Comments Re: Russian River Redevelopment Plan EIR Submitted by:
Tom Cruckshank
Guerneville, CA 95446
(707) 869-0505
(707 869-5616 (fax)

I have the following comments regarding this EIR where I maintain the EIR is inadequate of fails to fully address situations in the project area.

I. I would like to add my opinion to the chorus of objections to the traffic impacts and the determined mitigation. You state that the impacts (T-2, T-4) to be unavoidable. This is clearly untrue. To avoid the impacts, you leave the highways alone. The need for highway improvement is there, however it is not feasible without major engineering and disruption which would be intolerable to the current population. This Redevelopment Program will only serve to exacerbate an already highly frustrating traffic situation in the project area. The traffic increase which would result from the proposed additional domiciles and resort development would cause further gridlock in an area which already experiences horrendous problems during many times throughout the year.

II. You state in Impact PS-1: ěIncrease demand for water diversion by the District from the Russian Riverî Your finding is that this is not significant. How can this be the case? The Russian River is one of the most impaired waterways in the United States. A very significant reason that this is the case is that the drainage is already under enormous pressure from water diversion. How can you find this impact less than significant when the anadromous fishery is struggling for itís very existence (and losing the struggle, I might add)? Have you considered the impact of the probable reduction and, in all likelihood, the eventual complete reduction of the diversion of water from the Eel River into the Russian River and what impact that will have on further allocations from the Russian River? To find that further diversion from the Russian River less than significant is irresponsible and unacceptable. The Russian River Watershed is already severely over-exploited.

III. Impact PS-3 Sewage Treatment Demand. I have followed the sewage issue in Guerneville and environs very closely for the past several years, attending most of the CAC meetings and meetings held by the SCWA and itís Board of Directors. You blithely refer to "Permits based on planned and approved additional collection, treatment and storage capacity". This is hardly a slam dunk situation. There are physical constraints which make it impossible to expand the RRCSD without engineering scenarios which are excessive, exorbitantly costly, and unacceptable. The Board of Directors of this District have been reluctant to face that the treatment plant was flawed from the start from design inadequacies. To wit, the system uses a gravity collection with booster pumps in a flood plain. Thus the system is continually violating the Clean Water Act during flood events. The discharge of raw or partially treated sewage into the Russian River has unfortunately become a commonplace event. The District is currently under demand from the NCRWQCB to address these discharges. It has already incurred fines from this Board which burden the ratepayer. These fines will continue and the mandates to address the problem will intensify unless and until the District faces the problems associated with even marginal flooding and its impact on the RRCSD. For this EIR to find that just adding "planned and approved collection", treatment and storage as less than significant ignores the larger and primary problem which I have outlined. This is an unacceptable impact and mitigation. Any further additions to the RRCSD are irresponsible and reckless until these problems are corrected.

IV. Impact PS-4 acknowledges that there is insufficient capacity at the RRCSD. As this is true, then, if and when further capacity becomes available, it should be allocated to domestic uses rather than business uses.

V. In the Vegetation and Wildlife section of the EIR, the drafters refer to mitigation by replacing disturbed or removed vegetation based on some kind of ratio or by using such ploys as mitigation banking. The environmental community is becoming tired of these inadequate approaches. Granted they are better than what was done in the past, but they still will never repair the natural habitat which existed prior to development.

VI. The prior comment is an apt segue into my strong objection to your consideration of developing the Skaggs property located at 16101 Neeley Road (General Plan Amendment site #2). I have resided at the above given address since 1974. Mays Canyon Road abuts this property. I have had the opportunity to view this parcel carefully during this time. Site #2 is the confluence of two creeks, the creek from the Mays Canyon watershed, and the creek from the Pocket Canyon watershed. The area where these creeks join is a natural bottomland and wetland. The site is very dense vegetation which provides for a great diversity of habitat for natural species. Both creeks have a history of having been spawning sites for anadromous fish. Disturbing this fragile ecosystem would result in a tragic loss to the natural world and shows great insensitivity. This property is one of the very first parcels to flood in the lower Russian River basin. It takes on water before practically any other property in the Guerneville area. During severe flood events, the property is part of the River. I have kayaked through the treetops and the amusement park (Jís) on several occasions, sometimes with more than 10 feet of water under my keel. Placing any additional structures on this property would appear to be foolhardy. What exactly are ětent-style cabinsî? This sounds much more like the definition of blight rather than the cure to blight. What will happen to these cabins when they are entirely submerged by the fetid, backwater from a major flood? I strongly object to the development of this site in any regard and demand that it be removed from consideration for a General Plan Amendment.

In conclusion, I would like to offer some general remarks and suggestions. This program EIR once again demonstrates that the business community is in control with little regard for the residents of the project area. The EIR is way too top heavy with the development side of redevelopment. If you really want to aid the community with redevelopment, I offer these suggestions:
1) Spend a large portion of the capital available on the ugly but necessary prospect of replacement of the gravity sewer collection system with a pressure collection system, being ever vigilant to design this system so that it eliminates any inflow when the system is inundated. This should include design for at least a 500 year flood event, as with the continued buildout that is occurring in the remainder of Sonoma County, flooding only will worsen in future years.

2) Abandon these foolish ideas of developing new resorts in the area, especially any that exist in the flood plain. Instead focus on elevating homes and business and aid to existing business. We already have several marginal resorts that struggle to survive. These proposed new businesses will suffer from the same seasonal occupancy as the existing ones and will hasten the demise of to the latter through competition. This will not further the needs of the region. I understand that certain local politicians might be seeking a trophy such as that planned at Site #3, but that is a high price to pay for a marginal improvement for the populace. The planned pouring of dollars into this Site #3 will result in a subsidy for a man who is already a multimillionaire. I hardly think this is an appropriate use for these funds and you can be certain that I am not alone with this opinion.

3) Any roadway improvements should focus on improving traffic flow. They should be highly sensitive to the aversion shared by the residents to any widening which would result in the loss of trees, vegetation and habitat. Please remember that you are dealing with a designated scenic highway.

4) The people who are drafting this EIR and concocting this project must realize that this area cannot sustain any more growth in the flood plain. The homes and businesses located in the flood plain should never have been constructed in the first place. They would never be approved today. They are a mistake. Constructing more homes or businesses in the flood plain is the height of improper planning. It is merely repeating the egregious errors of the past. The infrastructure is not there with a failed sewer system. Please put the RE back in Redevelopment and drop these plans for development.

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