SAVE OUR WILDERNESS
Topic: Proposed JH Facility Expansion
Dear Mr. Plucker: It has come to my attention that the JH Corporation of Birmingham, Alabama has a Proposed Plan Development Amendment and a Negative Declaration (ND) document in for review before the Planning Department. This proposal, if approved, will at least quadruple the number of guests permitted at their facility at any one time. In addition, the JH indicates they want to operate on a year round basis, rather than a seasonal basis. As a resident of the French Creek drainage and a member of the Friends of French Creek I am quite concerned and opposed to this potential action.
This operation already has considerable effects on our rural lifestyle of both French Creek residents, and Scott Valley in general. Scott River Road and its residents are also affected. The daily traffic, noise, number of people using the vicinity, potential water quality and quantity effects, increase in sewage, and impacts on wildlife, fish, wilderness and mountain environments are all considerations that should to be addressed by the Planning Department.
I have read the JH Planned Amendment and find it both incomplete and misleading. The Negative Declaration minimizes the effects of their actions so that a No Significant Impacts can be claimed. Particularly, their road and noise analyses are highly biased in their favor; that the increase in numbers of guests will have no effect on the community. This is plainly not common sense. The documents are deceiving in that there is no mention of any increase in guests, only that they want to upgrade and rebuild a number of housing structures. This is a typical tactic the JH has used in the past, as witnessed by a great number of French Creek residents. The JH has a habit of being less than open about their plans. I believe the Planning Dept also has experience with this firsthand. In fact, recently the JH was involved with constructing a new housing structure, is County Planning aware of this?
First and foremost their proposal is in violation of the Scott Valley Plan, a zoning and goal oriented document that was constructed by the citizens of Scott Valley, overwhelmingly passed in a Valley wide vote, and approved by the County Board of Supervisors. It has been used as a framework document by the County for over 30 years. As far as I know, it has not been repealed. It needs to be followed. The Plan is very clear that commercial development hosting large numbers of people will be concentrated around existing towns, such as Etna and Ft. Jones. This is to both preserve the rural character of Scott Valley, and concentrate development where infrastructure can support it, and effects can be mitigated (such as road maintenance).
And let me be clear, despite the fact the JH is a non-profit organization providing children with an outdoor and Christian experience, it makes millions of dollars yearly. If the JH is allowed to continue with their expansion, it sets a dangerous precedent for development in the Valley. I am aware that another organization (Kidder Ck Camp) will also be applying for an increase in development. I would like to add that I have no problem with the JH teaching Christian values or outdoor skills, but the size of development is well outside the bounds of the SV Plan, and has no place in very rural French Creek.
The Negative Declaration claims the SV Plan will not been violated since the Board of Supervisors permitted the original development. At that time the JH occupancy was placed at 136 people. One could argue the Board stretched the intent of the SV Plan. At this time, however, with the JH proposed use rates at a 975 person level, and sometimes at a 1600 people level it is clear this is well outside the policies laid out in the SV Plan. The SV Plan discusses deer winter range, which a Plan map shows JH facilities are within. In their ND they claim there will be potential effects, but with mitigating practices, on wintering deer. However, this would be in their best interest to say so, and I believe this is something state Cal-Wild needs to determine, not the JH. The JH claims any adverse effects can be mitigated by allowing only 300 persons at a time during the winter months (page 23-24 of ND). This is well beyond what is allowed in the SV Plan, which calls for 80 acre minimum parcel size. The JH states since there are many parcels below that size already that it abrogates them from following the winter range policy. Their logic makes no sense since they state the 7 parcels they have would allow 15 residents, yet they want to have 300. And who will monitor for compliance occupancy during the deer wintering months?
They want to expand the facility, up to an additional 115,000 square feet of construction, so I would imagine there would be some effect, since they will have to cut some trees and increase their “footprint” to allow for additional buildings. There are also potential effects to a number of other wildlife species, including spotted owl, which also needs to be determined by Cal-Wild. The JH application claims there are no Coho salmon (State and Federally listed species) using the reach of French Creek below the camp, which is not true. Fish surveys have shown Coho to be occupying stream reaches just below the camp, making them vulnerable to any pollutants coming from their operation.
How do we know there are no pollutants now coming from the JH sewage treatment plant or won’t in the future if they enlarge their operation? The County should start water monitoring at this time, before any further development and additional guests are present, so background data is in place. The County should continue monitoring stream water for pollutants if the JH plan is approved to determine downstream effects.
The SV Plan is also about preserving the rural character of the area, this is imbued throughout the document. The Plan stipulates the kind of zoning and development that can occur, and is a major reason why the Valley has maintained its unique character. Anyone visiting places outside the Valley is able to see how development has dramatically changed the character of these places. People move to Scott Valley because it maintains a rural character and they want to live a more relaxed, quiet lifestyle. It is the responsibility of the Planning Dept and Commission to honor the lifestyle of its residents, and landowners who pay property taxes.
The JH operation, as it is currently, does not honor our local rural lifestyle, and this would be greatly exacerbated if it is allowed to increase in size. Let me illustrate a few examples. I used to enjoy riding my bicycle up French Ck road. I no longer do this during the time the JH is in operation. I feel I would be in danger of being hit. In fact, I was almost hit twice. The JH moves people by private car and they descend the road in large convoys of 25-35 cars, all following each other at one car length distance. They travel at speeds unsafe for this road, as there are a number of blind turns and narrow places. Since there is no center line they feel the whole width of the road is open. If the first car had to stop for a deer or cyclist there would most likely be a pileup. Twice I was forced to quickly ride into the inside ditch to avoid being hit, once injuring myself slightly.When the camp is in operation, the traffic by other vehicles increases dramatically. There are frequent trips by various service vehicles, sometimes buses, and often Sysco food trucks. Almost all of them drive at a speed which is not safe for this narrow, curvy road. The County needs to place speed limit signs at strategic locations along this road. I also know of at least one instance when cattle were being driven along the road when JH drivers approached. The drivers ignored the frantic waves of those tending the cattle and drove through the herd, narrowing missing animals. Some local residents have made the comment it is sometimes hazardous to exit their driveways (of which there are many) when these caravans of cars are on the road. And they want to double this?
The JH traffic extends beyond French Ck, as they routinely travel Scott River road to the Scott River Lodge, which they use extensively. This use is not addressed in their Amendment. The SR road is another curvy, dangerous road with no center line. In driving this road at night I was forced to pull over and stop to allow 30+ cars approaching in the opposite direction to drive down the center of the road at a high rate of speed.The noise from the camp is readily audible to anyone who lives within a mile or two. One resident who lived close to the camp elected to sell their home to escape the noise. At times it is quite loud and even though my residence is 3-4 air miles away at times I can hear their loudspeakers plainly when I am outside. I have heard their loudspeakers while hiking in the Russian Wilderness which stands above their camp. Speaking of Wilderness, the JH uses our mountain country for backpacking. I’m all in favor of young people learning about backpacking. But in large groups of 20-30 at one small lake? On more than one occasion I have come to a mountain meadow or lake only to discover a large group of noisy kids. Trash is sometimes found. I believe the Forest Service no longer gives the JH permits for backpacking trips in the Wilderness. In spite of this, our local District ranger, Dave Hayes, found a large group camped at Paynes Lk, within the Wilderness. In talking with Dave, he told me the JH has had numerous violations of their permit, enough so that they are no longer allowed to have operations within Wilderness.
The Scott Valley Plan states another reason to concentrate commercial use operations around existing towns and infrastructure: It is to “not create unduly burdensome public service demands” (page 28). As increased use on the roads occurs there will be more need for maintenance and improvement, and addressing unsafe situations. It may include widening the existing roadbed and eliminating blind corners, further increasing the speed that the JH vehicles can drive. This road work would be paid for by the County and its residents, not by the JH. Also, paid by the County and State, and putting additional stress on the volunteer organizations will be the need for more fire protection, sheriff, and emergency services.
What is going to be the County’s plan and response when a wildfire comes through the camp with 1600 people there? Cal-Fire will need increased manning and infrastructure to handle this very real possibility. Local volunteer services could be called for extra service as well. What is the County’s responsibility when it allows a great number of people to be in harm’s way in a very rural setting? Will the County be liable for a lawsuit if a number of JH guests are injured or killed by a fire? Since the JH is a non-profit corporation it pays no property taxes, no bed tax or income tax, and provides very little economic benefit to the County. Almost all their employees and volunteers come from outside the area, and most are only here when the operation is open. Guests rent cars outside our area, and probably only a few need gas on their trips back and forth to the Medford airport or to the Scott River lodge. The food comes from outside the area in large Sysco trucks. The JH sells snacks and momentoes so little of that is needed from local communities. The guests do come to Etna to eat ice cream cones, and maybe buy something at Ray’s market, but little other money is spent in the community.
Finally, the JH came under scrutiny back in 2007/8 by the Siskiyou County Grand Jury. Their report points out a number of areas of concern regarding their operation, including having a number of guests well in excess of what their permit called for. As I recall, the Planning Department, Planning Commission, and Board of Supervisors all recommended that these indiscretions be dealt with. Again, as I recall very little was done at the time. The JH has continued to grow in the number of guests over the years without approval from the County. It seems to me that the County needs to enforce their own requirements at this time, instead of “rewarding” the JH by increasing their ability to have even more guests with no consequences, no enforcement or monitoring. What is the County going to do to ensure to the residents and landowners in French Creek that they will enforce the rules? I wish to list a number of action items I think the County Planning Department should consider in this matter:
The Scott Valley Plan needs to be followed. If the County elects not to do this and the application will still be considered, then:
The number of guests should be limited to what their current permit allows (250). Currently, I have heard numbers as high as 800 people using the camp at one time.
An EIR with mitigations should be required, as this is a major project with many possible negative effects.
The Planning Department should hold public meetings in Scott Valley to inform its citizens of the proposed project.
Residents and other public agencies need to have plenty of time to learn about and comment on this development.
The County should start a water monitoring program downstream of the JH before and after any additional development and increase in number of guests.
Sewage treatment should be monitored.
A traffic analysis of Scott River Road should be done, since the JH uses this road on a regular basis during their operation, and an increase in guests will have additional effects.
We need more speed limit sign postings along French Creek road.
The County sheriff should monitor traffic and issue citations where warranted.
The JH should be informed that excessive speed and unsafe driving will not be tolerated.
Although the road is narrow perhaps a center line is needed to keep their drivers on the right side of the road.
The County needs to have a plan on how to monitor the JH and inform the public of their findings and action to be taken.
Perhaps if their actions are publicly known they will be more likely to comply with their permit.
Any actions by the JH, outside their permit, needs to be dealt with in a timely manner. This includes existing situations outside their permit, and in fact, these should be dealt with before approving additional development.
I recommend members of the County Planning Department and Commission drive the French Creek and Scott River roads for themselves to get a better picture of the situation.
I am sure funding in our small, rural County is scant to monitor and enforce compliance of the JH’s permit. And it seems the County has done little to enforce the JH permit so far.
The JH has a history of not complying with their permit (see Grand Jury report). This fact alone should disallow any consideration for an increase in development and occupancy. If the County chooses to ignore this fact then: I believe there is a fair argument there are significant adverse impacts that have not been adequately evaluated and/or mitigated in the Mitigated Negative Declaration. An EIR should be required.
Thank you very much for the opportunity to provide comment for this controversial development. The Friends of French Creek will continue to take an active interest, as well as promote awareness and education of others in Scott Valley. We stand firmly opposed to any increase in numbers of guests, and hope the County will be responsible in their enforcement of the SV Plan, and preserve our local rural lifestyle.
Sincerely,MarcR Williams
