NO TRUST
Re.: JH Ranch Planned Development Plan Amendment
Dear Mr. Plucker and Ms. Trytten,Thank you for the opportunity to review the IS/Mitigated Negative Declaration (M-Neg. Dec.) for the JH Ranch Planned Development Plan Amendment (PDPA). We have attached comments for you to consider and forward on with this cover letter to the Planning Commission.
We are concerned that the Department has concurred with the PDPA preparers that the proposal qualifies under CEQA for a Mitigated Negative Declaration, and that you have already approved the determination. We respectfully disagree that such a determination can be made without a comprehensive Environmental Impact Study and report. With the limited analysis of Hydrology and Water Quality effects alone, it appears to us that there would potentially be significant impacts in spite of the handful of mitigation measures offered.
We trust that past and current public input will be considered before a final recommendation is made to the Commission. In addition, agencies that are authorized to protect natural resources, (County, State and Federal) should weigh in on the full range of potential impacts.Our concern with the appropriateness of a Negative Declaration is based on inadequate analysis or mitigation relative to direction contained in the Scott Valley Area Plan, the North Coast Regional Water Quality Control Board’s Basin Plan, and State and Federal requirements to protect fish, including California and Federal Endangered Species Act requirements.
As daily users of French Creek Road, we are further concerned with our safety, given the increase in the number and size of vehicles.Finally, we have serious doubts whether the terms of any PDPA amendment would be complied with by the Ranch management, or enforced by the County. This is based upon past performance, which we have witnessed during our 30-year residence in French Creek watershed. For example, in 2010 second dwelling housing permit (SDH-09-06) was granted to allow a second dwelling to be built on a parcel otherwise zoned for a single residence. The approval was contingent upon conditions designed to ensure that the residence would not be used to house staff from the JH Ranch, as this has become common practice throughout the French and Miner’s Creek watershed. The conditions have been blatantly ignored each summer since the variance was issued. Of the seven parcels in our Azalea Drive subdivision (outside the PD area), three are used to house JH Ranch employees. Besides the 1993 PD permit requirement for housing of staff on the development site, a number of other permit conditions have been ignored over the decades.
Why should we trust that any new permit restrictions would be worth the paper they are written on?The limited number of mitigations that might require enforcement in the M-Neg. Dec. depend upon voluntary compliance. For example, the Proponent must apply for a building permit. There is widespread awareness that the Proponent may have recently erected a building without permit. Whether this is true or not, there is widespread public perception that the County has neither the financial means nor the political will to enforce mitigation measures upon which a M-Neg. Dec. depends.Please notify us as soon as you know when the Commission hearing will take place.
Thank you for the effort in keeping us up to date. We appreciate your forwarding the attached letter to each of the Commissioners, and providing us with a notice of your receipt of this letter.
Sincerely, Roberta and Richard Van de Water(530) 467-5488 rvdw@sisqtel.net CC Supervisors Marcia H. Armstrong, Brandon Criss, Ed Valenzuela, Grace Bennett, and Michael N. Kobsoff.
