To PRMD, commenting on the revised Sonoma County Local Coastal Plan

I live near the Sonoma coast because of its wild open spaces, abundant public
land, recreational and scenic opportunities, and the rich variety of plant and
animal species it fosters. These attributes draw more and more people to the
coast each year, both visitors and residents, and this increased use puts increased
stresses on this unique and fragile area. Therefore it is critical that we have in
place very specific guidelines over how coastal lands are used and how, or
whether, development occurs. With this in mind I attended the PRMD workshop
at the Timber Cove Fire Hall on September 14. I was taken aback that PRMD is
rewriting the LCP to conform to the General Plan, taking a document meant to
protect a very small, unique area and generalizing it to conform to a plan that
governs the rest of the county.
As a volunteer at Fort Ross and Salt Point State Parks I meet hundreds of visitors
each summer, and while some come from all over the world China, Europe,
Russia, South America, most of them come from California, many from within
Sonoma County. What they have in common is that they ALL come to the coast
to see beautiful wildlands - ocean bluffs, coastal grasslands and redwood forests,
perhaps catch a glimpse of a bobcat or fox. I assure you that people visiting from
Santa Rosa are not driving to the coast to see cows or wineries.
So I expect an updated LCP to provide safeguards for these wildlands and
promotion of our Parks. But although the LCP discusses the importance of
preserving the unique coastal environment, when it comes to actual language in
the code itself, the only value attributed to coastal lands are economic ones. For
instance, discussion of California Floristic Province (Open Space and Resource
Conservation element) states: However, human population pressures have
rendered California one of the four most ecologically degraded states in the
country, with all or part of the nation's eight most threatened ecosystems
represented. The greatest threats to the ecosystems of the California Floristic
Province are expansion of urban areas, habitat encroachment, and pollution;
expansion of large-scale agriculture; strip mining and oil extraction; road

construction; livestock grazing; logging; increasing use of off-road vehicles;

invasive, non-native plant species; and suppression of natural fires
So I was surprised to see wording encouraging long term grazing leases on Park
lands and retention of Park lands for agricultural over recreational use Policy CAR-3f: Encourage the State Department of Parks and Recreation to take the
following actions regarding managing agricultural land in State Park Units: (1)
Prepare a long range resource element of each Park Unit General Plan long-term
plan for managing grazing lands; and use the plan as a basis for grazing leases
agreements; (2) Retain in agricultural production land not currently needed for
public use, as compatible with the General Plan Resource Element of the park unit;
and improve range management practices. (3) Grant long-term grazing leases
(five to twenty years) on State Lands, providing which include incentives to
improve the quality of range quality
I was also surprised at the change to the Agricultural element C-AR-5, allowing
new visitor services in agricultural areas that are limited in scale and location and
are beneficial to the agricultural industry and fam operators and compatible with
long-term agricultural use of the land., and more specifically the language in CAR-5.1 and 5e that says that the test for these new visitor services is that they be
secondary and incidental to agricultural production activities. I am very
concerned that whether tasting rooms and/or event centers for the wine
industry, or some other intense future use that we cannot foresee, this language
is extremely vague and does not provide adequate protection.
Some parts of the document are so simplistic as to be useless. For instance, I was
surprised that a document intended to guide land use and development well into
the future describes wildland fire risk as Most damage results from a few large
fires in the dry weather months. There were 21 wildland fires of 100 acres or more
in the County between 1989 and 2000 (Public Safety Element). Warmer
temperatures and years of drought have dramatically increased fire potential, just
ask any California fire fighter, so I am dismayed that the document that is to guide
coastal Sonoma County into the future uses 20 year old fire statistics!
For another example refer to Climate Change Potential Impacts (Open Space
and Resource Conservation element), a section consisting of a 2 page, grade

school level description of climate change with the grand conclusion that It is not
possible to predict with any accuracy the impacts of climate change on Sonoma
County. What on earth is the purpose of that section? Many of us would
translate a warmer globe to less predictable weather, worse droughts, more
severe storms, increased sea level, all of which can and should be addressed in a
document intended to plan for the next 20 years.
Other parts of the document are internally contradictory. For instance, the Public
Safety Element states: Residences have increased the number of fires in rural
areas. Ninety-seven percent of the wildland fires over 50 acres in Sonoma County
since 1989 were caused by human activities or facilities. Residences in rural areas
cause fire suppression agencies to devote limited resources to structural
protection while the wildfire spreads. The probability of large damaging fires in
developed areas is affected by weather conditions and the spread of fires in
surrounding wildland areas. The type of construction, preventive measures, and
the extent of fire suppression services are the chief factors which determine how
far these fires spread. Wildland fire hazards may be reduced by mitigation
measures including removing vegetation and installing dependable water systems,
but cannot be eliminated entirely.
But then look at General Design Guidelines outlined as Policy C-OSRC-4 (Open
Space and Resource Conservation Element). Structures shall be sited behind or
near existing vegetation or topographic relief to screen them from view from
public roads and use areas Structures shall be located within or behind wooded
areas, tree stands, or tree groupings to screen them from view On ridgelines,
pruning or removing tree stands or groupings shall be prohibited if doing so would
make structures more visible from public roads and use areas The following
guidelines shall be used for design of commercial buildings: Wood or shingle
siding and natural or earth colors shall be used The following guidelines shall be
used for exterior finish materials and colors: Wood or shingle siding shall be
used. It seems that the staff that wrote the Design Guideline section of the Open
Space element was not reading the Public Safety element!

We need a coastal plan that works, that is understandable by the public and that
really guides land use into the future. A document that really protects the coast.
So I was disconcerted that Sandi Potter, PRMD Planning Manager, suggested to
the citizens at the September 14 meeting that concerns about the agricultural
tourism issue be made to Sonoma Countys Winery Working Group. This is a 21
member working group, over half of whom work directly with the wine industry.
Is that the group to guide policy for our coastal wildlands? It was another
indication to me that PRMD is not taking seriously its responsibility to protect our
fragile coast as a unique, separate entity, and instead is determined at the
standards used in the rest of the county are to be applied here.
PRMD, the Board of Supervisors, and the Coastal Commission may be surprised at
the forceful reaction of coastal residents and other concerned citizens over the
updated LCP. But remember the successful fights that prevented the building of a
nuclear power plant at Bodega Bay and kept open public access to the coast. And
remember that locals were unable to prevent an industrial book printing facility
within the Coastal zone, even with the current Coastal and General Plans in place.
If we allow existing rules to weaken, what negative changes will the coast see?
Reviewing the LCP has been a lengthy and frustrating experience. I want to
remind PRMD that PRMD staff, the County Board of Supervisors, the Coastal
Commission members, industry lobbyists, are all paid to read, study, comment on
the plan. People who care about the coast and read and evaluate this lengthy and
convoluted document on their own time are at a distinct disadvantage! PRMD
are paid employees of the people, and we expect you to work to protect what we
and so many of our predecessors have hard won. Our elected representatives
need to be reminded that we remember and we vote.
With best hopes that we can work together towards an improved Sonoma County
Local Coastal Plan,
Susan Zerwick
109 Niestrath Road

Cazadero, CA 95421
(707) 331-5662