Saturday, 25 June 2022

Ravenwoode: Concerns about Plum Flat Subdivision

According to a county staff report dated July 8, 2010, the developers of Plum Flat Subdivision are requesting a rezone from rural residential, (RR) (low density) to planned development residential (PDR) (high density) to construct a residential subdivision on a 105-acre parcel.


And if the added request of a general plan of development is approved, their initial 30 parcels can expand to 104 with the approval of a specific plan of development.


Increased residential density: This increase in density requires a full environmental impact report to inform the surrounding community as to whether this project will create significant environmental impacts.


Discrepancies: All parcels immediately surrounding this project, are zoned either RR or rural lands (RL), or have potential agricultural use as indicated by a grading permit issued for a vineyard; and the existence of a walnut orchard to the north. Due to these immediate zoning differences and agricultural possibilities, a full EIR should be completed to protect agricultural land and reduce urban sprawl.


Lack of Infrastructure: While the developer vacillates between a community or individual septic system, the most obvious problem is that currently, no infrastructure exists. Combining this problem with a speculative water supply, shows this Project needs more planning and a full EIR, to inform and allow public comment on “how” waste water will be treated; “where” the water supply will be found; and “where” the related municipal water system will be located within the project. In addition, how will the water supply use affect the surrounding Clear Lake Rivera water quantity and quality.


Access: How can “potential environmental impacts related to traffic and circulation be mitigated to insignificant levels” (page 17 (A) (3), if there has been no final decision on access to the project. All possibilities for access, (and a through traffic study on each alternative) should be documented in a full EIR for public comment and review.


Absence of California Law regarding Oak Woodland Protection: The California Laws which govern Oak Woodland Protection include the: California Environmental Quality Act, Professional Foresters Law and Public Resources Code Section 21083.4.


California Law regarding Oak Woodland Protection: The definition of an “oak woodland” has been determined by the Board of Forestry and Fire Protection as: “any significant stand of oak trees, with a canopy cover of 10 percent or greater.” The Board of Forestry has the authority to regulate oak woodlands at the local or state level. The most important aspect of the Board of Forestry definition is how it applies to the California Environmental Quality Act (CEQA).


Under California law, when a local jurisdiction is making a determination involving CEQA, they must ask: Does this Project have a “potentially significant impact” on oak woodlands? The staff report dated 7/8/10 for the 7/22/10 Planning Commission hearing does not address this question. Under California Law, only a Registered Professional Forester (RPF) can legally and accurately answer the above question.


Therefore, greatest need for a full EIR is to answer the above question regarding the 70 acres of oak woodland habitat and seven acres of mixed oak woodlands within the Plum Flat project boundary. The removal of 77 acres of native species for a high density subdivision requires a determination by an RPF under CEQA.


Conclusion: Deny the request for rezone and general plan of development and deny any proposal for adoption of a mitigated negative declaration. The only legal way to move forward on this project is to comply with CEQA, which is a public disclosure document, and require a full EIR on this project.


Anna Ravenwoode lives in Kelseyville.

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