March 29, 2022 – Sonoma Land Trust has submitted detailed comments on the Notice of Preparation to Permit Sonoma, the planning body for the Sonoma Developmental Center (SDC), as part of the Environmental Impact Report (EIR) process. In addition, Sonoma Land Trust is offering to partner with the county and the state to conduct the necessary detailed studies to document wildlife concentrations and movement at SDC.
“The negative ramifications of an incomplete and inaccurate Environmental Impact Report are often substantial and irreversible,” said Eamon O’Byrne, executive director of Sonoma Land Trust. “While we applaud the state’s focus to protect biodiverse areas and provide affordable housing, we feel the current SDC redevelopment proposals, as outlined, devastatingly fall short to do either. We believe there is a planning and development path that will support this unique piece of land ecologically, while providing support for those in need of housing.”
As outlined in the letter, the Notice of Preparation for SDC was developed to meet the requirements of the California Environmental Quality Act (CEQA) but fails to do so. The letter also details what the EIR for SDC must address, including the following:
- The EIR must include a complete analysis of the environmental impacts of various types of development within this proposed range and must include these project variants in its core analysis rather than as alternatives to the project. The Notice of Preparation states that the SDC project will consist of between 450 and 1000 residential units. It does not provide specific details about the location or intensity of proposed uses at the SDC.
- The State’s own 2019 governing legislation and the Plan’s adopted Guiding Principles require preserving the SDC’s ecological resources, including the Sonoma Valley Wildlife Corridor. The EIR must accurately describe wildlife’s use of the Corridor and the SDC site and conserve and enhance irreplaceable habitat areas. The EIR must employ the latest scientific tools, datasets, and studies so that the public and decision-makers may fully understand, design around, and mitigate for development impacts to SDC’s ecological resources.
- The Sonoma Valley Wildlife Corridor serves as a critical linkage in a larger corridor from coastal Marin County to eastern Napa County. Because of its regional significance, analysis of cumulative impacts on the Corridor should include an area that is large enough to account for the movements of local populations of the widest-ranging species present (i.e., mountain lions) and evaluate the impacts of all the different types of development proposed for the property that will impact the permeability of the Wildlife Corridor and the ecosystem services it provides.
- The project must incorporate appropriate buffers between development and sensitive habitats, such as watercourses and wetlands, to protect the ecological value of the SDC site and the Sonoma Valley Wildlife Corridor. This may require the removal of existing, unused structures. Buffers will be particularly critical to protecting the species that rely on the Wildlife Corridor.
- The County must analyze wildfire risk and plan for safety to preserve the ecological value of the SDC site and the Sonoma Valley Wildlife Corridor. The County cannot approve development that would require vegetation management in areas (or to a degree) that would negatively impact the Wildlife Corridor or build new roads that will fragment intact habitat areas and eliminate or significantly disrupt wildlife use.
- The EIR must consider how development at SDC will increase future water demand at the regional scale and analyze the resulting ecological impacts from such water use. The EIR must consider the water use impacts on sensitive aquatic resources and groundwater, especially during drought conditions, and evaluate how these impacts will affect fish and wildlife that rely on local water sources for survival.
To view the full letter to Permit Sonoma, please visit: https://sonomalandtrust.org/current-initiatives/sonoma-developmental-center/