Sonoma Group, Redwood Chapter 55A Ridgway Avenue, Santa Rosa, CA P.O. Box 4 , Santa Rosa CA !
54"# $%"%& 544'% 5( )ax $%"%& 544'!* ( http+,,redwood.sierra-.u/.org,sonoma April 4, 2014 David Rabbitt, Chair Sonoma County Board of Supervisors 5 5 Administration Drive, Room 100 A Santa Rosa, CA !540" R#$ Ratna %in& Retreat Center and Dharma 'ress (he Sierra Club Sonoma )roup is very *on*erned about the si&nifi*ant proposed e+pansion of the Ratna %in& retreat and industrial printin& fa*ility in the *oastal hills near Ca,adero -ithout the benefit of an #nvironmental .mpa*t Report/ #nvironmental impa*ts from this pro0e*t may in*lude the follo-in&$ a doublin& of overni&ht population and supportin& infrastru*ture on the site1 heavy traffi* on narro- *oastal a**ess road-ays, in*reased &reenhouse &as emissions, pollution from hi&h2volume printin& operations, dama&es to the -atershed from &radin&, in*reased runoff from impermeable surfa*es, and in*reased &round-ater pumpin&/ (hese fa*tors in 3one RRD B4 240 a*res *learly re5uire an #.R to evaluate the *urrent and future impa*ts of the development/ (ru*6 volume also raises the issue of road safety/ (he appli*ant relies on the premise that if the pro0e*t *ontinues -ith a *onstant flo- of tru*6s that no ne- impa*ts -ill o**ur/ (his i&nores the County de*ision to defer road maintenan*e7repair on most rural roads, and the li6elihood that 89erita&e Road: status may be appropriate in this part of the County/ #ssentially defunded *riti*al infrastru*ture in the rural areas that are 6ey lifelines for the *oastal *ommunities leaves the roads in*reasin&ly vulnerable to hi&her volumes of traffi*, espe*ially tru*6s/ Defundin& and the resultin& road de&radation is a le&itimate *umulative impa*t under C#;A that needs to be *onsidered/ (he *umulative impa*t needs to be miti&ated/ (he proposal for an annual limit on tru*6 traffi*, ma6es it impossible to analy,e daily traffi*, or seasonal in*reases and asso*iated impa*ts/ Daily or -ee6ly limits -ould ma6e possible a*tual traffi* impa*t analysis/ <e are also *on*erned that the pro0e*t=s s*ope is not appropriate in a Rural and Resour*e Development >RRD? ,one/ Su*h ,onin& is to 8to provide prote*tion of lands needed for *ommer*ial timber produ*tion, &eothermal produ*tion, a&&re&ate resour*es produ*tion1 lands needed for prote*tion of -atershed, fish and -ildlife habitat, bioti* resour*es, and for a&ri*ultural produ*tion a*tivities that are not sub0e*t to all of the poli*ies *ontained in the a&ri*ultural resour*es element of the &eneral plan/ (he Resour*es and Rural Development distri*t is also intended to allo- very low density residential development and re*reational and visitor2servin& uses where compatible -ith resour*e use and available publi* servi*es/: .n Chapter 24 of Sonoma County 3onin& Re&ulations, Arti*le 10, RRD, Se*tion 242102020, @ses -ith a @se 'ermit >-? 'oli*y %@24e re5uires pla*es of reli&ious -orship, at a minimum,
to *omply -ith A%% *riteria >see 1, 4, A and !?, -hi*h this proposal *annot do/ <hile a modest si,ed retreat *enter may be *ompatible -ith RRD ,onin&, the enlar&ed Dharma 'ress fa*tory is industrial7*ommer*ial and should be lo*ated in an *ompatible ,one as it -as -hen it -as established at its previous site in Ber6eley, California/ <hile re&ulations *annot unreasonably burden a reli&ious pra*ti*e, *hur*hes are not e+empt from ,onin& re5uirements/ Before approvin& this re5uest, it -ould be prudent to assess other RRD 3oned lands to determine the impa*t of this type and intensity of use a*ross the *ounty, -ere it allo-ed/ (he printin& fa*ilities and art ob0e*t produ*tion areas are not 8in*idental, se*ondary or subordinate: by any *riteria/ Stora&e, printin& fa*ilities, art produ*tion areas, and housin& for non2a&ri*ultural -or6ers vastly e+*eed other spa*e uses/ Sin*e the te+ts printed are not sold, there *an be no measure of e*onomi* proportion to other uses/ 9ealth and safety issues have not been ade5uately addressed/ .n addition to the use of printin& *hemi*als, or the impa*ts of tru*6 emissions, impa*ts asso*iated -ith fire ha,ards must be *onsidered/ (he lo*al Bolunteer Cire Dept/ has stated that they do not have the *apa*ity or e5uipment to fi&ht a fire of the s*ale and type asso*iated -ith lar&e printin& operation and te+t stora&e/ A fire of this type in this lo*ation in any season -ould potentially endan&er the residents, nei&hbors and forests/ .n a drou&ht *ondition -here &rasses are more fire sus*eptible, a fire *ould *reate a disaster far -orse than the histori* Ca,adero 9ills fire/ (he B3A approval 1A months a&o -as of a pro0e*t proposal that has been e+panded to su*h an e+tent that a supplemental environmental assessment -as re5uired/ (he pro0e*t should, at a minimum, be sent ba*6 to the B3A for revie- of the *urrent Dar*h 201" proposed pro0e*t/ (his pro0e*t has *learly out&ro-n its former @se 'ermit/ Su*h &ro-th -ithout a permit mat*hin& the a*tual uses on the site should not have been allo-ed/ An #.R is needed at this point to analy,e -hether su*h an industrial pro0e*t *an be permitted in an RRD ,one/ (he 3onin& is inappropriate for this use, the pro0e*t is not *onsistent -ith the )eneral 'lan or 'oli*y %@24e, the use sets a pre*edent that is not analy,ed in other RRD areas, the s*ale is in*ompatible -ith RRD allo-ed densities, a baseline has not been established due to unpermitted in*remental in*reases in uses over many years, and impa*ts *annot be demonstrated to be redu*ed to less than si&nifi*ant/ (his pro0e*t has *learly out&ro-n its former use permit/ An #.R is needed at this point to analy,e -hether a pro0e*t of this si,e and industrial use should be permitted in an RRD ,one/ Eours sin*erely, Dan Ferbein, Chair Sierra Club Sonoma )roup