California Department of Forestry and Fire Protection
P.O. Box 944246
Sacramento, California 94244-2460 Fax: 916.653-8957
Re: Written Comment/Kendall-Jackson Myers Timberland Conversion/JNA 97-384
Dear Mr. Robertson:
Western Sonoma County Rural Alliance appreciates the opportunity to comment on the above-referenced matter. Rural Alliance has been a leader in environmental advocacy in Sonoma County since 1979. Our work has included analysis and testimony in land use issues, contributing to the adoption and implementation of the General Plan and the Lower Russian River Specific Plan. For several years, we have followed with interest the proposed development on the old Bones Ranch. In order to prepare this response, we have reviewed documentation including the Draft EIR, and the Harrison Grade Study. We have attended the public hearing on the DEIR and held our own briefing with experts for the Board of Directors of Rural Alliance on the issue. As a consequence of this in-depth review, we have serious concerns as to the feasibility of the project and its immediate and long-term adverse effects on this unique area. Our concerns with the conversion include:
1. Lack of conformity with the Harrison Grade Study of the Sonoma County General Plan. From page 23 of the Harrison Grade Study, "Because of the serpentine geological formation, a unique botanical area has been created over thousands of years, resulting in an unusual array of plant species. . . [T]he California Native Plant Society states that the Sargent Cypress (Cupressus sargentii), a rare evergreen that grows only in very limited areas, thrives here. Also a unique form of manzanita (Arctostaphylos bakeri), now on the rare plant list, is found in these dry serpentine ridges in this part of Sonoma County. It grows nowhere else." (Emphasis in original) Far from the conclusions in the DEIR, our review indicates significant impact to this rare plant. Weíre also concerned about the omission of the Sargent Cypress from Table 4-1. Removal of Bakerís manzanita and other undisclosed serpentine endemics is not mitigated by establishing a 3-acre conservation easement. The protection of this fragment is inconsistent with the Sonoma County General Plan, which recognizes this plant community as rare and worthy of protection. In association with the development and the resulting vineyard, the botanical value and the quality of this site will be forever and irreparably damaged.
2. Hydrologic Modeling, Flooding, Erosion, Groundwater Recharge: Estimates of peak-flow and base-flows are unreliable due to inaccurate rainfall projections and inappropriate comparisons with San Antonio and Santa Rosa creeks which have different climates, geology, land use, and drainage areas.
In discussing flooding, the DEIR states the project will not have a significant impact on flood characteristics of the Russian River, but fails to address the significant impact that it will have on bank stability, sediment load, flood magnitude and frequency, which would significantly reduce the quality of instream and riparian habitat in Green Valley Creek.
Removal of trees and cultivation of soils will alter soil characteristics and contribute to erosion. Runoff from the project area will increase the frequency and severity of flooding in Green Valley creek resulting in stream bank failures and increased sedimentation. The impact of altered streamflows on aquatic habitat for salmonids, freshwater shrimp, turtles, frogs, etc., have not been adequately addressed.
Erosion control structures are undersized and will present a hazard to downslope properties. Appendix B, page 6, states the basins are designed for a 2-year, 24-hour storm and will only trap 70% to 80% of the sediment inflow. The study did not use accurate rainfall projections for the area (frequently twice the value used in the hydrologic model) and should recognize that an increase of 20% to 30% sediment into Green Valley Creek and the Russian River is very significant.
The elimination of forest will reduce groundwater recharge and throughflow, which currently provide water to the stream system after winter rains have ceased. The proposed timber conversion will eliminate interception of fog and rain by trees. In a healthy forest, intercepted precipitation slowly drips down the surface of the trees and percolates into the humus and through the soil and rocks along the surface of the roots. The impact of this loss is not acknowledged and cannot be mitigated. Compaction from vineyard activities will alter soil structure, thus affecting groundwater recharge.
3. Impact of loss of forest habitat on resident wildlife. A 1990 report from William. Imboden of Fish & Game notes: "The biologist identified a roosting area (for the spotted owl) which will not be cut." The presence of the spotted owl on this site was not noted in the present DEIR. As the owl was present in 1990, there exists a probability that its presence was simply not found during more recent surveys. It is possible, of course, that the absence of the spotted owl is due to the interference with habitat of the timbering at the site in 1990. In that case, the absence of the owl could be seen as a cumulative effect, unconsidered in this DEIR. We have, as well, concerns about habitat fragmentation for the red tree vole. We see no provision for ongoing monitoring of protected areas for any of the plants and animals listed in the DEIR. In this regard, we find that biotic surveys, both faunistic and floristic, were not adequate. We strongly suggest an exhaustive survey of avian, amphibian and reptilian species.
4. Effects of chemicals to be used to prepare and maintain grape vineyards. Should groundwater flow occur in the direction of neighboring wells, a contamination problem for adjacent wells by pesticides/chemicals used on the vineyard could result.
5. Impact on narrow, winding country roads of logging trucks and vineyard vehicles when children are present. The DEIR would restrict log truck traffic to between the hours of 8 and 5. Children are present in this rural neighborhood until after 8:15 a.m. and return from school shortly after 2 p.m.. Middle school students, however, return home later in the afternoon. It does not appear that contact with school administrators was made in order to determine hours when children and young people would be at school or en route. Observing these hours would necessarily increase the number of truckloads on these narrow, winding country roads and constitute an impact not addressed in the DEIR. It should also be clearly stated that there would be no weekend traffic whatsoever.
6. Failure to identify "No Project Alternative" as prescribed by CEQA. Development of a vineyard, reservoir construction, diversion of sheet flow, pumping of ground water and spraying of chemicals does not appear to constitute a CEQA-compliant no project alternative.
7. Failure to include monitoring of mitigations Under CEQA, all mitigations are required to be monitored. There is no indication of monitoring agencies, standards, schedules, nor enforcement procedures in the DEIR.
In conclusion, Rural Alliance finds the project is neither sustainable nor feasible, based on our review of the DEIR. This project would so dramatically alter the existing unique natural environment that rural Sonoma County would, contrary to the specific intent of the General Plan, lose an irreplaceable and pristine portion of its natural legacy. The far-reaching consequences of such a loss may be incalculable at this time, therefore we urge your rigorous review and skilled attention to this proposed conversion.
Very truly yours,
WESTERN SONOMA COUNTY RURAL ALLIANCE
CATHERINE SHARP, Board of Directors
JULIE SICAUD, Secretary
copies: Mike Reilly, Fifth District Supervisor
Mary Nichols, Natural Resources Secretary