Northern California Environmental Defense Center

11220 Occidental Road
Sebastopol, California 95472
Facsimile 707-527-5443

Kimberly Burr, Esq. -- 707- 887-7433
James Doyle, Esq. -- 415-924-9090
Jack Silver, Esq. -- 707-527-8811
David Weinsoff, Esq. -- 415-460-9760

January 12, 2000
VIA FACSIMILE & U.S. MAIL Tom Bane
Sonoma County Community Redevelopment Commission
1440 Guerneville Road
Santa Rosa, CA 95403

Re:Russian River Redevelopment Program Draft Environmental Impact Report

Dear Mr. Bane:
After having studied the Draft EIR for the Russian River Redevelopment Program, I am submitting the following questions and concerns to be considered during the drafting of the Final BIR. The comments and questions are generally relevant to all the alternatives studied except the no project alternative.

Cumulative Impacts
Has the County's General Plan Update FIR, upon which cumulative impacts analysis is based in this Draft FIR, become final and been approved?

There are several significant unmitigated environmental impacts identified in the Draft FIR. Please explain why these may be deemed acceptable?

The Russian River is impaired by sediment. The lead agency must; therefore adhere to a zero net discharge policy with respect to sediment, and must base its choice of alternatives and mitigations accordingly. Which alternative results in aero net discharge to the river?

Several aspects of the redevelopment plan will impact riparian areas. What is the biological value of mature riparian areas in this county and the state? What areas are considered critical? What rational was used to suggest that restoration and pollution credits are the equivalent of removing rare habitat and bank stabilizing vegetation in the long and short term?

What is the extent of the threat of destruction to historic buildings, sites, cultural resources i.e. archeological, palentological, etc.

Does the lead agency consider that spoliation of the river by up stream land uses, and users, a factor in the determination of blight? If so, where in the redevelopment plan is this addressed?

Tree free paper
It is unclear if the General Plan amendments (zoning changes to K) to mentioned in the Draft FIR will or will not remove the combining districts currently designated. This is an important issue and should be fully analyzed.

Wastewater
Are the plans to construct a Monte Rio waste water treatment facility based upon current need and population or future? If it is constructed, by what authority and via what funding, will it accomplished? When does the SCCRC anticipate this construction will begin?

In the absence of a Monte Rio collection and treatment system, and the highly uncertain future of such a system, the redevelopment plan should limit itself to growth and development within existing limitations and structures.

Blight
On what basis does the Draft EIR conclude that these communities pose physical or economic liabilities to the county?

What distinguishes blight from rural, blight from small town, blight from low income, and blight from successional community?

Has a survey been taken to poll the need and desire for redevelopment in the communities targeted for redevelopment? If so, what were the results?

The examples of "blight" in the appendix demonstrate that restoration and renovation is taking place in these communities. What justification is there for speeding up the pace of growth in these communities?

Are trailer parks and one lane roads properly factors in determining blight?

On what basis does the Draft FIR conclude that the blight in these communities cannot reasonably be expected to be reversed or alleviated by private enterprise or government action or both?

Funding
What is the current budget for the redevelopment described in this Draft FIR? Can that budget increase in the future?

Is there a limit on the budget for this redevelopment program?

Who benefits from redevelopment? What projections have been made that describe the economic benefits to the current residents i.e. employment related to redevelopment, employment resulting from redevelopment? What projections have been made that identify the likely beneficiaries of contracts with the county, state, federal governments associated directly or indirectly with this redevelopment program?

What funding sources other than the tax increment are expected to be a part of the redevelopment of these communities?

Are Federal monies expected? How much?
Are state funds expected? How much?

Are private funds expected? How much?

What percentage of the total funding is planned for road work (estimates are acceptable)? What percentage of the total funding is planned for sewer improvements in Guerneville? What percentage of the total funding expected is planned for Monte Rio sewer projects?

From which sources will operation and maintenance of the waste water treatment plants, if they are improved or constructed funding come in the long term?

It is unclear from the Draft FIR what specific geographic similarities exists between all the communities included in the Draft FIR? What impacts will be similar for all those communities?

If the redevelopment program is approved, what process will be used to select the owners and operators of the lodging proposed in the Draft FIR? What process will be used to select the properties to be developed with residents? The contractors?

Thank you for the opportunity to comment on the Draft FIR. If there is an extension of the public comment period beyond January 12,2000 or a re-opening of the comment period, please bring this to my attention.

Very truly yours,
/s/ Kimberly Burr
Kimberly Burr

As a member of Northern California River Watch, Forest Unlimited..., and Sierra Club

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