! April 5, 2014 ! !

John Howland Architect

Board of Supervisor Efren Carrillo, 5th District 575 Administration Dr., Rm. 100A Santa Rosa, CA 95403 Subject: File No. PLP08-0021, Ratna Ling Retreat Center 35755 Hauser Road, Cazadero Road APN: 109-230-024 and -018

Architecture Interiors Planning

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22050 Timber Cove Road ~ Jenner, CA 95450 ~ (707) 975-3691 ~ john@johnhowlandarchitect.com ~ johnhowlandarchitect.com

! Dear Supervisor Carrillo: ! I urge you to deny PLP08-0021. !

The central point of my opposition to the proposed expansion of printing facilities at Ratna Ling Retreat is that this facility is, in fact, a major printing operation. By its size, product, and sales, this is undeniably an industrial use and is not ancillary to the retreat. Rather, the retreat is ancillary to the industrial use. Profit or not-for-profit is not an issue. In either case it is primarily an industrial operation.

! Please note the following points: ! !

1. A change in land use requires an Environmental Impact Report, NOT a Mitigated Negative Declaration. 2. The EIR or a Mitigated Negative Declaration needs to examine the cumulative impacts of the printing operation on public safety and health, the sensitive biological resources in the area, climate change, and water quality. It must examine the potential land-use conflicts involved, the nuisance of increased traffic, visual changes, and increased fire risk. Then these effects need to be examined for consistency with the purpose of the land-use designation and all pertinent policies of the general plan before any decision can legitimately be made. CEQA guidelines state that a planning document (i.e. a General or Specific Plan) be used as a base for assessing cumulative impact. The new Subsequent Mitigated Negative Declaration improperly uses the prior 2004 MND as a base. 3. The Initial Study relies entirely on a few technical reports prepared and paid for by the applicant. The technical reports provided by the applicant are incomplete and misleading. Many of these reports are based on the 2004 Mitigated Negative

Declaration that contained inaccurate information. Further, it is clear that these reports do not cover all potential impacts. These reports should at least be peer reviewed, as they would be when preparing an EIR. Concluding that there is no impact or less than significant impact from this project without qualified analysis is careless and irresponsible. 4. Land-use is at the base of this controversy. The owners of Ratna Ling are using their property PRIMARILY as a industrial printing operation, a large portion of which is sold commercially. This is an industrial use in a Resource and Rural Development Zone. The use of the word ancillary in the conditional approvals for the expansion of the industrial plant is highly unusual. This word is used in the zoning ordinance when it refers to the land use, referring to areas like swimming pools, tennis courts, kitchens, etc. It is not normally used to refer to an applicants purpose.

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In this project the structures devoted to the retreat itselfthe original stated purpose of the projectinclude the Lodge, Meditation Hall, Library, water storage, office, linen and other storage, Wellness Center, and Senior Care Facility. Altogether these use 43,900 square feet. Compare this with the space allotted to the printing operations: printing and book storage housed in 61,800 square feet and worker housing another 31,200 square feet! It is clear from the allotments of space which operation, is the primary function of the site. The California Building Code limits ancillary spaces to 10% of the primary use. 5. Public Safety is the basis for all zoning and is the primary reason for not having an industrial use in a rural zone. Both the 2004 and 2014 MND analyses lack the following issues: a) Fire Department and Emergency Medical response time and its impact on survival rates have not been considered. How does a 25-minute response time (vs. a 5-minute response time in urban areas) effect the mortality rate in case of an accident? Anything longer than 8 minutes is considered unacceptable for any municipality. b) No emergency response plan has been proposed for industrial accidents at the printing plant. How long would it take to evacuate 1-5 people or 6-10 people? c) How can our Volunteer Fire Department be expected to deal with a major industrial fire without proper training and equipment? Fires in printing plants are extremely intense. The Fire Chief has stated publicly that the Timber Cove Fire Department does not have the training or the equipment to fight an industrial fire. Fighting such a fire would put his fireman in a dangerous and life threatening situation. d) Does Ratna Ling have a water supply adequate to fight such an industrial fire? e) Hazardous materials are incorrectly listed in this plan. No analysis states how and when such materials will be handled. Potential hazardous materials at the site include printing solvents, generator fuel, etc.

f) Who regulates worker safety at the printing factory and facilities? Cal OSHA does not.

6. The Mitigated Negative Declaration does not say how PRMD will manage to report or monitor programs at Ratna Ling. CEQA requires that Mitigated Negative Declarations include a reporting or monitoring program to avoid significant impacts from this project. Ratna Ling currently has at least eight outstanding violations of its 2004 MND, none of which were noted or recorded by PRMD staff.

7. Transportation protection measures and controls have not been addressed, including: a) The traffic study by W-Tran acknowledges that Hauser Bridge Road does not meet American Association of State Highway standards and the cost to bring it to these standards is not feasible. b) Transportation of hazardous materials has not been addressed in this report. c) The report by W-Tran only reports collision accidents with other vehicles. The Timber Cove Fire Department responded to two truck roll-overs last year. That number of vehicular accidents is much higher when Timber Cove Road is used as a detour for Highway 1 closures. I also know personally of one fatality at the intersection of Highway One and Timber Cove Road less than five years ago.

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8. Aesthetics have not been addressed. The Initial Study concludes that the project would not substantially degrade the existing visual character. This statement is inaccurate. Construction has had a major affect on views from private properties to the east. This project, comprising 144,848 square feet, with walls that can be built up to 35 feet high, is the size of an urban shopping center. It will be visible from all of the hills east of the project. Views of a forested hillside have been replaced with views of clearings and industrial structures. These structures create a significant visual land-use conflict with neighbors to the east. In summation, the 2004 Mitigated Negative Declaration was based on inaccurate reports supplied to planning staff. This study improperly viewed the project application as a retreat/ lodge, when it should have been viewed for what it is: a major industrial project in a rural zone. Since the 2014 Mitigated Negative Declaration is based largely on the 2004 MND, the 2014 MND is similarly flawed, and therefore invalid. If the County of Sonoma approves this project without an Environmental Impact Report, it will be in violation of CEQA. Yours truly,

John Howland Architect 22050 Timber Cove Rd. Jenner, CA 95450 Copy;

Cynthia Demidovich, Planner; PRMD Tennis Wick, Director of Planning, PRMD