8/11/20
To Permit Sonoma from Save the Sonoma Coast
Dear Cecily, Steve, Gary and Tennis:
Thank you for your efforts and good faith to create a document worthy of
governing the Sonoma coastal zone’s future. To that end, and in support of
your efforts, we offer the following candid comments, which we hope will be
received constructively and lead to a closer collaboration with informed and
dedicated public stakeholders.
Within the next two weeks, we hope to furnish you with more specific
concerns applicable to each Element of the Draft LCP.
Who we are:
Sonoma County has a long history of citizen involvement in coastal
conservation. Successful citizen opposition to PG&E’s nuclear power plant
on Bodega Head from 1958 until the passage of the California Coastal
Initiative in 1972 is the preeminent example. That legacy has continued in
the form of Save the Sonoma Coast, a group of local coastal advocates that
carries Bill and Lucy Kortum’s legacy, both philosophically and in action.
While we are challenged by the Draft’s construction and our inability to
meet with staff to provide meaningful citizen participation in the Draft’s
formulation as mandated by the California Coastal Act, we offer changes we
feel are crucial components required to wisely safeguard and steward our
unparalleled and unique coastal resources.
It is our intention to provide a general summary of our concerns, and later
offer point-by-point documentation to suggest changes in policies and
address problems due to inadequacies and/or omissions.
A general list of areas within the Draft LCP we believe need improvement in
order to facilitate public contribution as mandated by the Coastal Act:
The introduction should include greater detail to assist citizens in
orienting themselves to the document and should revise any
inconsistencies;
• An index should be included, in order to locate particular topics;
mapping technology, all maps must be
current and comprehensive. References to maps that are outdated by
20-25 years is not appropriate, given existing mapping resources;
• ESHA mapping and categories should be complete. In this Draft, they
cannot be correlated to the last LCP and are inappropriately abbreviated
to preservation status only;
• Specific language to prohibit onshore support of high-impact energy
resource development (eg, wind turbines) must be included;
• Regulatory language for aquaculture (under the Agricultural Element),
with regard to size or scope, mitigations and public review must be
included;
• Input from long-standing, local coastal advocacy non-profits and public
coastal funding project sources should be sought and included;
• Recommendations by coastal communities, including local Native
American tribes, and other coastal governing bodies such as Regional
Parks, State Parks and the Greater Farallones National Marine
Sanctuary, should be sought and included;
• Marine Protected Areas, the California Coastal National Monument, and
the Greater Farallones National Marine Sanctuary, including the 2015
expansion area must be included and their boundaries identified. All
convey various levels of protection and regulations and require
coordination with State and Federal agencies.
• Collaboration among and between expert scientific resources, such as the
Bodega Bay Marine Laboratory, NOAA and others should be part of the
LCP revision and peer review.
• Goals for public education, social and environmental justice, pesticide
regulation, and timber-to-agriculture conversion policy must be
included;
• Vacation rental regulations, specific affordable housing policy and
priorities for fishing industry housing must be included;
• Please include greater detail in the Table of Contents in order to locate
areas that are referred to in the Elements;
• Strike-throughs or traceable comparisons between previous and current
draft LCP policies would be very helpful. Examples would include
housing, dredging, outer continental shelf development (eg, oil drilling)
and onshore support systems;
• The Glossary should be comprehensive to assist citizens and applicants
by clarifying all planning terminology;
• As has been noted, the planning language used is incomprehensible for
the average citizen;
• The Appendices are difficult to connect to the text;
• New draft policy language is noted as “LCP-revised” or “General Plan-
revised” but there are no strike-throughs or comparison to the existing
LCP or General Plan to identify the changed or omitted previous policy
language;
• Exhibits and Plans are referenced but lack any links to the text or to their
origins.
Additionally, the LCP draft omits important issues:
• Climate change impacts must be considered throughout the Plan with
regard to sea level rise, associated earthquakes, tsunamis, floods,
landslides, fires and droughts— including impacts to coastal housing,
businesses and transportation, best forestry and soil management
practices for carbon sequestration, erosion prevention, fire fuel
reduction, and recommendations for water resource management;
e: emergency/first response, firefighting, law
enforcement, and highway patrol presence to manage tourism impacts
on the coastal zone;
• Lastly, it is critical that the Sonoma County coast’s unique character be
protected–independent of the County as a whole—in compliance with
the Coastal Act. The Coastal act requires General Plan consistency, not
compliance.
We sincerely hope to work more closely with Permit Sonoma, as did the
large group of citizen-advisors during formulation of the first LCP in 1978.
Our times are fraught with unforeseen challenges to our planet’s life-forms,
including human, to which coastal conservation is essential.
Thanks for your attention and collaboration.
On behalf of Save the Sonoma Coast,
Richard Retecki
Laura Morgan
Richard Charter
Rue Furch
Norma Jellison
Janus Matthes (Wine & Water Watch)
Reuben Weinzveg (Preserve Rural Sonoma County)
Padi Selwyn (Preserve Rural Sonoma County)
Cea Higgins (Coastwalk)