John Zorovich, Senior Planner
Development Review, North Division
County of Santa Barbara
624 W Foster Road, Ste. C
Santa Maria, CA 93455
RE: Notice of Preparation for Rancho La Laguna Subdivision; Project # 06RM-00000-00002
Dear Mr. Zorovich:
Thank you for the opportunity to comment on the Notice of Preparation (NOP) for the proposed subdivision of Rancho La Laguna into 13 lots ranging from 160 to 604 acres in size. As you know, the Santa Ynez Valley Alliance submitted comments on the proposed Mitigated Negative Declaration for this project in November 2010 (copy attached and incorporated).
The Valley Alliance is pleased that the County ultimately decided to require an Environmental Impact Report (EIR) for this project as we had, and still have, major concerns about the adverse impacts that this project will have on several key issues areas, as described in our letter, and discussed in the Notice of Preparation.
Agricultural Resources: Protection of agricultural lands is of utmost importance in the Santa Ynez Valley. We support the scoping items identified in the NOP, but believe that water availability should be included in the assessment of existing and future potential physical constraints (3rd bullet on page 7). Of particular importance to address is the long-term sustainability of an agricultural scenario that converts grazing land into more intensive row crops, which greater water needs and which may be more affected by crop prices. The agricultural viability of the property is perhaps the most important factor in ensuring the protection of long-term, agriculture on this property.
Biological Resources: The Valley Alliance agrees with the concerns raised with regards to the impacts to native grasslands and wetlands, and to sensitive and/or special status species, including the California Tiger Salamander and the California red-legged frog, among others and support the scoping requirements laid out in the NOP. The fragmentation of biological resources, as well as the conflicts between increased agriculture and the biological resources on the property must be identified.
Geologic Resources: We disagreed with the MND in 2010 about the significant impacts that the substantial grading that will occur if this proposed project is approved. As we stated in our November 18, 2010 letter, “One driveway along will require the creation of seven switchbacks, 12 foot high retaining wall and 24,000 cubic yards of grading. This is excessive. We strongly support the recommendation in the NOP to assess the soil erosion and sedimentation impacts (both short and potentially long term) associated with this excessive grading.
Land Use: The NOP recommends no further environmental analysis is needed in this area, however, the Alliance believes that the issues relating to the protection of agricultural resources, especially cumulatively, are intrinsically tied to land use. The critical issue here is the cumulative impact if large portions of the Santa Ynez Valley are converted to smaller and smaller parcels. Efforts were made decades ago to increase minimum parcel sizes, to ward off the movement towards subdivision of large agricultural ranches into rural ranchette developments. This project represents the reversal of that direction and, therefore, requires that the land use implications of subdividing this large agricultural property be examined. The fact that there have been no recorded subdivisions within a one-mile radius of the subject property since 1990 is irrelevant. It is the possibility of similar subdivisions in the future that creates the impact, and not just within one mile of the property, but all over the rural areas of the Santa Ynez Valley, of which there are plenty.
Cumulative Impacts: The lack of any meaningful analysis of cumulative impacts was perhaps the most compelling reason to require an EIR on this project. With the EIR, we expect this section to fully analyze all cumulative impacts in detail, as is indicated in the NOP.
Alternatives: The Alliance will be looking for a variety of alternatives in the EIR, such as a reduced level of development, as well as a variety of creative options to preserve the agricultural viability of this property, such as the imposition of agricultural easements, etc. The EIR should discuss the no project alternative and should also identify the most environmentally superior alternative.
The Santa Ynez Valley Alliance hopes that these scoping comments are helpful and we look forward to review the Draft EIR when it is released for public comment.
The mission of the Santa Ynez Valley Alliance is to work collaboratively with individuals, groups and governments to protect the rural character of the Santa Ynez Valley and support good stewardship of natural and agricultural resources through education, comprehensive planning and public participation.
Again, thank you for this opportunity to comment.
Mark Oliver, President