#1 Comply with the California Environmental Quality Act (CEQA) as interpreted by the state supreme court in the recent Banning decision. That requires the City, as lead agency, to coordinate and collaborate on the Draft Environmental Impact Report (DEIR) with other key government agencies now, not later: the Army Corps of Engineers, US Fish & Wildlife Service, California Department of Fish & Wildlife, Sonoma County Regional Parks, and the City’s own Site Plan Architectural Review (SPAR) process. California Environmental Quality Act (CEQA), is a statute that requires state and local agencies to identify the significant environmental impacts of their actions and to avoid or mitigate those impacts, if feasible. Because of CEQA, the City is analyzing the 2017 Draft Environmental Report (DEIR) on the Davidon Development. The recent unanimous Banning decision by the California Supreme Court states the all affected agencies need to confer before a development receives approval from the City. We have discovered that the critical 2013 document from California Department of Fish & Wildlife (CDFW) was not considered in preparing the 2017 Davidon DEIR. As of May 15, 2017, the following agencies have not responded to the Davidon DEIR. Army Corps of Engineers (ACE) US Fish & Wildlife Service (USFWS) California Department of Fish & Wildlife (CDFW) Sonoma County Regional Parks Petaluma's Site Plan & Architectural Review (SPAR)* * The purpose of SPAR is to secure compliance with the Zoning
Ordinance and to promote the orderly and harmonious development of the City of Petaluma. #2 Carefully review the factual evidence, community standards, potential consequences, and alternatives contained in the public comments submitted on the 2017 DEIR, as well as the 300 comments on the 2013 DEIR that still pertain to this virtually identical housing project. Many of you wrote comments on the 2013 DEIR. We discovered that none of these comments were considered in preparation of the 2017 DEIR. Therefore, we submitted those comments again. We encouraged you to submit your 2013 comments again plus write 2017 comments. When reviewing the 2017 housing project, we discovered that the 2013 housing project was virtually identical. Some slight adjustments were made in 2017, however, the public comments were ignored. #3 Reject the Scott
Ranch/Davion 2017 DEIR as incomplete and inadequate. Require updated
professional studies and analysis of biological, traffic, hydrology, and other
impacts and recirculation of a new, revised DEIR for public comment. These
issues cannot just be addressed in the Final EIR. The DEIR is so
fundamentally inadequate that CEQA requires the preparation and recirculation
of a new revised DEIR. These are just a couple of the inadequate items that we discovered in reviewing the 2017 DEIR:
#4 Reject Davidon’s proposed amendments to Petaluma’s 2025
General Plan. The amendments would undermine the City’s general plan
solely so Davidon could build more houses on this land. #5 Accept the unanimous recommendation of the City’s
Planning Commission: there must be no housing units constructed
south of Kelly Creek, given the critical wildlife habitat and unstable
hillsides there and the extreme difficulties of accomplishing effective
mitigation. #6 Ensure any approved Davidon project is consistent with all
Policies in the City’s 2025 General Plan. As currently proposed, 35
lots violate General Plan policy mandates. Compliance with the 2025 General
Plan would reduce the development footprint from 63 to fewer than 30 housing
units. (See attached table and map prepared for Kelly Creek Protection
Project.) In the revised DEIR, specify the additional lots that must be
eliminated to mitigate the environmental impacts caused by the Project’s
violations of the General Plan. #7 With $4 million in charitable funds now available, do
not lose the opportunity to negotiate the purchase, at fair market
value, of some or all of Davidon’s property interests, recognizing the
development constraints of this site. The goal is to extend Helen
Putnam County Regional Park down to D Street and ensure environmentally-sensitive
recreational access. #8 Tell Davidon the handwriting is on the
wall. Encourage them to meet and confer with Kelly Creek Protection Project (KCPP), Petalumans for Responsible Planning (PetRP), the City
and the County and to discuss in good faith, as a willing seller, a
solution that benefits all parties. You know what this means! |
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