October 25, 2005
Michael Delbar , Chair
Mendocino County Board of Supervisors
501 Low Gap Road
Ukiah , CA   95482

Chairman Delbar

What follows are my 14 summary comments on the Ukiah Valley Area Plan (UVAP )   EIR and a detailed comment on the Cultural Resources component.

Thank You

Antonio Andrade

UVAP Comments

1) The EIR does not assess the cumulative impacts of the installation of multiple private septic systems on ground water and the valley aquifer under the scenario of a complete build out-a build out which would include both the existing and the building lot creation anticipated in the EIR.

2) There is a lot of talk about reclassifying lands in the EIR.  One primary cumulative impacts issue I don't recall being covered is what is the build out allowed for under the existing plan (in the UVAP area AND the City of Ukiah ).   That is, what is the aggregate total of buildable lots in the study area, including those that currently exist and those that have been added in the UVAP.   The existing build out and the build out allowed for under the reclassification of land must be combined. This is a crucial cumulative impacts issue that needs addressing.

The EIR projects a population increase of 8705 in the unincorporated area of the UVAP by 2025.   This population growth translates into a need for over 4000 new residences in the next 20 years.

How many buildable lots already exist in the unincorporated area? How many are being added under the UVAP? How many sewer hookups exist?   How many water hookups will be available? These elements need to be interconnected to understand what we are planning for and what we have the capacity for.

Note, we have perhaps 2500 residential units already projected from developers in this unincorporated area over the next few years.

3) There is no map of the various Water and Sanitation Districts and no analysis by District in the UVAP .  Using the Millview Water District as an example,

• What is the build out planned for within the parameters of the Millview  Water District ("2" above)? 
• How many water connections will be needed at buildout
• How will sanitation be handled within the District boundaries:   Private Septic Systems? Ukiah Sanitation District Hookups? A combination of both?)  

The EIR is designed in a way that it is difficult at best to be able to look at all of these projections to determine if they are possible to be realized given the available resources and infrastructure

4) Mitigations have been offered but they are hard to assess because they are not arranged in a manner that

• correlates them with various service districts
• puts them in a cohesive format for comprehensive analysis purposes
• is integrated across the board

5) Because of items 2, 3, and 4, above, if this document goes forward, it will be a recipe for piecemeal development that will allow the 1st pig to the trough the right to whatever water is available, whatever the limits of the environmental degradation allowed, and the right to maximize the existing infrastructure and utilize the existing capacity--all to the detriment of the existing small taxpayer who has invested his/her resources into this community for years.  Big money will take it all and there will be nothing left when the individual wants to split his/her existing lot in order to develop it to get some return on their investment. 

6) The big picture issues here that have not been assessed are

• determining the carrying capacity of the Valley --how many people can this valley hold given resources available
• the quality of life we have in this valley and how that will be impacted with the level of development proposed.  We are given the impacts on the various parts or components that create our quality of life but they are not looked at as a whole

7) G iven what the population migration has been to the cities directly to the south of the Valley, the prudent approach here requires there be at least three population growth models (historical patterns of growth, moderately higher patterns of grown, and rapid patterns of growth) constructed and impacts of those three models reflected in the UVAP.  If not, the one-size-fits-all document is doomed to miss the planning and environmental impacts assessment goal and creates the need for more public dollars being spent on a revision in the future.

8) There has been no listing of the mitigations offered from the perspective of costs (let alone a fiscal analysis of the financial cost of the mitigations) or identification of who bears the costs.   The EIR assumes quite a number of costly mitigations in order to reduce impacts to "less than significant".  This gives the impressions these are economically feasible.  If local taxpayers will be asked to fund these mitigation measures, we need to be able to look at them collectively in order to assess their cumulative possibility.

9) It is interesting to note here when the EIR does venture into the area of funding additional fire protection, they talk about how many $400,000 homes it will take to fund a $60,000 fire protection position.  Are they saying:

• we are targeting $400,000 homes being built;
• there is nothing more to fire protection than the $60,000 position.  No wage inflation, no training, no maintenance, no new buildings, engines and equipment.  I think they are missing a big chunk here. 

10)  We are in the middle of a planning nightmare .  The County is reviewing and taking comment on its General Plan.  They are in the process of approving an Inclusionary Housing Element for lower income people.  They are in the process of revamping significant aspects of the Subdivision Ordinance which will change many of the land use descriptions used in the UVAP.  Then there is the UVAP EIR process.  There is a humungous tractor plowing its way right through the middle of these complex processes.  Right smack in the middle of these concurrent processes, we have 4 significant developments being proposed just north of Ukiah and at least two smaller scale developments South of Ukiah.  The projects North of Ukiah will require General Plan Amendments to what is being planned if they are to go forward. In effect, they will lay waste to the plans currently being evaluated.  Yet, none of these proposals are mentioned in the UVAP.   

11) The EIR does not acknowledge the Masonite facility as a place of historical
importance.
  

12) An analysis of the amount of water needed to operate a sanitation plant / to handle the raw material has not been assessed in the EIR-especially in the Calpella area.  

13) There is not discussion of  Healthy Lifestyle issues . Obesity is at almost epidemic proportions in the United States yet health of community residents is not discussed in the UVAP.   There has been a significant amount of research done on how community design (incorporating many of the Smart Growth concepts) which facilitates physical activity is perhaps the single most effective way of improving the overall health of the community.  Yet, as the UVAP designates various areas of development, there is no discussion on how that approach will affect the overall health of the community.

14) There is  Native American land in the UVAP.  It should be evaluated separately for its range of uses, including gaming.  

15) Regarding the Cultural Resources element, please note the following:

There is one significant error under "A .Setting". It says there are two Indian communities within the project area. The report fails to mention that the current Guidiville Rancheria is on Vichy Springs Road so there should be 3 Indian rancherias or reservations.

The report mentions that development would create " potentially significant impacts" on areas of archaeological or historical importance but that current mitigation measures would reduce impact to "less than significant level".

However - there is no budget attached to ensuring that the implementation of the mitigation measures is actually taking place. The measures rely heavily on volunteer commissions. For example - WHO will prepare the historical preservation guidelines and standards for adaptive reuse of residential structures? WHO will monitor whether the State Historic Building Code is applied to protect the appearance of buildings? WHO will follow-up to monitor whether land use applications are in fact sent to Sonoma State? WHO will prepare a list of cultural and historic resources worthy of nomination? WHO will maintain programs for the review and systematic archiving of public and private records? WHO is responsible for convening the Archaeological Commission to review applications? WHO are the current members of that Commission and how are they selected?

The only budget measure suggested is capital improvement funds for maintenance and enhancement of historic buildings.

The archaeological section is very weak. The edges of the Russian River and its tributaries were densely inhabited especially along the foothill areas. Of course, the constantly changing course of the River has erased many archaeological sites as has the impact of agricultural development. There are existing lists of archaeological sites both in the ethnographic record and in SSU archives.

The other aspect of cultural sites not well developed in the EIR are native plant and animal uses. For example, several Carex or sedge species are listed in the Special Status Species list as having the potential to be affected. Carex or sedge is a plant still used to make Pomo baskets. Some of these are listed as rare in California and rare, threatened or endangered in other parts of the country. This type of resource should be listed as part of the cultural resources as should any sacred or burial sites.