion of the original capacity design of 710,000 mgd. But no one has explained that the original capacity was designed for the RRCSD ONLY. It has turned out that RRCSD does not need it except for a few days each winter. And even then, we might not need it if we had about 5 million gallons of additional storage.

Please explain how you can justify using that 23 year old EIR to build capacity for other communities when it was intended for the RRCSD ONLY? Furthermore, Guerneville's dry weather average flow, after all District parcels are hooked up, according to the discarded EIR was about 410,000, yet this document (page 209) again states that average dry weather flows are 300,000 to 350,000. That assumption would throw capacity estimates off by about 15%. Please recalculate. In fact, even the 410,000 gpd number demonstrates that RRCSD does not really need the Third Unit Processes Project. We need storage!

The statement is made (page 210) that, "The collection system is relatively new and any leaks appear to be minor." Have there been any tests on the collection system that we don't know about? We know the SCWA likes to insist that things are fine with the pipelines but we are not aware of their being tested in a long time. Given the problems with construction of the collection system, it is entirely possible that infiltration is occurring along with inflow during rainy periods. In fact, we believe there is a study going on now and for the coming year that shed light on this issue.

Please explain how the addition of 1043 people BEYOND the addition of these entire communities will exacerbate problems with RRCSD's storage and irrigation limitations? What will be the impacts on all perimeters of water quality? How could this possibly be an improvement over what we have now? How might the bypass problems at the plant be exacerbated? How might the penalties and fines for continuous spills and bypasses increase over the years? How will commercial growth impact the RRCSD as compared to residential growth?

Comments on RRCSD Upgrade and Expansion EIR....

Finally, we believe that many of our comments on the RRCSD Upgrade and Expansion EIR are relevant here. We include for your response an excerpt of our comments on the pertinent issues from that document as well as questions raised concerning the expansion of the treatment plant. Please address these. At this point we want to integrate the pertinent comments on the EIR for RRCSD's Upgrade and Expansion Project. We have eliminated those parts that do not apply to Monte Rio.

Russian River Watershed Protection Committee (RRWPC) Comments on:
Draft EIR Facility Upgrades and Disposal Expansion Project for the Russian River County Sanitation District (RRCSD)
November 2, 1998

Key issue goes unaddressed....

This EIR does not really address the key issue that caused the need for this document in the first place. The collection system, and ultimately the plant, fails during high water periods and subjects the District to fines and penalties for water quality violations. The Citizens Advisory Committee (CAC) recommended early on that the EIR only address failures occurring 95% of the time in order to assure affordability of the improvements. We wonder if the Sonoma County Water Agency (SCWA) has adopted that as a criteria for this project EIR? If so, has it been determined which, and how many flood events would be eliminated by that criteria?

Because of a concern for water quality and public health, RRWPC believes that every attempt should be made to treat all waters entering the plant up to 38' flood events instead of using a 95% criteria. Over that level, it may be physically impossible to meet discharge permit regulations since the river inundates the collection system. We have observed the SCWA try and get water quality standards lowered in order to relieve them of meeting discharge standards during any high flows, even below flood level. In February, 1998, plant treatment broke down when the river was at 25'. For these reasons, RRWPC does not believe that the RRCSD treatment plant can serve a greater area without being in frequent non-compliance with the Clean Water Act.

How does SCWA intend for this project to meet all requirements of the Regional Water Quality Control Board NPDES permit for this system, especially during high water periods? Does this project assume that the Agency will be able to get monitoring and discharge regulations changed to meet District needs? Please explain in detail.

Infiltration and inflow problems go unaddressed....

SCWA rejected the request of some CAC members to include pipeline infiltration and inflow repairs and improvements as part of the long range plan. In the Agency's submittal of the Russian River Treatment Plant Short Term Solutions Report, Cease and Desist Order No. 98-57 to the North Coast Regional Board, the report states, (page 5-6) "The average dry weather flow (ADWF) for the RRTP (Russian River Treatment Plant) is between 0.31 and 0.36 million gallons per day (mgd). Winter flows (non-flood related) typically remain in the 0.35 to 0.65 mgd range, which indicates that approximately 0.3 mgd of inflow in winter may be due to infiltration. This illustrates that the collection system is in very good condition."
(These numbers are misleading as they do not represent actual flows for all years.)

Unfortunately, the above report did not account for the severe drop in District population during flood periods. In order to substantiate their conclusion, definitive studies of summer populations are needed vis a vis winter flood period populations. How many people stay in the river area during major storms? Can SCWA produce this data? In other words, if fewer people are producing twice as much effluent, leaking pipes could be at fault. Has SCWA done any testing of the pipes to certify their good condition? If not, why not? Responsible ongoing maintenance should dictate periodical testing and cleaning of pipe lines.

West County taxpayers oppose regional pipeline.....

RRWPC was part of the public that severely criticized a regional pipeline system proposed two years ago. The SCWA has proposed the current project in its stead, claiming that it is not a regional pipeline project. We believe that this project is a thinly veiled attempt to produce a major segment of the regional system proposed two years ago.

Who is this project supposed to serve, if not most of the same communities proposed in the 1996 project? The current system, after all required hookups are on line, only needs about 410,000 gallons per day (gpd) dry weather flow capacity. This project provides 710,000 gpd, about a 75% increase. The DEIR states, "In 1996, the District proposed three regional wastewater system scenarios to resolve sanitation issues in the West County. The District's Board of Directors directed staff not to proceed with the regional system concept because the majority of public comment reflected strong opposition to a regional system. However, other west county communities are considering alternatives that may include a connection to the District treatment facility as part of their analysis of a reasonable range of alternatives under CEQA. Such connections are not being proposed as part of the Facility Upgrades and Disposal Expansion Project, however, the cumulative impacts of these related projects are discussed in Sub-chapter 6.3- Cumulative Impacts."

RRWPC attended many of the Occidental, Camp Meeker, and Monte Rio meetings where citizens voiced opposition to a RRCSD pipeline. In some cases, they were told that a local solution would be far more expensive than a RRCSD hookup. They were told they had to consider a RRCSD hookup even though the latter system fails regularly with only current users. The whole range of impacts to the Guerneville system is eliminated from consideration in this EIR even though capacity for these new hookups would be ostensibly provided by this project.

Real project being piecemealed......

So what is the real project? How can this project document provide capacity for unknown and unidentified future hookups (its title alludes to its being an upgrade AND expansion project) whose critical impacts are currently unknown? Given the serious failures of the plant during high river flows, and given the fact that this project does not completely address those problems, how would added flows from either/or Occidental, Camp Meeker, Monte Rio and a possible 750 annexations, impact the plant during high water flows? What would be the impacts to the river in terms of added nutrients, heavy metals, bacteriological contamination, pH factors, temperature changes, turbidity, etc.

What is a feasible alternative?

We would also like to know why it is reasonable for Occidental, Camp Meeker, and Monte Rio to study hooking up to a system that regularly fails during high river flows and which is likely to get worse if such hookups were to really occur?

Design Capacity: An excuse for expansion?

Throughout the EIR process, the SCWA has referred to a need to bring the RRCSD up to design capacity. We believe the concept of design capacity has been misused to justify unneeded growth to the system. In the original system design plans, the number 710,000 gpd dry weather flow was ostensibly the capacity of the system to treat all summer flows.

And yet, the plant was never completed to provide that level of treatment, and some components, designed to treat that amount, proved inadequate. The disinfection, storage, and irrigation systems were never adequate. The aerator being proposed for this project was in the original design but never built. On page 4-2, it states that a third clarifier and a third filter are also necessary. Why are they not being proposed in this project?

Something else doesn't make sense. It is stated that the aeration basin is needed for emergency storage during the reclamation season. If the plant is being utilized to its capacity, in other words, if excess capacity from this project is used by hooking up 750 annexations and three other communities, would a fourth aerator be needed then? (Actually, we have learned that the aeration basin cannot switch uses from treatment to storage and back again.)

Because of this, as well as the problems encountered in the collection system during high river flows, the North Coast Regional Board determined that the dry weather flow capacity was actually 510,000 gpd. While certain upgrades are necessary at the present time, the expansion to 710,000 gpd, for reasons already mentioned, is certainly not. The footnote on page 4-2 explains how expanded capacity will be used. Why was this not part of the project description? How can you justify putting in a footnote and studying cumulative impacts and still not making it part of the project description?

In project objectives list on page 4-4, why is there no objective listed about expanding the system? How can you include the concept of expansion in the title of your document (and other places) and not include it in your project objectives? Further, in designing the storage component, design capacity was assumed. How can you assume design capacity without describing from where the capacity will be filled? If current users don't need capacity, how can you assume full design capacity for components not needed on that basis? How can you explain the fact that while the irrigation component is about five times what current users need, the storage component proposed is severely inadequate for current users in several river flow circumstances.

It is quoted on page 4-5 that 18 mg flow went through the plant in eight days in the Jan.'95 flood. I believe that in March, 1995, about the same amount went through the plant in two days. While I believe that local citizens should not be held responsible for treating the river in those extreme flow scenarios, nevertheless, adding new hookups to this system would guarantee additional pollution in the river at those times. Rather than providing pollution control, adding new hookups would exacerbate the situation and would be totally irresponsible.

It is important to provide information on the various problems at the plant under various flow scenarios. ln conversations with Regional Board staff we have come to believe that much can be done to improve operation of the system during minor floods under 38'. At what point is it impossible to run the system? How would the addition of 300,000 gpd dry weather flow during winter conditions exacerbate the problem?

On page 4-5 it states that the aeration basin would be utilized for storage. If new hookups are added to the system, at what dry weather flow scenario will the aerators be needed for treatment rather than storage? How is it possible to switch functions if higher flows are coming into the plant? What is the comparative per gallon cost for building an aerator as opposed to a storage pond? On page 4-6 the report states, "During the reclamation season, the third aeration basin could be used for emergency storage because it would be needed only as a Titled 22 reliability requirement and not as part of the treatment process." This is very interesting since emergency storage is generally needed in the winter time and seldom in the summer.

Reliance on 1976 EIR.....

We wonder how appropriate it is to rely in any case on the 1976 EIR (as on page 4-6 in the project description). So many conditions have changed since then. For example, some components have proven inadequate such as spray irrigation on the golf course, water quality changes in the river have occurred, endangered species have been listed, the Mandatory Connection Ordinance was passed. While the goal of this document is to produce a project to serve so called design capacity, circumstances have changed so drastically since 1976, new environmental review has become necessary.

Geologic feasibility of additional storage on plant site....

In reading the geotechnical report, we learned there are several factors of concern in area where storage and aeration would be built, including weak soils, high ground water, and possible uphill slope instability. (page 6 & 7: Report, Soil Investigation.... by Giblin Associates). What special ground modification techniques would be integrated into the project to protect against possible hazards? Would consolidation of granular soils be utilized to guard against extreme damage during a seismic event? At what cost? We wonder if these factors were taken into consideration before cost figures were developed? Was overexcavation and recompaction factored into the costs? What were these? Would pond embankments be geotechnically reinforced? At what cost? How would the compression of soils under ponds and aeration basins be affected by seismic events? What movement might be expected in a 5.0, 6.0, 7.0, and 8.0 earthquakes? What measures (and their associated costs) would be taken in construction to maximize ground stabilization and minimize liquefaction? Are there cumulative effects on the stability of the soils from the combined effects of the whole facility? What are these?

The report states that the actual consolidation of soils might take an unknown amount of time. How might this affect capacity and integrity of storage ponds and aeration basin during various construction time spans? Can you use facility as compaction takes place? Under what circumstances might loss of use occur? How would this affect overall operation of system? What problems and repairs might be anticipated? What would be anticipated cost of repairs? On page 4-13 of the EIR, it states that costs for reducing seismic and liquefaction potential are not included in the estimates. It seems as though this makes cost projections very misleading. Are we looking at a doubling of costs or more for that work? It seems as though the most important component of the project will cost way more than projected and will not solve the problem of winter water balance for current users, let alone allowing hookups to use capacity of 710,000 mgd.

Land Use: Comments on Impacts.....

The question arises, would increasing the system to design capacity stimulate housing uses in the flood plain? Also, plant functioning is severely impacted by hook ups in the flood plain; there is a great deal of infiltration and inflow from flooded properties. Assuming that Occidental, Camp Meeker, Monte Rio, and 750 annexations in the Guerneville area (about half are undeveloped) come on board as a result of increased capacity, how will that increased density affect flooding and what would be the corresponding impact on the plant?

Geology, seismicity, and soils: comments on impacts....

What is the history of seismicity in the project area? To what extent were hillsides and fractured rock formations formed historically as a result of earthquakes? What instabilities in the soils can be attributed to seismic events? What is the likelihood and probable extent of future failures in the project area as a result of seismic events?

On what basis are erosion hazards seen as slight to moderate? What would be considered severe? Why are there no maps showing which soils predominate in each area of the project? Page 5.3-2 states that, "The greatest portion of landslides in Sonoma County occur in areas of weak soils that are devoid of vegetation, have excessive slopes, and are subjected to high-intensity, long-duration rainfall events." While we agree with this statement in general (and it is ONLY a general statement, not site specific!), the document then goes on to site the Rio Nido landslide which was NOT devoid of vegetation. Similarly another example was several serious slides at or near the treatment plant in an area also filled with vegetation.

Will all compacted fill be examined for contaminants such as organic compounds and heavy metals? Will NMFS & CA Fish & Game be consulted for all creek work including all crossings? Who will oversee construction? Will the SCWA have inspectors on sight to assure mitigations are being met? How frequent will construction inspections occur?

Water Quality: Comments on Impacts.....

How does the nitrate/nitrogen range compare to other local dischargers? Can nitrates that are irrigated filter into the ground water, especially in permeable soils? If salts can move through the soils without accumulating and this is good for the soils, what does it do to the groundwater?

What risks exist for bioaccumulation of heavy metals or organic chemicals? Has any testing been done for pharmaceuticals in the waste stream? What has been the bioassay history of RRCSD wastewater in regards to chronic and acute toxicity? What testing has occurred, how frequently and what were the results?

According to the EIR, this project reduces the potential for flood overflow operations during flood events. What would it take to eliminate the potential? What is the quality of the water being discharged during flood events? Are any studies done on the existence of trihalomethanes formed during storm weather discharges? What are the trihalomethane levels during normal operations?

Given the instability of the soils at the plant and vicinity, what is the likelihood of a massive failure once the project is built? What toxins would enter the river if that were to happen. Why was there no data presented showing water quality upstream and downstream of the discharge? In fact, why was there no data presented on quality of the effluent over the past years since operation? Santa Rosa's EIR presented hundreds of pages of data on water quality of effluent; this report gives nothing. How can we analyze past, present and future water quality impacts with no data?

We are concerned that erosion at the plant during construction can go into the rainy season and cause permanent damage. How will the project avoid being impacted by the rainy season? Also, how will timber harvesting at the plant site impact and interface with erosion from construction. What site alterations will occur as a result of potential erosion?

Accumulation of salts in soils is mentioned as a potential problem of irrigation. What about the problem of the accumulation of organic chemicals and heavy metals? What chemicals and metals have been found in RRCSD's wastewater in the last five years? How often were tests taken? How sensitive were the tests?

Public services and utilities.....

The only major question here is what is the impact on downstream wells (including Sweetwater Water District and private wells) when a lower quality of wastewater is released during winter flood events? What would be the impact once Occidental, Camp Meeker, Monte Rio and 750 parcels in Guerneville were hooked up, especially if infiltration and inflow were to greatly expand due to the new hookups?

Biological Resources.....

What is not mentioned here is that there are other xenoestrogens coming from wastewater including thalates from plastics and surfactants from many household products. Please obtain more information on this issue and also the extent of pharmaceuticals in the waste stream. We suggest that you contact the EPA and include more detailed information about their current findings and direction in which possible regulation is going to go. Please include this in the final EIR.

Growth Issues.....

Please identify which parcels in Occidental, Camp Meeker, Monte Rio, as well as the 750 parcels identified for possible annexation might be buildable now, according to the General Plan if they had wastewater services accessible. Also, how many of the lots might become buildable with certificates of compliance?

On page 6.2-4 it states that, "The increase in connections as a result of the Mandatory Connection Ordinance requires the construction of a third aeration basin, secondary clarifier, and filtration equipment." It was my impression that the entire EIR was predicated on the ability to operate the system at full capacity once the project was complete. If that is not possible, then, many of the conclusions of this document are probably invalid (This was also pointed out as a significant problem in Tech. Memo #3 for Monte Rio.)

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This document fails to mention that some of the parcels in the Guerneville area are not part of the RRCSD and would require annexation. Please discuss the impacts of annexing those parcels to the RRCSD.

Impacts and Mitigation Measures for Sewer.....

Impact PS-3: Sewage treatment demand impacts....

We believe this document amply demonstrates why this project should be considered as having an unavoidable significant impact rather than a potentially significant impact. There is no additional sewer capacity available now for new development without significant capital being spent on expanded wastewater treatment and disposal facilities. Right now the current system is in need of additional storage and summer irrigation lands. The implementation of any part of this project will exacerbate current conditions to the point of needing major new facilities. Furthermore, these facilities themselves may easily continue to have adverse affects on the environment.

Mitigation PS-3:.......

This does nothing to address cumulative impacts of expanding or constructing additional wastewater treatment facilities.

Vegetation and Wildlife......

At what point do onsite surveys get done to determine existence of endangered species? Will any small parcels be required to conduct field surveys? What environmental documents have been prepared for our area that contain information on vegetation and wildlife (how about a list)? The trees in many parts of the Redevelopment District are far more dense than alluded to on page 10-2 under (b) Urban. It says, "....remnant stands of coast redwood and Douglas fir can be found along property boundaries and creeks." This is a mischaracterization; many of the areas are so dense that we fail to see the sun about four months of the year. Has the author of this document ever visited our area? Did he or she enter and explore Rio Nido? Or the Guernewood Park area? Or the Drake Road area? (These are just examples.)

This document fails to identify locations of the various riparian habitats and forested lands. Shouldn't a map be provided that shows the location of the various habitats in the study area?

Page 10-3 states that Chinook are stocked in the river from hatcheries. It is doubtful that all Chinook are from hatcheries. Please consult with fishery experts and NMFS on this matter. In any case, they have been listed as a threatened species and will be given special protection by the ESA. Also, why do you refer to Chinook salmon, coho salmon, and steelhead trout as having special status when they have been listed as threatened under the ESA? Why does your list in Table 10.1 not list Chinook and steelhead? Is the list more than two years old? What other species have been listed in the last two years including plant, animal, and bird species, etc. that do not appear on this list?

Why is there no mention that National Marine Fisheries Service (NMFS) is in charge of the listing of salmonids and has regulatory powers for their protection? You only mention USFWS and CDFG on page 10-4 under special status species. Why is there no mention of the Section 7 process, to include an extensive biological assessment, currently undertaken by the county and very much affecting this project (page 10-5)? Please learn more about this and discuss the possible impacts on redevelopment.

On the top of page 10-4 you fail to list toxic pollutants, and point and non-point discharges in your list of impacts on water quality. Please explain why. As in all other sections of this document, Sonoma County General Plan Goals, Policies, and Objectives are listed. Why is it never mentioned that these have no real force of law since they are really advisory and discretionary? Why are no pertinent regulations of the State and Federal Government listed? What are all the pertinent State and Federal regulations that apply here?

It seems as though water quality perimeters should be added to the list of significance criteria. Again, none of your criteria here mention NMFS or the WQCB. Why not? Please list. Why is there no mention of the need to prevent erosion and other pollution so as to protect water quality? Mitigation VW-1(a) is really inadequate to protect against unavoidable impacts if development is allowed too close to stream banks. By the way, the General Plan has almost never protected banks before when people are determined to alter them, how can you state that the County General Plan will reduce potential riparian impacts to a less than significant level? Please demonstrate where this has occurred. Also, we are concerned that revegetation won't really alter the impact caused by streambank erosion during construction. Furthermore, depending when construction and revegetation take place, there could occur significant erosion problems, especially if it is on the river and high waters should occur. Please discuss impacts of such a scenario.

Also, this same mitigation calls for replacing riparian vegetation that has been removed. Precisely how is this going to help erosion problems? How can mitigation banking be used where a threatened species is affected? Why is there no specific minimum set back required? How will the NMFS requirements affect setback requirements? (They had advocated 300') The mitigations in this EIR are very weak on this issue.

How are the mitigations to protect from erosion and pollution going to be effected for small parcels? Will the entire area come under these mitigation measures? How will they be implemented? What considerations will be made for the toxins released by pressure treated wood? What slope and bank protections will be put in place to protect erosion from occurring? What special considerations will be made in the floodway? In fact, why has there been barely any acknowledgment of special considerations in the floodway?

Most of the General Plan so-called protections that are to bring impacts to a less than significant level have not seemed to do much so far. The river has been steadily degrading in most places and the fish and wildlife disappearing. How can we assume that these measures to protect the environment are suddenly going to work? Also, how can a mitigation that is encouraged, guarantee that impacts will be brought to a less than significant level?

Air Quality.....

Please comment on the statement that, "Pollution potential in the Project Area is relatively low dur to the rural nature of the area and the lack of abundant air pollutant emissions sources." This is an interesting statement in light of earlier considerations in the document referring to the project area as urban.

Why is there no air quality data presented for 1998 and 1999? The air quality this year has appeared to be pretty bad.

Construction site controls on page 12-10 call for pavment as one means to protect from dust at construction sites. Has this potential added pavement been factored into the amount of impervious surfaces that would be created by new development?

Why is there no mention of the air cleansing and oxygen producing capabilities of our trees? What are the potential impacts from tree cutting? What is the estimated benefit of each tree's oxygen producing and cleansing properties? What would be the cumulative effects of tree cutting from the project on air quality? Please estimate the number of trees that would have to be cut for the project.

Mitigation AQ-2 is designed for an urban community, not a rural one. We do not want urban amenaties such as sidewalks and a lot of artifical non-native landscaping on our roadways. Bikelanes are generally an amenaty that most urban areas have, let alone rural ones. This mitigation is totally unacceptable; you are going to have to do better than that!! Also, why is there no mention in this Mitigation to limit tree cutting?

Hazardous Materials....

Why were none of these hazardous materials issues listed in your section on water quality impacts? What are the impacts to water quality from the various toxins that will potentially leach into groundwater and waterways? Also, again we request you address the pressurized wood issue as mentioned in our section on water quality.

Please address issue of potential chemical accidents on Neeley Rd. as a result of more chemicals being needed by the treatment plant in order to serve more people. What chemicals and amounts do they currently use? How much more will they need if Monte Rio and 750 new annexations get hooked up to RRCSD? How many trucking loads will this represent? How much chemical is carried in any one load? What emergency measures are in place to protect residents in the event of a spill?

Can we have a map of the parcels that have been identified as having toxic problems?

Can fire be a source of toxic asbestos release? What are the ways that firemen and construction workers will be protected from asbestos release during rehabilitation work?

On Page 14-9 under Potential Asbestos and PCB Exposure it is mentioned that, "....the City would require the project applicant to coordinate with the Bay Area Air Quality Management District to determine is asbestos is present." First, is our area under the authority of the BAAQMD? Secondly, what City are you talking about? The process for determining whether asbestos is present in any redevelopment project is unclear. Please be more specific as to how the presence of asbestos will be identified.

CEQA-Required Assessment Conclusions....

Bottom of page 17-1 you compare number of households to units; are these the same thing?

Why is there no unavoidable significant adverse impact for the increase in wastewater discharges and the increased risk of future spills? At the very least, these are guaranteed during many flood scenarios (ie., there is probably no way to make the RRCSD completely safe during all flood scenarios)?
It is simply not adequate to say an impact is mitigatable if it appears in the Sonoma County General Plan EIR. That is merely an easy way out. The Study Area is located in an environmentaly fragile zone and that is either not adequately dealt with in County documents or often ignored when it is. One example is a section of River Road about 1/3 mile east of Rio Nido that was being threatened by bank erosion for many, many years and the County did nothing about it. When the bank blew out, taking half the road with it, the County could then apply for emergency disaster funds to pay for fixing it. Someone could have been killed in that situation, yet nothing was done until disaster hit. The County manages many situations that way, so merely citing county documents as mitigations is not adequate.

List of Attached Documents.....
1. Instant Democraphics by CACI Marketing Systems: Oct. 23, 1997
2. Letter to Brenda Adelman from Wagstaff and Associates plus attachment, Dec. 3, 1999
3. Chromated Copper Arsenate by Caroline Cox in Journal of Pesticide Reform, Spring, 1991, pp 19-23
4. HESIS Fact Sheet No. 11, Hazard Evaluation System & Information Service, Revised Feb. 1990
1 Dangers of the extensive use of CCA Pressure-treated wood in houses being elevated in the Sonoma County flood elevation program plus attachment, by Dennis Davis, April 10, 1998

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