Friends of the Gualala River

An affiliate of the Redwood Coast Watersheds Alliance

P.O. Box 1543, Gualala, CA 95445 GualalaRiver.org

Cynthia Demidovich, Project Planner Sonoma County Permit and Resource Management Department 2550 Ventura Ave. Santa Rosa, CA 95403 cdemidov@sonoma-county.org SUBJECT: File No. PLP08-0021, Ratna Ling Retreat Center January 19, 2012 Dear Ms. Demidovich: Friends of the Gualala River opposes approval of a new Use Permit, PLP08-0021, for Ratna Ling Retreat Center and the Dharma Press Book Publishing Facility at 35755 Hauser Bridge Road, Cazadero. No use permit application for this industrial project in a rural residential watershed of the South Fork of the Gualala River should be processed without an Environmental Impact Statement (EIR). Dharma Press is situated on land zoned Resource and Rural Development (RRD). The proposed project would authorize expansion of piecemeal, unauthorized past industrial expansion and operation of a major printing facility that is basically incompatible with RRD zoning and existing, legal, ongoing land uses including forestry, agriculture, recreation, low-density housing and the production, processing and protection of local resources. Previously, in 2004, the printing facility at Ratna Ling (Dharma Press) was authorized by PRMD as a subordinate use of the Ratna Ling Retreat Center (UPE04-0032). The relationship is apparently reversed now, with the industrial commercial activity now proposed as the dominant land use. The Dharma Press book production facility, described as a small, religious, non-profit, one press operation, was allowed as an ancillary function of the Retreat Center- a special case. As defined by Sonoma County Building Regulations, an accessory (ancillary) use must be incidental to the primary use and must not significantly change the character, appearance, or operation of the principal use of the building or property. This former special case exception now swallows the rule with respect to zoning and land use in the current permit proposal; the industrial printing operation tail now wags the Retreat Center dog. This is unreasonable in itself, and in the absence of an EIR, this major land use change is unacceptable and would violate CEQA. This major zoning change proposal requires an EIR and a general plan amendment because it may result in significant direct, indirect, and cumulative impacts from continued sprawl of intensive industrial land use in a RRD zone, following a pattern of unauthorized construction

Friends of the Gualala River January 19, 2012 1

PLP08-0021, Ratna Ling Retreat Center

Friends of the Gualala River

An affiliate of the Redwood Coast Watersheds Alliance

P.O. Box 1543, Gualala, CA 95445 GualalaRiver.org

and after-the-fact permit applications for Ratna Lings apparent history of piecemeal development. The following potential significant impacts are not adequately mitigated, and are sufficient to trigger the preparation of an EIR: Chemical spill hazards with potential runoff to tributaries of the South Fork, Gualala River, with potential significant impacts to special-status aquatic species (steelhead, foothill yellow-legged frogs). Industrial chemical supplies for printing operations, and chemical wastes generated by industrial printing operations, would be routinely transported in increased quantities along hazardous, steep, twisting rural county roads with extremely long response times (long driving distance) from hazardous waste clean-up crew dispatch points. PLP08-0021 would increase press supply trips for a 40-ft. long tractor-trailer truck to a round trip a day all year. All raw materials are trucked in and all finished products are trucked out via a 200 mile round trip from the Bay Area. Traffic impacts on rural roads would be significantly increased due to trucking for materials deliveries and worker and service industry transportation. Many of the rural winding roads servicing this area narrow to one lane without a centerline and are maintained with ever diminishing available county road maintenance funding. Increased water demand due to construction of a new dormitory for 12 more workers and a seasonal campground for 24 additional workers, and increase of on-site residents from 67 to 122, may have significant indirect effects on stream baseflow and endangered salmonid habitat during critical drought years. Ratna Ling already has 11 cabins and 2 houses for workers and 20 deluxe cottages for guests approved in 2004. Increased water demand met by well use or diversions, particularly during droughts, may reduce streamflows (summer channel pool volumes, temperatures, depths) below thresholds for survival of steelhead juveniles in tributaries of the South Fork Gualala River.

PRMD should consider off-site project alternatives that would eliminate conflicts with existing, long-established zoning and land uses, and eliminate potential significant impacts. Location of printing operations within the urban boundary of Santa Rosa would be consistent with County General Plan zoning and land use policies, minimize long-distance rural road travel (reduce greenhouse gas emissions), keep frequent truck deliveries of hazardous materials on Caltrans-maintained roads with rapid emergency response capacity, and provide economic benefits and jobs to Sonoma County residents. Neither the applicant nor PRMD has provided any meaningful justification why an industrial printing operation should be permitted inside a religious resort within remote rural forested and agricultural lands, rather than in urban areas with other industries in the County with labor pools in need of employment. There is nothing about the nature of the printing enterprise that essentially requires location in a RRD lands: the
Friends of the Gualala River January 19, 2012 2 PLP08-0021, Ratna Ling Retreat Center

Friends of the Gualala River

An affiliate of the Redwood Coast Watersheds Alliance

P.O. Box 1543, Gualala, CA 95445 GualalaRiver.org

location is apparently merely based on land ownership, and possibly the availability of volunteer labor supplied by the Ratna Ling religious community. It is our understanding that this facility is in large part dependent on this off-the-books volunteer labor force. These private interests should not override public interest review by PRMD. The precedent this proposal establishes for county land use planning is atrocious: it provides incentive for tax-exempt religious organizations to acquire relatively inexpensive real estate outside urban industrial areas and establish industrial operations, with after-the-fact, ad hoc zoning changes and piecemeal permits. And it provides incentive for Ratna Ling to continue to expand intensive development and land uses on the South Branch of the Gualala River watershed, incompatible with Sonoma Countys General Plan, and contrary to the public interests protected by the General Plan. We look forward to your response to our concerns and a continued commitment to the overall interests of the General Plan, the natural environment of the west county and to all the citizens of the larger Sonoma County. Sincerely,

Chris Poehlmann President, Friends of the Gualala River poehlman@mcn.org

Friends of the Gualala River January 19, 2012 3

PLP08-0021, Ratna Ling Retreat Center