17600 Morgan Valley Road
Lower Lake, CA 95457
May 20, 2005
To: RMM Environmental Planning
From: Marie Pritchard
Re: Provinsalia Development, Clearlake, California
You have asked for comment regarding the scope and content of the environmental information to be addressed in the EIR. The information that was sent stated the Initial Study was attached, it was not. I requested a copy be sent over a week ago but have yet to receive it. Therefore I might have addressed other issues but lacking this study was unable to do so. The following are my comments:
Summary of the Project Within your Notice of Preparation (NOP) and Environmental Checklist Form (ECF) as well as other documents prepared conflicting information is being presented. Also in some areas information insufficient in detail hampers the readers ability evaluate and comment. For example:
Agricultural Resources The ECF dismisses agricultural uses of this property without mentioning vineyard potential. Vineyards are well suited for this land and should be considered before reaching this conclusion. A vineyard already exists adjacent to this property and vineyard growth in Lake County within the past few years has been phenomenal so this is a viable option. The ECF further states that it is unlikely that this project will conflict with agricultural spraying. I work for a vineyard and know firsthand that residential development and vineyards donıt mix. I assure you that this project will put homeowners at odds with the neighboring vineyard when it comes to spraying, noise, nighttime operations and dust. This clearly will impact that vineyards economic value or utility and is significant.
Air Quality It is stated that exposure to short-term construction-related air pollutant emissions will not impact the elderly since this is a ³semi-rural area and the preponderance of City of Clearlake population is approximately one mile to the West. First, this is a ten-year project not ³short-term construction, this means ten years of disruption to surrounding neighborhoods. Second, there is a senior mobile home park within spitting distance of this project. The elderly will be impacted when this is in their backyard.
Biological Resources All of the studies reviewed for plants and animals on the site failed to identify the river otters who enjoy the banks and waters of Cache Creek. Lowering the water and disturbing their riparian habitat will be significant. It is stated that housing and the golf course cover 215 acres and the remaining 77 acres, some of which have slopes of 40% or greater, are to be "public open space". Further, this open space will include a mapped trail system, nurseries and wildlife corridors while at the same time inviting the exploration of the area by children as well as hiking and biking area for everyone. Wildlife and people are not compatible, therefore this will not provide a home for wildlife. Planting new oak trees to replace gigantic old oaks will not provide a home for wildlife and does not mitigate the impact the removal of old oak trees will have on wildlife. This is significant.
Cultural Resources Native Americans need to be contacted and included is the evaluation of cultural resources. Our local tribes now have their own professional Environmental Officers and they should be included in this process. Have they been provided detailed information about this plan?
Hydrology and Water Quality Since this projectıs property line is in Cache Creek I believe the County of Lake should be directly involved in the permitting process. The water and land on the unincorporated side of the creek (County of Lake) is clearly impacted by this project and beyond that the drawdown on Clearlake itself impacts everyone in the county. Frankly I am shocked that anyone believes it's all right to provide water for this massive development, and in particular an 80 acre golf course, by drawing water from Cache Creek. You state, "This is permitted through Yolo County Flood Control and Water Conservation District". The water for this development and Yolo County comes from Lake County. Watering an 80-acre golf course with our water is reminiscent of the golf courses and decadent water features built in Las Vegas because they tapped the Colorado River. Almost daily we read that a water crisis is looming in our future. Please have the EIR justify this waste.
Land Use and Planning Again conflicting statements are made about the use of this land. In one place it is stated this is a ³semi-rural area and the preponderance of City of Clearlake population is approximately one mile to the West². This conflicts with the statement that, ³The project site is at the eastern periphery of the City and constitutes a logical extension of urban density and intensity of land use². Well thought out General Plans apply zoning to a community in such a way that housing is centered around amenities such as water, sewer, stores, fire departments and police thereby making it easy to provide needed services. Then the surrounding more rural areas, in this case one mile away with only bare bone city services, are zoned to create larger parcels so that rural farming, minimal housing and open space exist. This logical design provides habitat for wildlife and an open space buffer zone to separate communities. Somehow Clearlakeıs General Plan failed to recognize the value of this concept. I understand that this land was zoned Agricultural before the General Plan was adopted. I am astonished that it was ever zoned to allow for a density of 46 people per acre like it is now. Itıs time to back the truck up and explore revising the General Plan and zoning this property something equivalent to Lake Countyıs RR (Rural Residential) zoning.
Recreation Inclusion of public access to Cache Creek is an idea worth exploring in the ³mapped trail system² which will be available to the public. Something that is not clear here though is does ³public² mean everyone or only the public who will live in this development? Is this to be a gated community?
Transportation/Traffic Again, lack of detail leaves the reader wondering just where the two roads required for this project will be. I assume one is Dam Road, where is the other? Comment is difficult without knowing this information. The information provided fails to acknowledge the impact of traffic on Middletown and Highway 29 over St Helena then on to Santa Rosa. This is not a trivial impact it is major. If the EIR is to ³take account of the whole action involved, including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct², then it will fail unless it include these areas in the traffic and transportation evaluation. I believe that car lights and noise impacts should also be evaluated for residents along Dam Road and Lake Street. Residents of this development with the increased number of vehicles being driven as they commute to Santa Rosa, will be driving during dark periods with their lights on and clearly impacting the quiet neighborhood environment which presently exists. By the way please correct your information, it is Lake ³Street² not ³Boulevard².
Thank you for considering this information. I look forward to reviewing the forthcoming EIR.
Members, Lower Lake Watershed Group
The Sierra Club
The Clearlake Observer American
Members, Clearlake Planning Commission
Members, Clearlake City Council
Ed. Robey, Lake County Supervisor