RE: Appeal of PLP15-0060, “Wing and Barrel Hunt Club” aka Kenwood-BPSC Hunt Club LLC, aka Black Point Sports Club
6600 and 5400 Noble Road; APN 68-190-005, -007, -008, -009, -013, -015, -017 and 068-180 -008
Zoning: LEA (Land Extensive Agriculture) B6 100, Z (Accessory Dwelling Exclusion) F2 (Flood Plain) RC 50/25 (Riparian Corridor) SR (Scenic Resource)
Proposal: Appeal of staff’s administrative approval of a Conditional Use Permit modification authorizing a new 26,802 square foot hunting clubhouse, a 1.5 acre fly casting pond, and an 85 foot tall sporting clay shooting tower and related facilities on 978.5 acres utilized as a hay farm and hunting club. The project includes a proposed lot line adjustment between the 825.6 acre hay farm/hunting club property (Lot A) under a non-prime land conservation contract and an associated 152.9 acre parcel (Lot B) containing levees, riparian wetland sloughs and adjoining hay land. The Lot Line Adjustment is subject to Board of Supervisors approval due to the Land Conservation Act contract. The proposal is to remove 89 acres of land for the clubhouse from the contract and add 89 acres of the levee and wetland slough parcel to the reconfigured 825.6 acre contract parcel.
From our friends at Petaluma River Council
To: Sonoma County Board of Zoning Adjustments
Attn: Chairman Willie Lamberson and BZA Members
Dear BZA Chairman Willie Lamberson, members of the BZA, and Planning Director Tennis Wick:
Since 1991, members of the Petaluma River Council in Sonoma, Marin and San Francisco Counties, have worked to protect, restore and support the integrity of the Petaluma River, her tributaries, watershed lands, and the vast Petaluma Marsh and baylands.
The following are comments on the proposed expansion and construction of structures, activities and appurtenant facilities and related environmental impacts of the Wing and Barrel Hunt Club, PLP15-0060 (“Project”) in the Sonoma Baylands. We firmly share and support the expressed concerns and appeal of the CUP (“Appeal”) initially filed by Sue Smith and Tom Rusert and other concerned citizens and neighbors. Further, we protest the administrative approval of the CUP and Mitigated Neg Dec for the Project with no public hearing.
Petaluma River Council strongly urges BZA to grant the Appeal and deny the administrative approval of the CUP, and to subject the Project to a full EIR under CEQA, including the requisite public notice and public hearings.
As well described in the Appeal and other documents submitted in support of the Appeal, the Project would impose many significant and unmitigated impacts on the fish, birds (particularly within the effective refuge areas of the Pacific Flyway), wildlife, plants, biotic, visual and scenic resources of the Baylands, Sonoma and Tolay Creeks; traffic congestion and safety of Highway 37; air and water quality; increased flooding risks to life and property as global warming and sea level rise inundate this property increasingly over its expected 50+ year lifespan; as well as the long-term health of San Pablo Bay wetlands complex and tidal margins.
In addition, the proposed change of intensity, expanded times and days of use and areal extent of the Project’s structures and impacts is inconsistent with LEA agricultural use and the overlay zoning limitations on site and on neighboring parcels, and essentially converts the property into a social club and large event center in an unsuitable location. The Project includes a retail pro shop for firearms, ammunition and other sporting supplies, instructional facilities for sporting and cooking activities, a large ‘clubhouse’, and three 85′ towers, with all the impacts predictably associated with those changes, including significant traffic, noise, lights, visual intrusions in an area that currently has mostly unimpeded views from Hwy. 37 to San Pablo Bay, San Francisco Bay and the Bay’s urban skyline silhouettes, polluted runoff, and water supply, groundwater and wastewater disposal impacts.
This proposed Project is growth inducing within a large region of the Sonoma County baylands and San Pablo Bay frontage that has been protected from development and been preserved for tidal, wetlands, and agricultural preservation through the investment of millions of dollars of public and NGO funds. There is no demonstrated need to start taking that preservation and restoration efforts apart with this Project.
We believe strongly that this Project requires a full EIR under CEQA. The mitigated Neg Dec used for this Project does not satisfy the obligations under CEQA to fully inform both the public and decision makers of the potential impacts and means and methods to identify, avoid or mitigate predictable negative environmental impacts while also examining reasonable and feasible alternatives, including the “No Project” alternative. These problems were compounded by not having any public hearings on the Project’s CUP or Neg Dec. Nor does it give the public the opportunity to address a wider range of substantive issues raised in the Appeal, and to have the issues responded to and considered in advance of any agency decisions or approvals.
Petaluma River Council urges that the Appead be granted, and that the proposed Project and administrative approval of the CUP be denied, and that it be subject to a full EIR under CEQA.
Director, Petaluma River Council