PetRP Research of RDEIR

Biological resources

p. 4.3-2

The RDEIR states: “However, the findings of these studies that include information on biological and wetland conditions associated with the project site are still relevant for this analysis.”

“Biological Resources, Existing Conditions by Zander Associates (2003). This letter report summarizes biological and wetland resources on the site, including plant communities and wildlife habitats, special-status species, and wetlands. This includes the results of detailed surveys for special-status plant species conducted on March 12 and April 18, 2003 by Kelley Associates, protocol surveys for California red-legged frog conducted on May 30 and June 2, 2003 by Wildlife Research Associates, and the findings of a preliminary wetland delineation.”

p. 4.3-3

“California Red-legged Frog Protocol Surveys by Wildlife Research Associates (2003)”

p. 4.3-5

“Updated Biological Assessment by Zentner Planning & Ecology (2018). This report provides an updated biological assessment of the potential impacts of the Davidon (28-lot) Residential Project component of the Scott Ranch project, and compares the significance levels to previous residential development plans.”


We sent to the City Council and upload a PDF entitled “Smallwood Comments_Davidon Homes_Petaluma” from Dr. Shawn Smallwood, ecologist, who completed a site visit to the Davidon / Scott Ranch property in February 2021. Dr. Smallwood also analyzed the 2020-2021 Scott Ranch RDEIR.

In our effort to help the public analyze the 75 page Biological Resources report in the RDEIR, we created a chart entitled “Comparison Smallwood & RDEIR” that compares that section of the RDEIR and Dr. Smallwood’s analysis.

Pages 1-3 summarize Dr. Smallwood’s analysis of the RDEIR. Pages 4-24 are a table. The statements and page numbers from the RDEIR are in column #1. The analysis from Dr. Smallwood of the statements and page numbers in his report are in column #2.

Quotes from Dr. Smallwood

  • "The RDEIR’s characterization of baseline conditions and its analysis of potential project impacts to vertebrate wildlife are outdated, incomplete and flawed. The RDEIR does not provide the most basic information the reader needs to know about the surveys listed on pages 4.3-2. Decision-makers and the public need to know how much credibility to assign the surveys."

  • "Most of the surveys for biological resources were performed in 2003-2005. Wildlife populations tend to shift locations every generation or so, and given all the other changes to the landscape, to species’ status, and to survey protocols, surveys performed nearly two decades ago are out of date."

  • "The RDEIR should provide a detailed account of which species were seen and in what levels of abundance, what members of each species were doing, and in what environmental context."

In 2013, the California Department of Fish & Game wrote a letter to the Planning Department to alert Petaluma that this data was outdated. They found the surveys to be insufficient then; they must be insufficient now.

  • “The Report presents the results of a special status plant and wildlife surveys conducted within the proposed Project area during 2003. As more than a decade has passed since the Report was prepared, the Department recommends that the draft EIR be revised to provide an updated habitat assessment and survey results for special-status plant and wildlife species located within the proposed Project area and surround lands. Since no detail into the scope and depth of data collected during additional reconnaissance-level surveys performed since 2003 is given in the draft EIR, the Department does not consider the additional surveys, to be sufficient to accurately assess project impacts in in the Draft EIR."

Testimony from Rob Hamilton, biologist and President of Hamilton Biological, to the Petaluma City Council on June 19, 2017, also found the surveys to be inadequate.

  • “Although most of the Project site constitutes federally designated critical habitat for the Red-legged Frog, the EIR preparers failed to conduct updated protocol surveys for this species. Rather, data on Red-legged Frog on the project site is based mainly upon protocol surveys conducted in 2003 and 2005. According to the United States Fish & Wildlife Service “2005 Guidance on Field Surveys for the California Red-legged Frog,” survey data for this species are normally valid for only two years. Survey efforts in 2009, 2011, and 2015, did not follow the current federal protocol. Given that 12 years have passed since Red-legged Frog habitat data were collected following the required protocol, the EIR cannot rely on outdated protocol surveys, or more recent non-protocol surveys, to make valid assumptions about the status and distribution of Red-legged Frog in the project area. The EIR’s failure to provide updated Red-legged Frog surveys, conducted according to protocol, is particularly perplexing because the California Department of Fish & Wildlife notified the City and the applicant in 2013 that the documentation for Red-legged Frog was, at that time, insufficient to accurately assess the Project’s impacts.”

Research by Moira Sullivan

It’s really clear that no one should build on these fragile ecosystems in this wildland/urban interface. These native grasslands and wetlands are so important for carbon sequestration.

Frankly, the special status species here, including the federally-listed red legged frog, don’t stand a chance with the intended paved trails, dog, pedestrians, parking lot and homes. That’s really clear when looking at the impacts (and really painful to read).

Note: Davidon and Kelly Creek provided an email (not part of the RDEIR) from the U.S. Fish and Wildlife Service that (paraphrasing) no new studies are needed because the red legged frog breeds in the stock pond. Also stated that critical habitat (CH) boundaries extend to the north side of Kelly Creek. The revised project results in a relatively small loss of CH north of the Creek.

Our summary: Road and houses will be built on the north side of Kelly Creek, but it is not important because only a small loss of frogs and their habitat will be destroyed.

Concept Design

2017 Concept Design Map

In the 2017 Concept Design map, the red line indicated the red legged frog habitat.

2021 Concept Design Map

In the current Concept Design map, a red dotted line is still showing but with no indication that it is a red legged frog habitat.

Questions: What is the red dotted line on the Concept Map? Does it still indicate the red-legged frog habitat? If it does, are proposed houses 20, 21, 22, and 28 in the habitat?

p. 4.3-40

Discusses permanent habitat impacts (habitat lost as a result of development).

Questions: Why not do a current study to determine whether the red-legged frogs are located on the 28-home part of the project? Why not design the development that does not affect endangered species?

Is it preferable to build over the habitat and find “A minimum of 6.1 acres, at a yet to be identified off-site location, would be required to meet the standard mitigation ratio for permanent impacts.”

p. 4.3-42 to 43

“The Final CRLFMP shall be required as a condition of approval for the project Tentative Map . . ."

Questions: What does this mean? Isn't the public entitled to updated studies when evaluating the project? Does the project need to be approved before updated studies are prepared?

Climate change is real and our City is taking it seriously!

The Climate Action Commission (formed in August 2019) worked diligently and in collaboration with City officials and the community to create the Climate Emergency Framework, an ambitious ecological plan. Unanimously approved by the City Council in January 2021, this framework provides guidelines for meeting climate change and sustainability goals.

While the State of CA wants to reach carbon neutrality by 2045, Petalumans decided that we could reach that goal by 2030! There is no time to lose--every development project MUST take a Climate Action First approach.

Climate Emergency Framework

A priority for the city is to use Vehicle Miles Traveled (VMT) to reach the 2030 carbon neutrality goal. Strategies for reducing VMT are through active transportation, land use policy, infill development, and increased density, (p. 16, Climate Emergency Framework)

How does the proposed Scott Ranch project stack up?

Kudos on the Extension to Helen Putnam Park. Getting access to this community jewel, closer to town, will cut down on vehicle traffic to the entrance and parking lot via Chileno Valley Road.

However, traffic from this project will be significant and unavoidable.


Cumulative Impact TRANS-1: Development of the proposed project and the regional park trail would generate VMT per capita greater than the project threshold under cumulative conditions. (Significant; Significant and Unavoidable).

Mitigation Measure TRANS-1 is set forth above to address this significant impact. However, with mitigation, this impact would remain significant and unavoidable.

Therefore, since this mitigation measure cannot guarantee that the impact of the proposed project on VMT would be reduced to a less-than-significant level, this cumulative impact would be significant and unavoidable.

No doubt about it: Traffic will be significant and unavoidable

The fact that neither the park extension nor the housing development directly addresses our Climate Emergency Framework, tells us that these developers are not part of our community. You can’t live and work in Petaluma without knowing that we take Climate Action seriously! We Petalumans deserve a plan for this property that is Petaluma specific and addresses Petaluma's current carbon neutral agenda.

We know that the traffic cannot be mitigated. How would you feel if the City decided that building any homes in this development is OK even though the City knows that the traffic will get worse? Do you think that worse traffic is acceptable because the Davidon / Scott Ranch development provides economic, social, or other benefits to Petaluma?

Perhaps the development of 28 million-dollar homes is a good trade-off for parking spaces and new trails leading to Helen Putnam Park. Perhaps the wildlife will be able to negotiate a path around the new homes, yards, and streets and still migrate through this land. Perhaps the red-legged frog will stay away from the construction and housing area. Perhaps the run-off from the new homes will not cause flooding. Perhaps the residents who buy these million-dollar homes will add plenty of money to city coffers to fix our streets and help with other financial problems.

Perhaps approving 28 homes that causes significant and unavoidable traffic is OK because the city has until 2030 to be carbon neutral. Why start achieving that goal in 2021?

More about significant and unavoidable traffic

p 4.13-27

  • The 28-unit residential subdivision would generate 322 new daily trips, 25 new AM peak hour trips (6 inbound and 19 outbound), and 30 new PM peak hour trips (19 inbound and 11 outbound).

Intersection Operations

p 4.13-70

D Street / Lakeville Street remains an F

p. 4. 13-71

D Street / 8th Street becomes an F

The only improvement (because of traffic circle)

Windsor / D Street goes from an F to a B

Comments: The movement of traffic at Windsor/D might improve, but the pavement on D Street toward Marin County is in deplorable condition. Will that repaving be a part of the project?

Windsor has a weight limit of 5 tons. What is the weight limit on D Street? If no weight limit exists, what is future projection of pavement status on D Street from the proposed Helen Putnam Park parking lot on D Street to Lakeville?

RDEIR says the following impacts are significant and unavoidable


“Cumulative Impact TRANS-1: Development of the proposed project and the regional park trail would generate VMT per capita greater than the project threshold under cumulative conditions. (Significant; Significant and Unavoidable).”

“Mitigation Measure TRANS-1 is set forth above to address this significant impact. However, with mitigation, this impact would remain significant and unavoidable.”

“Therefore, since this mitigation measure cannot guarantee that the impact of the proposed project on VMT would be reduced to a less-than-significant level, this cumulative impact would be significant and unavoidable.”

Question: Are these significant and unavoidable traffic impacts an acceptable permanent trade-off for this project?

Unrealistic statements about the amount of traffic generated by the Helen Putnam park extension

p. 4.13-27

“As shown in Table 4.13-4, the 44-acre extension of the county park and amenities would generate one vehicle trip during the AM peak hour and five vehicle trips during the PM peak hour.”

Note about trip generation: “These rates were found to be higher than trip generation rates prepared for the Taylor Mountain Regional Park and Tolay Lake Regional Park Master Plan studies13, which used ITE rates and a survey of Sonoma County Parks.”

Comment: Neither Taylor Mountain Regional Park nor Tolay Lake Regional Park are located adjacent to neighborhoods. Taylor Mountain Regional Park is being expanded but had not expanded before this RDEIR was written. Press Democrat, March 30, 2020:

p. 4.13-65

“As presented in Section, Project Trip Generation, the Putnam Park Extension Project component would generate additional visitors (approximately new 40 daily trips and five new PM peak hour trips) and potentially change existing visitor travel patterns.”

p. 4.13-72

“Based on the trip generation analysis and regional park comparison presented in Section, approximately 30-40 vehicle trips per weekday, or five during the PM peak period, would be forecasted to use the proposed parking lots in addition to people who shift to these parking lots from parking lots elsewhere to access the park.”

Table 4.13-4 on p. 4.13-27 indicates 34 daily trips.

Comment: For the average nontechnical reader of this RDEIR, these differing numbers are confusing. Credibility is stretched to believe that only one car will arrive in peak AM hours and only 5 cars in the peak PM hours.

The numbers seem inaccurate and very low.

Parking on Windsor Drive any time between sunrise and sunset far exceeds 34 daily car trips. Residents estimate that approximately 300+ per day enter the park entrance from Victoria (this figure includes runners and bicyclists who do not drive cars or park on Windsor).

Size of and price of houses

p. 3.0-19. “The residences would range in size between 2,678 sf and 3,523 sf.”

Comment: An approximate price for the houses has not been disclosed. Is a new home with 2,678 - 3,523 square feet overlooking open space affordable housing?

p. 4.11-2

Table 4.11-1 City of Petaluma RHNA Allocation – Year 2015 to 2023

Comment: The Regional Housing Needs Allocation (RHNA) is dated (adopted in December 2014). Have Petaluma housing needs have changed since 2014? Is more affordable housing necessary now?

Quote from Argus Courier, March 4, 2021

"The city’s annual Regional Housing Needs Allocation report, which was presented to city council Monday, shows Petaluma has failed to build enough affordable housing at the low and very low income levels since 2015, reaching just 18% and 47% of targets set by the regional body. That result sits in stark contrast to the number of units aimed at moderate to above moderate income earners – areas where the city has either met or dramatically exceeded state thresholds to the tune of 305% since the current eight-year housing cycle began in 2015"

2009 Noise Studies Existing Noise Environment, p. 4.10-6

“The primary source of noise at and around the project site is vehicular traffic on D Street.”

“Table 4.10-4, 2009 Roadway Noise Levels Off-Site, shows average daily noise levels along five roadway segments of D Street in 2009 at the time of the preparation of the noise analysis for the residential development previously proposed for the project site.

p. 4-10-7

“As shown in Table 4.10-4, in 2009 ambient noise levels along D Street exceeded 60 dBA CNEL at all five roadway segments (Christopher A. Joseph Associates 2009). Considering that traffic volumes have remained generally the same or slightly increased between 2009 and 2019, ambient noise levels at all five roadway segments still exceed 60 dBA CNEL at the present time (Christopher A. Joseph Associates 2009; Fehr and Peers 2019).”

Recommendation: Up-to-date noise studies be conducted so that an accurate dBA can be calculated.

Parking in existing neighborhoods for Helen Putnam Park


According to Sonoma County Parks, Helen Putnam Park had approximately 189,000 visitors in the 2019-2020 Season.

Throughout the RDEIR, the parking problems in the neighborhoods surrounding Helen Putnam Park are mentioned as existing parking for the park (p. 4.13-5, 4.13-26, 4.13-28, 4.13-65, 4.13-66, 4.13-72).

Residents in the Victoria neighborhood and West Haven neighborhoods are dealing with Helen Putnam Park parkers. For the West Haven neighborhood, the parking issues are relatively new because the park opened a trail by the traffic circle without building a parking lot.

For Victoria, this parking problem has been an ongoing issue for over a decade but has become markedly worse during the pandemic. Helen Putnam Park is not responsible for park visitors parking on city streets. Meetings have been held with city officials over the years. However, the conclusion has always been that these are city streets.

p. 4.13-72

The RDEIR states: “The proposed parking areas would serve as a secondary access point to the park and absorb some of the parking demand that currently parallel parks on Oxford Court and on Windsor Drive west of Oxford Court.”

Comments: Absorbing some of the parking demand while increasing park visitors is not a reassuring statement to the Victoria neighborhood.

The unknown factor is whether park visitors are parking on Windsor Drive because this location is closer to Petaluma or whether free parking is important. If, indeed, free parking is the determining parking factor, the new nearby parking lots that charge a fee will be avoided.

The park knows about the parking problems; the city knows about the parking problems; the residents of Victoria know about the parking problems; and any runner, bicyclist, or motorist driving down Windsor know about the parking problem.

“Perhaps” the parking problem will be solved is not a good enough solution for residents who live in the middle of a parking lot.

What about the new proposed neighborhood?

3.0 Project Description, p. 3.0-32

“In addition, the new public roads would have parking lanes on both sides that would provide on street parking for the neighborhood.”


If this historical well-known and recognized parking problem is not addressed, the parking problems will become the problem of the Scott Ranch neighborhood. Will the new neighborhood have park visitors not parking in parking lots but parking in the neighborhood?

Pinnacle Heights is directly across from the proposed park. Will that neighborhood see the same problems that Victoria lives with on a daily basis?

The city must address the existing Helen Putnam Park parking problems before approving an extension that will increase park visitors.


p. 4.15-5

Figure 4.15-2

Hundreds of homes are in the Wildland Urban Interface area (WUI)— a designation for areas with dense housing adjacent to vegetation that can burn in a wildfire (Sonoma County 2018).

“The project site is not within a “very high fire hazard severity” (VHFHS) zone by the State of California (Sonoma County 2008).”

Comment: What the report fails to mention is that this open space is designated as Tier 2, Elevated Risk of fire threat. 2019, the California Public Utilities Commission map:

Below is a link in order to better see how this 2019 map affects a variety of homes in Petaluma.

The categories are Tier 1 (Extreme) and Tier 2 (Elevated). Much of the southwestern part of Petaluma is in Tier 2 (orange color - elevated fire risk). All of the Davidon property is in Tier 2.

Questions: Should it matter that the site (and surrounding homes) are in elevated fire risk? If maps from California Public Utilities show that information, why not include them in the Wildfire section of the RDEIR?


“Conclusion The project’s compliance with the California Building Code 2019 to develop the residential component with fire-resistant construction materials and the wildfire fuel control through the implementation of the Fuel Management Program developed for the proposed project would improvement existing conditions (without the proposed project), reduce the risk of wildfires, and facilitate quick containment, so that fire would not spread quickly within the residential portion of the site and nearby residential subdivisions.”

Questions: The project site is a small section of a very large WUI and Tier 2 elevated fire risk. The Scott Ranch housing would adhere to strict fire safety regulations and reduce the risk of wildfires. What about the nearby residential subdivisions and homes, which were built when fire safety was not a consideration in building materials or landscaping? A more comprehensive question for the existing elevated fire risk homes is: Should the city suggest home-hardening standards to encourage fire-safe retrofits that could save lives and property?

“Also as discussed under Impact WDF-1 above, with the worst-case traffic assumptions and fire scenarios identified and analyzed in the Fuel Management Plan report, D Street and Western Avenue would have sufficient capacity to accommodate evacuating vehicles while maintaining one lane along those streets for emergency access. Therefore, the proposed project’s impact associated with the risk wildfire and exposure of project occupants to spread of a wildfire would be less than significant.”

Question: The subdivisions of Victoria and Victoria Residential have one evacuation road: Windsor Drive. Under the above assumption during a wildfire, is it assumed that each house would evacuate using one car or did the analysis take into account the previous experiences with fires that residents take several vehicles per home to escape?