John Howland Architect

April 5, 2012 Board of Zoning Adjustments Tom Lynch, 5th District Board Member Sonoma County PRMD 2550 Ventura Ave. 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 222050 Timber Cove Road ~ Jenner, CA 95450 ~ (707) 975-3691 ~ john@johnhowlandarchitect.com ~ johnhowlandarchitect.com

Dear Mr. Lynch: The central point surrounding the proposed expansion at the Ratna Ling Retreat Center is that this facility is, in fact, a major commercial 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. Please note the following points: 1. Such a project requires an Environmental Impact Report, NOT a Mitigated Declaration. The EIR needs to examine the impacts of the retreat center on the sensitive biological resources in the area, climate change, and water quality. It must examine the potential land-use conflicts involving traffic safety, 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 about t can legitimately be made. . 2. The agency referral should be redirected as an industrial printing operation. The referrals were originally sent out as a retreat and not as an industrial use. Therefore the referral agencies were not responding to the true nature of this use. 3. The Initial Study relies entirely on a few technical reports prepared for and paid for by the applicant. The technical reports provided by the applicant are incomplete and misleading. Many of these reports are out-of-date and contain incorrect information. Further, it is clear that these reports do not cover all potential impacts. These reports should at least be peer reviewed, as they are when preparing an EIR. Concluding that there is no impact from this project without qualified analysis is careless and irresponsible. 4. Land-use is at the base of this controversy. Ratna Ling is using their property PRIMARILY as a commercial, industrial printing operation. This is a primarily 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. 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 Initial Study acknowledges that this use would not be allowed if this was not an ancillary use to a retreat center which is similar to a noncommercial lodge or club, and that such religious use could be approved with a use permit if such use does not interfere with or detract from the purposes of the district. The Initial Study fails to make an argument on either point. The applicants contention is that printin g is important to their mission. But we must be clear: their mission is not a land -use, and it should have no bearing on land use rulings. If this flimsy argument, the applicants mission is allowed, what would stop any nonprofit organization with any industrial operation from building anywhere in a rural area? The Initial Study does not address growth-inducing impacts of this, original use of the word ancillary, since such impacts would only be examined in an EIR. This is another reason that an EIR is needed for this project.

5. Groundwater: The reports provided have been in some cases poorly extrapolated from a water study by Eugene Boudreau in 1999. Examples of the omissions in this report include:

a) water usage for fire suppression systems b) water requirements for fighting a major industrial fire c) water for printing operations (Water requirements for printing operations is one of the highest among industries.) d) all studies have concluded that there are inadequate water resources 6. Water quality has not been addressed. This project would be a significant increase in impervious surface area. The following analyses are needed: a) hard surfaces runoff, with locations, cross section, type and area b) roof area run off: 144,848 sf c) run-off calculations and a water containment study provided by an engineer.. These studies would be included in an EIR. 7. Grading has not been addressed. The Negative Declaration states that grading will only be needed for a six-bedroom house, and that therefore, there will be less than significant impact. And the application does not address other grading that will obviously be required. Grading for a project this size on a hillside is not minor, but major. 8. Public Safety has not been addressed. That analysis should include the following issues: a) Fire and explosion prevention measures. b) How can our Volunteer Fire Department be expected to deal with a major industrial fire? Fires in printing plants are extremely intense. c) Does the fire department have adequate equipment to fight such a fire? Does Ratna Ling have a water supply adequate to fight such a fire? How are the hundreds of thousands of volumes of sacred texts being protectedwith halon or water? d) Hazardous materials are not 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. e) No emergency response plan has been proposed for industrial accidents at the printing plant. 9. Transportation protection measures and controls have not been addressed. That should include the following analyses: a) Preferred routes, alternate routes b) potential pedestrian and bicycle traffic c) impact on students walking to and from Fort Ross School d) weight of trucks on paving sections e) tanker trucks to supply generator fuel 10. Greenhouse gas emissions that will be generated by the operation of project have not been analyzed by a qualified engineer. The applicants analysis consists only the gas emission during construction of a house

11. 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 mountain and 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. An EIR should include the following: a) photos of these views compared to both the original view and other project alternative views b) architectural graphics should have been provided c) massing studies should have been provided d) view studies should have been provided. In summary, I have not formed an opinion about this project. I am a resident of this region, and I may not personally be affected by the drastic changes that have been proposed. Yet, while reviewing the specifics of the project thus far, I feel that the review process has been so deficient, that as a professional and as a resident of this beautiful area, I must point these deficiencies out to you. I urge you to rectify them before any final determination is made. The Initial Study Declaration of Negative Impact was based on outdated, inaccurate reports supplied to planning staff. This study improperly viewed the project application as a retreat/lodge, when it should be viewed for what it is: a major industrial, commercial project in a rural zone. If the County of Sonoma approves this project without an Environmental Impact Report the County will be in violation of CEQA. Yours truly,

John Howland Architect 22050 Timber Cove Rd. Jenner, CA 95450 Copy;
Tom Lynch, Pamela Davis 5th District BZA Board Supervisor Efren Carrillo, 5th District