" FRIENDS of the RUSSIAN RIVER "

P.O. Box 1903, Sebastopol, CA 95473

The mission of Friends of the Russian River is to preserve, restore and enhance the natural systems, and the economic and public trust values of the Russian River, its riparian corridor and the watershed that sustains it. We do this through citizen action, public education, scientific research and expert advocacy

DATE: January 12, 2000
FROM: Joan Vilms, President
TO: Tom Bane, Community Development Department
Cc: Mike Reilly, 5th District Supervisor
SUBJ: Russian River Redevelopment Program DEIR Pages: 4 (including this one)

GENERAL COMMENTS
Quoting from the first paragraph in Section 15 (page 15-1), "The Russian River redevelopment program raises...concerns, because it would facilitate additional development in a river valley surrounded by steep slopes and gullies, abundant natural vegetation, [seasonal flooding], and seasonally dry and windy local climatic conditions." Despite these "concerns", the DEIR overlooks significant impacts such as increased flood hazard exposure. In addition, all but 3 of the dozens of impacts identified as "significant" are downgraded to "less than significant" through mitigation measures. Many of which are inadequate. Some have no track record of effectiveness and others have no guarantee of implementation.

This downgrading of impacts does not accurately predict the adverse impacts of total buildout or the growth-inducing impacts of redevelopment and new development outlined in the Program. The DEIR rightly assumes the "worse case" scenario to be complete buildout, but wrongly uses "best case" scenarios for mitigation measures. We strenuously object to rosy forecasts in the application of mitigation measures. It takes a large dose of wishful thinking to believe that the proposed mitigations would lessen to insignificant the biological impacts of substantial growth and development on the Russian River, on wildlife populations, and on native plant communities, including riparian vegetation and roadside forests. Regarding growth-inducing impacts, it is naive to think that significant increases in jobs and tourism will not have significant long-term growth-inducing impacts on the region and the County.

The DEIR accurately states that Program buildout will have significant adverse impacts to vegetation and wildlife. However, in every case, significant impacts ("S") are reduced to less than significant impacts ("LS") by relying on government policies and best management practices to mitigate adverse impacts. Downgrading "significant" to "less than significant" is unjustifiable unless evidence exists in Sonoma County to suggest that such policies and practices provide sufficient protection to eliminate significant impacts. Where is that evidence? We suggest that much evidence exists to the contrary based on the sediment-laden condition of the River, the lengthening lists of rare and endangered species, habitat fragmentation, questionable water supply, and wastewater problems. These are examples of the growth impacts and biological danger signals that are miraculously waived away in this Report. What miracle is going to render buildout of this Program immune to the adverse impacts of habitat reduction, erosion, water pollution, increased flood hazard, and competition for water supply?

Mitigation measures that rely on phrases such as, "shall avoid disturbance to the greatest extent possible" are ineffective and toothless. Such statements instill no confidence that the resource will be protected. In fact such statements reveal an underlying presumption that development will occur regardless of the detrimental effects and that, as long as we save a tree here and a shrub there, the impacts will be less than significant. Saying "less than significant" does not make it so. In fact, under the legally mandated "worse case" scenario of complete buildout, the impacts are more likely to be significant and unavoidable. Significant adverse impacts are either avoided or not. Period. If not avoided, the impacts will be "SU", not "LS". Since when does resolving conflicts between development and nature in favor of development result in "less than significant" impacts? Please cite examples.

The DEIR consistently provides inadequate justification for downgrading significant ("S") impacts to less than significant ("LS") ones in assessing the affect of Program impacts on the health of the Russian River, the watershed, and related plant and animal communities. We request that impacts to these systems be reassessed from a more realistic and nature-based perspective.

SPECIFIC COMMENTS
Impact T-2: Secondary Tree Loss Impacts
1) How does referring and deferring to the County Tree Ordinance do anything to fully mitigate the biological, climatic and scenic effects of tree loss? How could the Tree Ordinance, inadequate as it is, accomplish these miracles?
2) Where is the evidence to document that the impact would be other than significant and unavoidable?

Impact T-4: Secondary Tree Loss Impacts
1) How does referring and deferring to the County Tree Ordinance do anything to fully mitigate the biological, climatic and scenic effects of tree loss? How could the Tree Ordinance, inadequate as it is, accomplish these miracles?
2) Where is the evidence to document that the impact would be other than significant and unavoidable?

Increased Flood Hazard Exposure
1) The DEIR states that no significant impact has been identified and no mitigation is necessary. It defers to the General Plan as having fully considered such impacts. How can this be the case when (a) the Program includes 6 General Plan amendments intensifying land use and accommodates an increased number of residential units, (b) the General Plan pre-dates an increase in frequency of flooding, and (c) most of the Program area lies in a flood plain?
2) Why isn't relocating development out of the flood plain considered (a) part of the Program and (b) a Program alternative?

Impact W-1: Erosion, Sedimentation and Urban Runoff Pollution
To determine the impacts of the proposed Program, the DEIR states that it compares existing conditions before development to projected conditions after development. The Russian River is currently listed with EPA and State Water Quality Control Board as an impaired river because of high temperatures and sediment. This salient fact has been omitted from the DEIR. Nevertheless, because of this baseline impaired condition, the River has zero tolerance for further degradation. How, in a zero tolerance situation, can any mitigation change the adverse impacts of increased sedimentation and other pollution from significant to less than significant?

Impact SG-1: Slope stability and Erosion Hazards
1) Where is the evidence, based on the project area's past history of instability and risk, that the mitigations offered provide anything more than false security?
2) Doesn't the preponderance of evidence suggest that risks and costs of developing slopes over 25-30% in a fragile watershed are contrary to public interest?

Impact PS-1: Water Supply Demand Impacts
1) How does relying on "water conservation" to accommodate growth not put future human and wildlife populations at risk from water shortages? The problems and issues of water supply have not been adequately addressed. 2) How does deferring to County Policies adequately mitigate water supply demand impacts on the Russian River, its tributaries, and related aquatic and terrestrial life systems? Are their needs factored in? Where is the analysis of baseline conditions, the future impacts of buildout on these systems, and the proof that government resource protection policies actually work to achieve their intended goals?

Impact VW-1: Riparian Corridor Impacts
1) How does deferring to County Policies adequately mitigate riparian corridor impacts? Where is the analysis of baseline conditions, the future impacts of buildout on these systems, and the proof that government resource protection policies actually work to achieve their intended goals? 2) Where is the evidence that "replacement" mitigates loss?
3) What happens to the wildlife this habitat supports between the time of damage or elimination and "replacement"?
"Replacement" is an inaccurate term because it implies temporary disruption, when in fact the displacement is permanent, significant, and unmitigateable. Riparian habitat along the Russian River and its tributaries provides significant habitat for wildlife 24 hours a day, 365 days a year.

Impact VW-2: Aquatic Habitat Impacts
1) How does "avoid[ing] disturbance of aquatic habitats to the greatest extent possible" or "minimize[ing] impacts to aquatic habitat" actually avoid or mitigate loss?
2) Don't those statements say that, in the contest between wildlife and development, development wins?
3) Where are the teeth, the guarantees, of actual protection?
4) If such assurances cannot be provided, how can "significant" impacts be downgraded to "less than significant"?

Impact VW-3: Plant and Wildlife Species Diversity Impact
1) How does the toothless statement of "using native plants shall be encouraged to help offset the cumulative loss of habitat" justify downgrading of "significant" impact to "less than significant"?
2) Doesn't any loss of species diversity along a system as fragile and impaired as the Russian River constitute a significant loss that can't be mitigated?

Impact VW-4: Special Species Status
1) How does "avoid[ing] impacts to special-status species and their habitats where possible" actually avoid or mitigate loss?
2) Don't the proposed mitigations really say that, in the contest between special status species and development, development wins?
3) Where are the teeth, the guarantees, of actual protection?
4) If such assurances cannot be provided, how can "significant" impacts be downgraded to "less than significant"?

Impact VW-6: Cumulative Loss of Biological Habitat
1) See comments to VW-1 through VW-4 above.
2) Who has the burden of proof to demonstrate that the proposed toothless mitigations, even if followed, would be effective in preventing significant cumulative loss of biological habitat?

Impact 15.2: Secondary Visual and Biotic Impacts of Fire Management
The significant impact identified states, "vegetation clearance may also damage wildlife habitat".
1) Why "may" and not "will" damage habitat?
2) This significant impact is not mitigated by plans and landscaping. Vegetation clearance is an abrupt elimination of established upland habitat. It cannot be adequately replaced or mitigated. The habitat has vanished and displaced wildlife have nowhere to go, thus increasing stress and disease in the system.

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