[NOTE: The following documents are taken from the Lafferty Ranch Park Revised Draft Environmental Impact Report and Final EIR. They show the comments from county Permit and Resources Management (PRMD) on the project's consistency with the county General Plan, and the response by EIR consultants. - Ed.]
PERMIT AND RESOURCE MANAGEMENT DEPARTMENT
2500 Ventura Avenue, Santa Rosa, CA 95403
(707) 527.1900 FAX (707) 527-3767
Field Operations / Code Enforcement / Permits / Environmental & Comprehensive Planning
June 19, 1997
Leonard Charles and Associates
7 Roble Court
San Anselmo, CA 94960
I can confirm that the County believes that a park on the Lafferty Ranch is consistent with the Sonoma County General Plan, as per the October, 1995 letter from Jeremy Graves. I would also confirm that the draft statement on cumulative impact of development on Sonoma Mountain Road is accurate from my point-of-view. There is no reason to suspect at this time that there will be much residential development in the Sonoma Mountain Roacl area in the foreseeable future, which is the 2005 as per the 1989 Sonoma County General Plan.
Please contact me should you have any further questions or concerns regarding this matter.
Richard Lehtinen, Planner
PERMIT AND RESOURCE MANAGEMENT DEPARTMENT
2500 Ventura Avenue, Santa Rosa, CA 95403
(707) 527.1900 FAX (707) 527-3767
Field Operations / Code Enforcement / Permits / Environmental & Comprehensive Planning
City of Petaluma
P. O. Box 61
Petaluma, California 94953
Att: Warren Salmons, Assistant City Manager
Re: Notice of Preparation / Initial Study and Opportunities & Constraints Analysis for the Proposed Lafferty Ranch Access and Management Plan
We appreciate the opportunity to comment on the above-referenced documents ("NOP') and provide input on County planning policies, project alternatives and potential environmental impacts which should be addressed in the EIR and decision-making process. Attached to this letter and referenced briefly are written comments from the following County departments:
Department of Transportation and Public Works
Department of Emergency Services
Project Description: The limited nature of the proposed use raises questions about how well it meets the public recreational needs identified for this area in the Sonoma County General Plan. The NOP indicates, because of the site's environmental constraints, that recreational development will be limited to a small parking lot, fencing, signs and foot trails and that allowed uses will not include motor vehicles, bicycles, horses, boating, swimming, fishing, camping, group activities and competitive events. The project appears to be limited to a trail head for limited on-site trails and does not include the varied uses and facilities normally found in a public park.
To allow development of the proposed use in this Iocation, the City proposes to amend its General Plan to add a park facility category called "Habitat Preserve", designate Lafferty Ranch for this use and state that "recreational uses of this property will be allowed consistent with minimizing adverse effects on property biotic communities". Since the site is owned by an incorporated city, no County permits are required for park development.
Consistency with County Plans: Attachment #1 is a chronological history of County planning policies relevant to developing a park on the Lafferty Ranch property. The 1978 Sonoma County General Plan and the Sonoma Mountain Specific Plan adopted in the same year designated the Lafferty Ranch area as a potential regional park site. In the 1989 update, the General Plan maps were revised to indicate the general location of a planned future park and a general location where parkland is needed. Since the General Plan does not definitely state the type of park intended, any public park in the area could be considered consistent with the map designations in the current General Plan. If the project is limited to trail use and is not considered a public park, it would not be consistent with the General Plan because there are no trails designated in this vicinity The proposed use also does not appear to be any of the types of public parks described in the Public Facilities Element.
The Sonoma Mountain Specific Plan has established specific policies relevant to park development on the Lafferty Ranch site. The 1978 Plan specifically required recreational facilities on the Lafferty Ranch site to be compatible with environmental quality and adjacent uses. In 1993 the Plan was amended to provide that the use of the Lafferty Ranch site before park development is to be limited to "supervised field trips or other educational endeavors which do not infringe on the rights of adjacent property owners." This action followed requests by adjacent property owners to delete the park designation for this site due to the potential impacts of visitors and park development on surrounding properties. This policy would apply if the project being considered at this time is not a park but a trail. A trail open to public use would be inconsistent with this policy.
Alternatives: The Open Space Element of the General Plan requires selection of a site for public park development to be guided generally by the following objective:
Objective OS-7.1: Provide for adequate parklands and trails primarily in locations that are convenient to urban areas to meet the outdoor recreation needs of the population, while not affecting agricultural uses.
Because of the limited recreational uses proposed, distance from the site to the Petaluma urban area and the potential effects on agricultural uses adjoining the site, it is questionable if the project meets this objective. Given the environmental constraints on the project site, it seems reasonable that park development on other sites may better serve the park needs of the area as well as avoid or substantially lessen the agricultural and other impacts. For these reasons, the EIR should consider alternative projects and sites that better serve public needs for "adequate parklands". Specific alternatives which should be evaluated as part of the range of reasonable alternatives required by CEQA Guidelines include the following:
Development of other upland sites as "Habitat Preserves" with uses similar to the proposed project.
Full development of the Leftarty Ranch site as a regional park.
Development of a regional park on the Moon Ranch property.
Development of a regional park on other suitable sites in the area.
Evaluation of alternatives should consider the attached comments of the Regional Parks Department on the criteria for regional parks and should assess the relative costs of development, operation and mitigation compared to the benefits and/or revenues resulting from each alternative.
Specific Environmental Factors: In addition to the issues identified in the of the NOP's assessment of potential impacts. the concerns stated below should be addressed in the EIR and mitigation measures included which would avoid or offset any County costs or liability resulting from the project.
Access and Traffic: The EIR should fully evaluate the access constraints identified by the Crane Transportation Group in the NOP and should respond to the attached comments of the Department of Transportation and Public Works concerning the lack of public nght-of-way, high speeds on Adobe Road, accident history, access by pedestrians, equestrians, and bicycles, parking on Sonoma Mountain Road, emergency access, roadway conditions and access standards. The EIR assessment should also include the full costs of. the road improvements required for project-related traffic, who will pay for them and how County liability will be affected by that traffic and improvements to Sonoma Mountain Road.
Fire Hazard: The next attachment is a letter from the County's Emergency Services Director commenting favorably on the fire hazard mitigation considered thus far but pointing out that the site is within the jurisdiction of the County, not the Rancho Adobe Fire Protection District. Consequently, the EIR should address the alternatives suggested by the Director and any other mitigation measures which would assure adequate responses to reports of fires on the project site and adjoining land. The response times for emergency vehicles arriving at the site and the water supply available for fire-fighting should also be addressed fully.
Agriculture: Avoiding significant effects on agriculture is required for a park proposal to maintain consistency with the General Plan objective stated above. Since the project site and adjacent parcels are used for livestock grazing and zoned for a variety of agricultural uses, the assessment of potential impacts in the EIR should consiber the effects on this use. Effects could be significant in the areas of traffic, treapassing, vandalism, fencing, dogs, traffic and noise. The attached comments from the Count Agricultural Commissioner request that the EIR state the future agricultural use of the project site, assess the loss of agricultural land and demonstrate that the project meets a local need. The EIR should also assess potential impacts upon other agricultural uses which may be reasonably expected to occur in the future, such as vineyards.
If you have any question about this letter or the planning issues discussed, please feel free te contact me. If you have any questions about any of the attached comments provided by other County departments, please contact the staff member named in the comment.
#1. County Planning History for Recreational Use of Lafferty Ranch Property
#2. Memo from Philip Sales, Regional Parks Department (August 18, 1997)
#3. Letter from John Kottage, Department of Transportation and Public Works (August 13, 1997)
#4. Memo from Timothy J. Exline, Department of Emergency Services (August 6, ,1997)
#5. Memo from Alexis Ramey, Office of the Agricultural Commissioner (August 19, 1997)
COUNTY PLANNING HISTORY FOR RECREATIONAL USE
OF LAFFERTY RANCH PROPERTY
1-10-78 In the Sonoma County General Plan adopted in 1978, the map of Proposed Regional Parks on page 93 designated the general vicinity of the Lafferty Ranch as a recommended location for development of a regional park, a facility defined as "a spacious area having a scenic or natural character in which a variety of passive recreation experiences and facilities are provided". The General Plan did not establish park development priorities, schedules or implementation programs.
The Land Use Plan map designated the Lafferty Ranch and most of the upper portions of Sonoma Mountain as "Undeveloped: Forest, Grasslands". The Plan text described the types of uses found in these areas and the appropriate densities, but policies related to each designation were very general in nature. The map of Critical Open Space in the General Plan designated a large area on the west side of Sonoma Mountain as "Community Form Land" because of the area's high visibility from the Petaluma urban area. The Plan stated that such lands were to be maintained in large parcels by restrictive zoning or by public acquisition.
6-20-78 On this date the County adopted the Sonoma Mountain Specific Plan to implement the General Plan. The Specific Plan designated the Lafferty Ranch property as a proposed regional Park site, stated that it had been recognized by both the County and the City of Petaluma as a possible park site providing passive recreational facilities, and stated that there was no timetable for eventual purchase or development of the site. The description of the site was followed by the following policies:
"A. Insure that recreational facilities are compatible with adjacent !and uses, the maintenance of environmental quality, and protection of property dghts."
B. Integrate all park systems (federal. state, county, city) to avoid duplication.
C. Improve and maintain a system of regional parks."
The Land Use Plan map in the Specific Plan designated the subject property as "Undeveloped" and applied a maximum density of one dwelling unit per 60 acres. The Specific Plan proposed zoning of A1 Primary Agricultural, B6/60-acre-density which was adopted at the same time.
3-23-89 In the Sonoma County General Plan update adopted in 1989, the site is designated "Land Extensive Agriculture" (LEA) on the Land Use Plan Map. The text policies for the LEA designation allow "Community facilities such as public and private schools, churches and granges". The Land Use Plan Map also shows a triangular symbol near the Lafferty Ranch property which identifies the general location of a planned future park.
The Countywide "Schematic Map of Designated Outdoor Recreation Areas" in the Open Space Element shows a proposed park site in the vicinity of the Lafferty Ranch. The site is within a large area on the west slope of Sonoma Mountain designated as a "Scenic Landscape Unit" by the Open Space Plan Map in the Open Space Element. The objective of this designation is to retain the rural scenic character of visible upland areas which provide scenic backdrops to urban areas and visual relief from urban densities. The Open Space Plan Map also has a triangular symbol on the Lafferty Ranch property indicating the general location where parkland is needed.
8-90 As a part of the Countywide zoning changes implementing the 1989 General Plan; the base zoning on the site was changed to LEA, B6/60-acre-density to match the land use designation.
3-93 During further Countywide zoning changes, the site was included in an SR Scenic Resources overlay zoning to implement the "Scenic Landscape" designation. A small portion of the site was also included in the G (Geologic Hazard) combining district applied to the Alquist-Priolo Special Studies Zone along the active Rodgers Creek Fault.
3-93 During revisions to specific plans to implement the 1989 General Plan, the Sonoma Mountain Specific Plan was renamed the Sonoma Mountain Area Plan and its text amended to indicate that the use of the Lafferty Ranch site before park development should be limited to "supervised field trips or other educational endeavors which do not infringe on the rights of adjacent property owners." This action followed requests by adjacent property owners to delete the:park designation for this site because of the potential impacts of visitors and park development.
11-3-94 The Board of Directors of the Sonoma County Agricultural Preservation and Open Space District determined that the acquisition of conservation easements on the Lafferty Ranch property is consistent with the General Plan.
10-26-95 In response to a request from the City of Petaluma, this department provided a written determination on the consistency with the Sonoma County General Plan of the City's proposed exchange of the Lafferty Ranch and Moon Ranch properties. This determination was made.pursuant to Government Code Section 65402 (c) which requires that the proposed acquisition and disposition of property by a city in unincorporated territory be preceded by a report from the county planning agency on the proposal's conformity with the county general plan. It was determined that the proposed exchange of properties by the City of Petaluma was consistent with the General Plan.
[Excerpt from the Lafferty Ranch Park Revised Draft Environmental Impact Report, by Leonard Charles and Associates for the City of Petaluma, September 2000, pages 203-205.]
Park development of the site could be inconsistent with goals and objectives of the Sonoma County General Plan.
As noted previously, this impact is not significant because the County General Plan does not apply to tlus project. Thus, there is no need to assess the project vis-a-vis County General Plan goals and objectives. However, to ensure full disclosure, the following assessment is presented.
As described under the Setting above, the County PRMD has previously determined that a park on Lafferty Ranch is consistent with the County's General Plan and the Sonoma Mountain Area Plan. After making that determination, the County PRMD submitted a Response to the Notice of Preparation for this Draft EIR. In that Response (included in Appendix A of this report) as well as in a Comment letter submitted on the original Draft EIR, County PRMD staff raised the issues discussed below.
PRMD states that the General Plan allows a park on the site, but that if "the project is limited to trail use and is not considered a public park, it would not be consistent with the General Plan because there are no trails designated in this vicinity. The proposed use also does not appear to be any of the types of public parks described m the Public Facilities Element." Staff further stated that a "trail" rather than a park would be inconsistent with the Sonoma Mountain Specific Plan and the General Plan which do not designate any trails in this area.
Response The Draft Management Plan would allow the following at the Lafferty Ranch Park: trail use, off-trail use, trail use by people with disabilities, picnicking, bird.watching, nature study, use by educational groups, special events, and other passive uses..The park is not "limited to trail use;" all of Lafferty Ranch can be used for passive recreational purposes except for areas containing sensitive resources. Thus, Lafferty Ranch will. not be. simply a "trail" but a park that is open to a full range of passive uses except in sensitive areas where resource protection is the primary goal. The Draft Sonoma County Outdoor Recreation Plan describes a Regional Open Space as a passive recreation park including hiking, picnicking, mountain bike riding, and horseback riding. Lafferty Ranch Park includes the first two allowed uses for this type of park. Horseback riding and mountain bike riding were excluded for this particular site due to its steep terrain and the possible erosion impacts and impacts to other resources.
If the project were nothing more than a trail, it would be a facility that people can walk on but are prohibited from accessing property off the trail corridor. Generally, a "trail," when not within a park, is a right-of-way for.public access that travels through adjacent private properties. A park is where a trail system provides the main access routes and where the user can access other public-access areas for various other recreational uses such as picnicking and nature study. Thus, the proposed project is a "park" rather than a "trail."
The park would be similar to many wildland parks. For example, virtually none of the Marin County Open Space Preserves contain facilities other than trails. The Sonoma County Regional Parks Department in its Draft Sonoma County Outdoor Recreation Plan recommends developing Lafferty Ranch as a Nature Preserve with trail use.
The Draft Management Plan limits the use of the park to certain passive recreational uses, and thereby minimizes land use conflicts, including conflicts with agriculture, consistent with the guiding goals of the County General Plan.
The County also stated that the General Plan Open Space Element requires that selection of a site or public park development be guided generally by the following objective:
"Objective 0S-7.1: Provide for adequate parklands and trails in locations that are convenient to urban areas to meet the outdoor recreation needs of the population while not affecting agricultural uses."
The PRMD expressed the opinion that "Because of the limited recreational uses proposed, distance from the site to the Petaluma urban area and the potential effects on agricultural uses adjoining the site, it is questionable if the project meets this objective. Given the environmental constraints on the project site, it seems reasonable that park development on other sites may better serve as the park needs of the area as well as avoid or substantially lessen the agricultural and other impacts." The PRMD also stated that the EIR should address alternative sites.
Response As noted above the Draft Management Plan provides for a range of passive uses of the site. Additional uses were discussed by the Lafferty Ranch Access Committee when developing the Draft Plan. Uses such as equestrian use, allowing dogs on the site, picnic facilities, and active recreation facilities were rejected partly in response to the wishes of residents in the area who did not want a type of park in the area that would attract large numbers of users and in part because of the potential adverse effects of expanded use. Uses were restricted to be consistent with the portion of Objective 7.1 not to affect agricultural uses in the area.
The site is about 3.5 miles from edge of the City of Petaluma. The County General Plan (Public Facilities Element) states that regional parks be within a 30-60 minute drive from urban areas and that community parks be within a 30 minute drive of urban centers. Lafferty Ranch Park is approximately a 15-20 minute drive from the center of Petaluma. Thus, the park is consistent with the convenience aspect of objective OS-7.1 given the County General Plan definition of park accessibility.
As regards effects on adjoining agricultural uses, as discussed above, the effects on these operators will not be substantial. Because of the prevalence of agricultural uses in the area and the natural characteristics required for a park such as contemplated by the City, it would be difficult to develop a park anywhere on the west slope of the Sonoma Mountains without equally affecting agricultural operators. The Draft Sonoma County Outdoor Recreation Plan recommends both development of Lafferty Ranch as a nature preserve with trails plus another 300 acre park m the area. Almost all the land in the Sonoma Mountain area (including land bordering the currently-proposed park on the White Oak Estates project) is used for livestock grazing.
As regards the site's "environmental constraints,' this Draft EIR did not find any significant constraints nor impacts of the recreational component of the project, with the exception of traffic safety on Sonoma Mountain Road and increased fire hazard. The same constraints would be found on most sites (though as discussed in the subsequent analysis of the alternate site, the "Moon Ranch," CDF has determined that there would not be a significant fire hazard if this site were developed as a park) in the Sonoma Mountain area since they share similar fire risks, and none of the access roads in the area except Adobe Road and Stage Gulch Road meet the road standards by which the County requested Lafferty Park be assessed.
The County General Plan under the Objective cited above notes that potential park sites are denoted on the Open Space Plan Map. A park is denoted in the Lafferty Ranch area. Thus, it appears that the County determined that a park in this area would be consistent with Objective OS-7.1
To conclude, the proposed park is consistent with this Objective. This Draft EIR assesses alternative sites as requested by PRMD staff (see the subsequent section on Project Alternatives).
The PRMD and the Sonoma County Regional Parks express the opinion that a Regional Park should provide a broad range of recreation activities and that Lafferty Ranch Park, as proposed, would not meet the criteria for a regional park nor a regional park preserve and would thus not be consistent with the County General Plan.
Response The General Plan Land Use Map and Open Space Map both designate a "park" in the Lafferty Ranch area. The Plan does not state what type of park would be developed there, only that a site in the area was suitable for park. The City is proposing to develop a park on the site. The Public Facilities Element of the County General Plan classifies several types of park including a Community Park that is large enough to accommodate a variety of activities within a 30 minute drive of population centers. The proposed Lafferty Ranch Park is within a 30 minute drive of Petaluma, Cotati, and Rohnert Park. It provides for a variety of recreation activities. The Draft Sonoma County Outdoor Recreation Plan identifies passive regional open space preserves which do not provide a broad range of activities. The Draft Plan recommends that Lafferty Park be developed as a nature preserve with trails. Surveys conducted for the preparation of the plan determined that the highest priority for types of park facilities was "unimproved open space" (SCRP, 1999, p. 61). The surveys also found that 48 percent of the respondents favored passive parks while only 20 percent favored active parks (SCRP, 1999, p. 59). A more intensive use park such as that proposed by the SCRP is presented in Alternative 3.
PERMIT AND RESOURCE MANAGEMENT DEPARTMENT
2500 Ventura Avenue, Santa Rosa, CA 95403 (707) 565.1900 FAX (707) 565-3767
November 9, 2000
City of Petaluma
P. O. Box 61
Petaluma, California 94953-0061
Att: Pamela A. Tuft,
Director of General Plan Administration
Re: Comments on Revised Draft EIR (RDEIR) for Lafferty Ranch Park
We appreciate the opportunity to comment on the above-referenced document. The comments focus on the concerns expressed in our August 24, 1998 letter regarding the previous DEIR.
1.5 Project Description: On page 35, the RDEIR reports that the City is investigating the legal access to the site from Sonoma Mountain Road across land owned by another party. However, there does not appear to be any further discussion of this issue. The RDEIR should address the impacts of the proposed use of the project site if the City does not have such access and is not able to acquire it from the property owner.
3.6 Fire Hazard: On page 129, the RDEIR states that 40 percent of the Lafferty Ranch site is an oak-bay woodland which represents a relatively low fire hazard because a fire in this setting would be "a slow spreading fire of low intensity". Is this conclusion still true if many of the oak trees on the site are dead or dying due to the "sudden oak death" which now appears to be spreading to various species of oak trees in this vicinity? The analysis of fuel loading and fire spread in RDEIR section 3.6 and Appendix H should address this issue.
On page 130, the RDEIR states that the California Department of Forestry has the primary responsibility for suppressing fires on the site because the site is within a State Responsibility Area. Will CDF continue to have that responsibility if the site is developed and used by the City as a public park?
Clarification is needed on the sources of water available for fire suppression. On page 133, the RDEIR refers to three nearby reservoirs as possible water sources but states that it is not known if access is possible. If access is likely, the amount of water available in each reservoir should be stated along with any limitations on use. If access is not likely, these reservoirs should not be included as mitigation. If the reservoirs are not available, the RDEIR states that water trucks would have to travel back down Sonoma Mountain Road to get more water. The RDEIR should state if this conclusion is still true if the Management Plan recommendation to install 20,000 gallons of water storage on the site is carried out. Is this amount considered sufficient for fire suppression on this site by any standard criteria?
Appendix H recommends acquiring road access to the top or eastern edge of the site, but this action is not referenced by either the Management Plan or proposed mitigation. The Management Plan recommends that the City "investigate the possibility" of access to a corner of the site. However, the analysis of potential impacts in the RDEIR indicates that emergency vehicle access to the upper portion of the property should be available before public use begins. This provision should therefore be included in the required mitigation measures.
The response times for fire engines are estimated, but there are no standards discussed and no criteria provided to determine if the estimated response times for this site are adequate for the proposed use. The RDEIR should assess the adequacy of the estimated response times.
3.7 Traffic. Data and analysis have been expanded substantially regarding the road improvements and right-of-way acquisition required for project-related traffic on Sonoma Mountain Road, the impacts of those improvements, and traffic hazards at the Adobe Road Sonoma Mountain Road intersection. However, the RDEIR does not include mitigating improvements which would substantially reduce these impacts and address any County liability or lack thereof with respect to the traffic and improvements to Sonoma Mountain Road, especially if the improvements provided do not fully mitigate the traffic and safety impacts. In spite of our previous comments and the additional information now in the RDEIR, there is still no commitment to any mitigation. The new analysis is used largely to document the substantial total cost of all needed improvements and support the proposed finding that it is infeasible to mitigate road impacts to a less-than-significant level by doing all of the improvements.
This approach does not meet CEQA provisions regarding the responsibility of public agencies to mitigate project impacts. With the detailed information now available regarding Sonoma Mountain Road deficiencies and impacts, a plan of specific improvements should be developed and included in mitigation measures before the project is approved. The plan should clarify what the City considers "feasible" mitigation in this case.
3.13 Recreation: The review of County'recreation policies in RDEIR section 3.13 is incomplete and misleading because it does not mention the adopted General Plan policies and instead focuses on proposals in the draft Outdoor Recreation Plan that has not yet been considered by County decision-makers. Since the General Plan policies are reported in the land use impact analysis in section 3.14, a cross-reference to that discussion should be added to 3.13.
3.14 Land Use. Some of our previous comments regarding agricultural use of the project site and potential effects on surrounding agricultural uses appear to have been addressed in the RDEIR, but the proposed mitigation still needs refinement. The project management program mentions existing fences or repairing fences, but there is no complete description of the fencing proposed at the perimeter of the site. Patrolling the site by City staff should be conducted at least on a daily basis at varying times rather than the proposed 2-3 times per week.
4.5 Alternatives: The RDEIR does not adequately address the lack of supervision of visitors to the site. The Sonoma Mountain Area Plan specifies that the use of the Lafferty Ranch site is to be limited to "supervised field trips or other educational endeavors which do not infringe on the rights of adjacent property owners". This wording was adopted after much input by neighbors and is intended to assure the compatibility of site use with adjacent agricultural uses. Given this policy and the significant impacts of the proposed project, serious consideration should be given to the "restricted use" option described in the RDEIR as the environmentally superior alternative and the alternative which is most consistent with the Area Plan.
If you have any question about these or other issues related to the project, please feel free to contact me at 565-1917 or Greg Carr at 565-1944.
cc: Board of
Department of Transportation and Public Works
Department of Emergency Services
[Except from the Lafferty Ranch Park Final Environmental Impact Report, by Leonard Charles and Associates for the City of Petaluma, February 2001, page 60-62]
Response to Letter from Robert Gaiser, Sonoma County Permit and Resource Management Department
E1. The "no project' alternative addresses the scenario of no public access to the site (see pages 226-232 of the Revised DEIR). It should be noted that, at present, the nature and scope of the existing rights over the small strip of land between Sonoma Mountain Road and the entrance to Lafferty Ranch have not been legally determined. ff the City opts to approve a park on the site, it will explore all of its options for securing the required access, including, if necessary, condemnation.
E2. See Master Response No. 2 regarding fire hazard associated with SODS on the site.
E3. CDF will continue to have responsibility for responding to wildland fires on the site. However, the City of Petaluma Fire Depamnent will also respond to any calls for fire suppression. The City's willingness to provide first response to fire calls on the site will enhance the ability of fire suppression agencies to suppress any fires igniting on Lafferty Ranch prior to the fires burning off the property.
E4. The fire modeling and fire hazard analysis included in the Revised DEIR are not based on water availability from any reservoirs in the area. These reservoirs are not included as mitigation in the Revised DEIR. As stated on page 135 of the Revised DEIR, if reservoirs are not available, water tenders would need to travel down Sonoma Mountain Road to re-fill. This would be true whether the 20,000 gallon water tanks proposed for the project were available or not, as the water in these tanks would be primarily used for "mop-up" activities. See the preceding letter from CDF (Letter C) wherein CDF states that these tanks will be beneficial for all fires in the area.
E5. While improvement of this access would be of benefit, it was not deemed a necessary mitigation measure by the fire scientist who prepared the fire hazard section of the Revised DEIR. It is noted that one can currently drive along the route of this proposed access (the EIR preparers have driven the route in a pickup truck). The proposed road improvement would facilitate access by larger fire suppression vehicles. However, off-road fire vehicles (e.g., brush tracks) as well as possibly pumpers can already access the northeast comer of Lafferty Ranch along the route of the proposed road. As stated in the Draft Management Plan (see page 23 of the Revised DEIR), improvement of this access will be pursued with the property owner if a park is approved for the site, and the owner has expressed her interest in such a road. The commentor's opinion that an improved road access should be provided is noted for the record. However, it is again pointed out that emergency access already exists along the route of this proposed improved road, and improvements to the road are not a required mitigation measure to substantially reduce fire impacts.
E6. The estimated response times were provided by CDF. The Revised DEIR describes predicted fire spread given these estimated response times (see pages 137-138 of the Revised DEIR). As far as the EIR authors are aware, there are no adopted standards nor criteria for response times. The Revised DEIR finds that fire danger is a significant impact, in part due to long response times. If response times were quicker, there would be less risk of a major wildfire. The response times used in the Revised DEIR are conservative. It is quite likely that engines from either the City of Petaluma or Rancho Adobe Fire Protection District would arrive at Lafferty Park faster than the CDF engines.
E7. The Revised DEIR contains an extensive description of existing roadway deficiencies on Sonoma Mountain Road and roadway improvement needs; see pages 154-160 of the Revised DEIR. Bringing the road up to minimum AASHTO standards for roadway width and shoulders would require road widening. To meet AASHTO standards for line of sight and maximum grades would require much more extensive reconstruction of the road. At pages 160-161 the Revised DEIR identifies potentially significant project impacts on the roadway, i.e. the increased traffic will subject additional pedestrians, bicyclists, and drivers to the identified traffic safety hazards. On page 162, the Revised DEIR states that the traffic safety impact can be mitigated to a less than significant level by improving the road to meet the minimum AASHTO standards. These improvements, however, are within the jurisdiction of the County, and additionally are not feasible given the high cost of those improvements. In addition, bringing the road into compliance with AASHTO standards would itself be a project with the potential to cause significant adverse environmental impacts. FUll compliance with CEQA would be required before such project could be approved.
The Revised DEIR also states that traffic safety impacts could be reduced, although not to a less than significant level, by developing a phased plan to implement some or all of the needed road improvements or by implementing measures to reduce safety risks on the existing roadway such as posting warning signs, reducing and posting speed limits to meet AASHTO-recommended stopping distances, constructing speed bumps, and eliminating the proposed bicycle racks from the park to discourage bicycle traffic (see pages 162-163 of the Revised DEIR). With the exception of eliminating bicycle racks, these measures are also within the jurisdiction of the County. Thus, coordination with the County, CEQA compliance, and approval by the County would be required to implement all of these measures except the bicycle rack measure.
The cost of roadway improvements would depend on what improvements if any are approved by the County. Such improvements could result in environmental impacts of their own, which are discussed generally in the Revised DEIR, and may require additional environmental review prior to implementation. Improving Sonoma Mountain Road may also adversely affect the rural and scenic character of the road, depending on the level and nature of improvements implemented. The other measures for reducing safety impacts identified in the EIR, such as posting warning signs and constructing speed bumps, would be less costly than road improvements and are unlikely to result in significant environmental impacts.
The County would need to consider the above factors in determining whether to develop a road improvement plan or other road safety measures. It is noted that there are numerous existing rural roads in the County that do not meet AASHTO standards, including a number of roads to parks, and there is no evidence that the County has made upgrading of those roads to AASHTO standards a high priority. Assuming the County did determine that some or all of the measures identified in the EIR were feasible and desirable, at this point the City cannot assume the measures will be implemented, because there is no assurance that the County would approve and implement them. These are decisions within the County's control. Accordingly, as set forth in the EIR, although the City may wish to coordinate with the County on developing future roadway improvements, it cannot rely on such improvements to mitigate the significant road safety impact identified in the EIR.
The County's potential liability for the condition of its road does not raise an environmental issue and is beyond the scope of this EIR. The County General Plan contemplates a park in the vicinity of Lafferty Ranch, so the project is consistent with the level of development the County contemplated in the General Plan.
E8. As the commentor correctly states, the analysis of the proposed project per County recreation policies is contained on pages 203-205 of the Revised DEIR. Section 3.13 addresses impacts as regards actual benefits for the public and is not a discussion of the project's consistency with County General Plan policy. The latter analysis is contained within the Land Use Section (Section 3.14). The references to the Draft Outdoor Recreation Plan in Section 3.13 clearly indicate that the plan has not yet been adopted. The County specifically requested that this Plan be assessed for cumulative impacts in the Revised DEIR. The Draft Plan is discussed as an example of the identified need for more non-urban parks. There is no reason to revise the Revised DEIR based on this comment.
E9. The site is currently fenced, and no new perimeter fencing is required, other than to repair any damaged sections of the existing fence or replace short sections where the fence is extensively damaged or has disappeared. Fences include typical farm wire fencing except along the west side where there is an 8-foot high cyclone fencing. The commentor's opinion that patrolling should occur daily is noted for the record. As noted in the Revised DEIR (page 171), many other parks in the area are not patrolled on a daily basis. Daily patrolling is not deemed necessary to respond to the amount of potential crime predicted for the park. The Revised DEIR does not need to be revised to incorporate this suggested mitigation measure.
E10. The Sonoma Mountain Area Plan states that limiting the use of Lafferty Ranch to "supervised field trips" is required only until such time as the site is developed as a public park (Sonoma Mountain Area Plan, p. 17). As such, this policy does not contemplate limiting the use of the site to supervised trips once it is developed as a public park. The commentor's opinion regarding Alternative 2 is noted for the record. The Revised DEIR identifies Alternative 2 as the environmentally superior alternative among the altematives that are not "no project" alternatives.