On January 25, 2022 the Sonoma County Board of Supervisors (Board) will provide guidance and comment on a “project description framework” for the redevelopment of the 180 acre historic campus at the Sonoma Developmental Center (SDC). The Board will review a presentation from Permit Sonoma staff and their consultants that recommends a planning framework for “a mix of civic, residential, commercial, and institutional development” including 1000 new homes and “1,000 new jobs created from new local-serving retail, office and visitor-serving uses.” After receiving comment from the Board, Permit Sonoma will then “refine a project description and evaluate it as part of the project’s draft Environmental Impact Report (EIR).”

The “project description” is a legal term used in the California Environmental Quality Act (CEQA) that means “the whole of an action, which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment…” The reason why the project description is so important is that it forms the foundation for evaluating the potential environmental impacts of all the different aspects of the SDC Specific Plan. The staff proposal that the Board is considering has not gone through any level of rigorous environmental review, and so the specific, likely impacts of the proposed development on concerns such as water quality and quantity, the Sonoma Valley Wildlife Corridor, climate change resilience, traffic, fire safety and the rural character of the surrounding area have yet to be identified and studied.

Once the project description is finalized, the county will release a “Notice of Preparation” and Initial Study for the Draft EIR. The minimum content requirements for the Notice are:

• Description of the project
• Location of the project indicated on an attached map
• Salient environmental issues
• Probable environmental effects of the project
• A copy of the Initial Study which is a preliminary analysis conducted  to determine if a project may have a significant effect on the environment.

According to the schedule in the staff report, the Draft EIR and Draft Specific Plan will be available for public review by June 2022. The Planning Commission will then hold two public hearings to receive public comment on the draft EIR in July 2022 and to potentially adopt a resolution in August 2022 recommending that the Board of Supervisors consider certifying a final EIR and adopt a final Specific Plan. Ultimately, the Board of Supervisors may consider certifying a final EIR and adopting a final Specific Plan in September 2022.

The Sonoma Land Trust has submitted the following comments to the Board on the project description framework and we urge you to contact your Supervisor to share your thoughts and concerns about the SDC Specific Plan by filing online comments at: https://sonomacounty.ca.gov/Board-of-Supervisors/Contact-Board-of-Supervisors/. Once the Notice of Preparation is issued, we will provide more information about the CEQA process and how the public can effectively comment during the preparation of the Draft Environmental Impact Report.

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January 24, 2022

RE: SDC Specific Plan Project Description Framework

Dear Sonoma County Board of Supervisors:

SDC provides an opportunity for a major win for two critical state and county priorities: creating more affordable housing and using nature-based solutions to adapt to climate change. There is broad community support for zoning the most significant affordable housing project in the history of the Sonoma Valley at SDC (450 +/- units), and for creating the largest addition to our state and county park system in decades with precedent-setting land use protections for the wildlife corridor. That’s why we support the North Sonoma Valley MAC and the Springs MAC proposals as the starting point for the project description, as they have a more reasonable development footprint and density and 25% more affordable housing than what has been proposed by the county.

We are particularly alarmed at the proposal for an additional road linking Arnold Drive to Hwy 12 to allow for increased traffic from up to 1000 new homes and 1000 new jobs on the campus. Our decade of research at SDC indicates that this would severely damage the Sonoma Valley Wildlife Corridor. The new proposed road would also run right through the community separator that Sonoma County residents put into place through Measure K to prevent the intensification of development and ensure land within community separators remains open and retains its rural character. Constructing such a road to facilitate increased development at SDC would conflict not only with the intent of Measure K but with many other goals and policies of the County’s General Plan calling for protection of open space and agricultural land.

While we understand that the California Department of General Services (DGS) has repeatedly refused to accommodate any requests for adjustment to the planning schedule, we believe that failure to do so will simply condemn the whole process to protracted litigation. This will harm the health of the wildlife corridor and postpone much-needed affordable housing in the County. Finally, we urge the County to partner with community groups and the Governor to support a greater state investment in the future of SDC. Facing the twin crises of climate change and affordable housing, a new paradigm is essential. This is implicitly recognized by the line item in the Governor’s proposed budget request for $100M in funding to promote the conversion of surplus state property into affordable housing sites.

Thank you for your consideration of our concerns.

Eamon O’Byrne

Executive Director