Fountaingrove Environmental Impact Report - City of Santa Rosa ...

Aegis Senior Living Continuing 

Care Retirement Community – 

Fountaingrove Lodge Project 

Final Environmental 

Impact Report 

SCH # 2006112153 

Prepared for 

City of Santa Rosa, California 

October 2008 

155 Grand Avenue, Suite 1000 

Oakland, CA 94612

Contents 

1.0 Introduction.........................................................................................................................1-1 

1.1 Environmental Review Process............................................................................1-1 

1.2 Environmentally Superior Alternative................................................................1-3 

1.3 Organization of the Final EIR ...............................................................................1-3 

2.0 List of Commenters and Response to Comments ........................................................2-1 

2.1 List of Commenters................................................................................................2-1 

2.2 Master Responses ...................................................................................................2-2 

2.2.1 Soils and Seismic Mitigation....................................................................2-2 

2.2.2 Land Use Compatibility ...........................................................................2-5 

2.2.3 Oak Trees and Oak Woodland ................................................................2-6 

2.2.4 Noise............................................................................................................2-9 

2.2.5 Local Traffic..............................................................................................2-10 

2.2.6 Visual Resources......................................................................................2-12 

2.3 Comments and Responses to Comments on the Draft EIR............................2-13 

Response to Comment Letter from Aegis Living ............................................2-22 

Response to Comment Letter from Elizabeth Anderson and Thomas 

Toth, MD...................................................................................................2-29 

Response to Comment Letter from Linda Barr ................................................2-32 

Response to Comment Letter from Ed Bellone ................................................2-35 

Response to Comment Letter from Annette Cooper.......................................2-37 

Response to Comment Letter from Allen T. Daugaard ..................................2-39 

Response to Comment Letter from Dr. Susan L. Dibble and Dr. Jeanne F. 

DeJoseph...................................................................................................2-41 

Response to Comment Letter from Skip Epperly (Advocates for 

Responsible Development) ....................................................................2-52 

Response to Comment Letter from Fountaingrove Ranch Master 

Association (FRMA)................................................................................2-59 

Response to Comment Letter from Thomas and Judith Glenn .....................2-63 

Response to Comment Letter from Kyra Janssen ............................................2-66 

Response to Comment Letter from Jim Johnson..............................................2-69 

Response to Comment Letter from Kirt and Brenda Kisling .........................2-72 

Response to Comment Letter from Joseph Magagna......................................2-75 

Response to Comment Letter from Edward Margason ..................................2-81 

Response to Comment Letter from Henry McGuckin (letter 

dated July 18, 2008) .................................................................................2-85 

Response to Comment Letter from Henry McGuckin (letter 

dated July 25, 2008) .................................................................................2-90 

Response to Comment Letter from Carmen McReynolds, M.D....................2-93 

Response to Comment Letter from Native American Heritage 

Commission (NAHC) .............................................................................2-95 

ES092008001PHX\BAO\082970001 iii

CONTENTS 

Response to Comment Letter from Dewey Nelson (letter dated 

July 17, 2008).......................................................................................... 2-100 


July 19, 2008).......................................................................................... 2-106 


July 22, 2008).......................................................................................... 2-109 


July 28, 2008).......................................................................................... 2-112 


July 31, 2008).......................................................................................... 2-116 

Response to Comment Letter from Ryan and Sheri Neuman ..................... 2-118 

Response to Comment Letter from North Coast Regional Water 

Quality Control Board (NCRWQCB)................................................. 2-125 

Response to Comment Letter from Lynn and William Rood...................... 2-130 

Response to Comment Letter from Larry Scharf........................................... 2-133 

Response to Comment Letter from Lynda Scigliano .................................... 2-135 

Response to Comment Letter from Alan Spencer......................................... 2-137 

Response to Comment Letter from Jim Sturgeon.......................................... 2-140 

Response to Community Comments Letter (as submitted by 

Dewey Nelson)...................................................................................... 2-151 

Response to oral comments made during the Public Hearing 

(July 24, 2008)......................................................................................... 2-170 

3.0 Errata and Revisions.......................................................................................................... 3-1 

4.0 Mitigation Monitoring and Reporting Program .......................................................... 4-1 

5.0 References ........................................................................................................................... 5-1 

Tables 

4-1 Mitigation Monitoring and Reporting Program 

iv ES092008001PHX\BAO\082970001

Acronyms and Abbreviations 

3-D three-dimension 

afy acre feet per year 

BAAQMD Bay Area Air Quality Management District’s 

BMP Best Management Practices 

BRAR Biological Resources Assessment Report 

CCAR California Climate Action Registry 

CDFG California Department of Fish and Game 

CEQA California Environmental Quality Act 

CH4 Methane 

City City of Santa Rosa 

CNPS California Native Plant Society 

CO2 carbon dioxide 

CR Cluster Residential 

dBA decibels A scale 

dbh diameter breast height 

Draft EIR The Fountaingrove Lodge Draft Environmental Impact Report 

EIR Environmental Impact Report 

Final EIR Aegis Senior Living Continuing Care Retirement Community – 

Fountaingrove Lodge Project Final Environmental Impact 

Report 

Fountaingrove Lodge 

Project 

Aegis Senior Living Continuing Care Retirement Community - 


FRMA Fountaingrove Ranch Master Association 

FRPCD Policy Statement Fountaingrove Ranch Planned Community District Policy 

Statement 

General Plan Santa Rosa 2020: General Plan 

General Plan EIR General Plan Final Environmental Impact Report 

GHG Greenhouse Gas 

ES092008001PHX\BAO\082970001 v

ACRONYMS AND ABBREVIATIONS 

HFC hydroflourocarbons 

IPCC Intergovernmental Panel on Climate Change 

ITE Institute of Transportation Engineers 

KOP Key Observation Points 

kWh kilowatt hour 

lb/ft 2 pounds per square foot 

LOS level of service 

MMRP Mitigation and Monitoring Reporting Plan 

mph miles per hour 

N2O nitrous oxide 

NAHC Native American Heritage Commission 

NCRWQCB North Coast Regional Water Quality Control Board 

NOD Notice of Determination 

NOP Notice of Preparation 

NOx nitrogen oxide 

NPDES National Pollutant Discharge Elimination System 

p. page 

PFC perfluorocompounds 

PG&E Pacific Gas and Electric 

PM10 

pp. pages 

particulate matter 

Project Aegis Senior Living Continuing Care Retirement Community - 


ROG reactive organic gas 

SCWA Sonoma County Water Agency 

SF6 sulfur hexafluoride 

SUSMP Santa Rosa Area Standard Urban Stormwater Mitigation Plan 

SWPPP Stormwater Pollution Prevention Plan 

USACE U.S. Army Corps of Engineers 

USFWS U. S. Fish and Wildlife Service 

vi ES092008001PHX\BAO\082970001

1.0 Introduction 

The complete Environmental Impact Report (EIR) for the Aegis Senior Living Continuing 

Care Retirement Community - Fountaingrove Lodge Project (Fountaingrove Lodge Project, 

or the Project) consists of the following: 

• The Fountaingrove Lodge Draft Environmental Impact Report (Draft EIR), Volumes I and II, 

State Clearinghouse Number 2006112153, dated June 2008, by the City of Santa Rosa, 

California 

• The responses to comments and revisions to the Draft EIR contained in this document 

(the Final EIR) 

• The Mitigation Monitoring and Reporting Program, included with this document 

In addition, the following related environmental documents are incorporated into this EIR 

by reference: 

• Santa Rosa 2020: General Plan (General Plan) (City of Santa Rosa, 2002a) and Santa Rosa 

2020: General Plan Final Environmental Impact Report (General Plan EIR) (City of Santa 

Rosa, 2002b) 

• Fountaingrove Ranch Planned Community District Policy Statement (FRPCD Policy 

Statement) (City of Santa Rosa, 1992) 

The following subsections outline the environmental review process for the EIR and 

summarize the Project’s environmental compliance. 

1.1 Environmental Review Process 

The following subsections outline the environmental review process for this document and 

summarize the Project’s environmental compliance. 

Notice of Preparation and Scoping 

On November 29, 2006, the City of Santa Rosa (City) Department of Community 

Development issued a Notice of Preparation (NOP) that an EIR would be prepared for the 

Project (see Appendix A to the Draft EIR for a copy of the NOP). The NOP was submitted to 

the State Clearinghouse, responsible and interested agencies, and interested members of the 

public. The purpose of the NOP was to allow for concerns and comments to be received 

regarding the scope and content of the EIR. Written comments were accepted through 

December 29, 2006. In addition, a public scoping meeting was held on December 12, 2006, at 

the Steele Lane Community Center in Santa Rosa, where verbal comments were received. 

Draft EIR Circulation 

The Draft EIR was prepared based on input received during scoping. The Draft EIR was 

circulated for review by the public and agencies for 45 days. The 45-day comment period 

ran from June 13 through July 28, 2008; written comments postmarked by July 28, 2008, 

ES092008001PHX\BAO\082970001 1-1

1.0 INTRODUCTION 

were accepted. A public hearing to take verbal comments was held on July 24, 2008, before 

the Santa Rosa Planning Commission. 

EIR Certification 

This Final EIR includes additional information that is intended to clarify and expand the 

information in the Draft EIR. After a careful review of the comments received on the 

Draft EIR, the responses to the comments, and the information added to the Final EIR, the 

City has determined that recirculation of the document for additional public review and 

comment is not required. Section 15088.5 of the California Environmental Quality Act 

(CEQA) Guidelines governs recirculation of a Draft EIR before certification. Recirculation is 

only required when “significant new information” is included in the Final EIR, such as 

information showing that: 

1. A new significant environmental impact would result from the Project or from a new 

mitigation measure proposed to be implemented. 

2. A substantial increase in the severity of an environmental impact would result unless 

mitigation measures are adopted to reduce the impact to a level of significance. 

3. A feasible project alternative or mitigation measure considerably different from others 

previously analyzed would clearly lessen the significant environmental impacts of the 

Project, but the Project’s proponents decline to adopt it. 

Because the Final EIR does not identify any new significant environmental impacts from the 

Project or from a new mitigation measure and does not identify a substantial increase in the 

severity of an environmental impact over that described in the Draft EIR, the grounds for 

recirculation have not been met. 

This Final EIR contains copies of written and verbal comments received on the Draft EIR 

and responses to those comments; they are included in Section 2.0, List of Commenters and 

Response to Comments. The City will review the EIR for adequacy and consider it for 

certification pursuant to the requirements of Section 15090 of the CEQA Guidelines. 

Project Approval 

After the City certifies the adequacy of the EIR, it can approve the Project and would: 

1. Adopt appropriate findings regarding the significant environmental effects identified in 

the Final EIR, the availability of feasible alternatives and mitigation measures to reduce 

or avoid significant environmental effects, and other matters pursuant to Public 

Resources Code Sections 21002, 21002.1, 21081, and 21081.5 and CEQA Guidelines 

Sections 15002, 15021, 15064, and 15091 

2. Adopt a statement of overriding considerations pursuant to Public Resources 

Sections 21002 and 21081 and CEQA Guidelines Section 15093 

3. Adopt a mitigation, monitoring and reporting program pursuant to Public Resources 

Section 21081.6 and CEQA Guidelines Sections 15091 and 15097 

Following Project approval, the City would file a Notice of Determination (NOD) with the 

State Clearinghouse pursuant to CEQA Guidelines Section 15094. 

1-2 ES092008001PHX\BAO\082970001

1.2 Environmentally Superior Alternative 

1.0 INTRODUCTION 

As required by CEQA, Section 4.5 of the Draft EIR also identifies the environmentally 

superior alternative. As discussed in Draft EIR Section 5.0, Alternatives, in general the 

alternatives, including the No Project Alterative, would be expected to have impacts similar 

to or greater than the Project impacts. The Smaller Footprint Alternative and the State 

Density Bonus Alternative meet the Project objectives discussed in Section 2.2, Project 

Objectives, while the No Project Alternative may not, depending on the development that 

occurs. The Smaller Footprint Alternative would reduce the level of biological impacts 

compared to the Project, but would result in greater, potentially significant and unavoidable 

visual impacts. The State Density Bonus Alternative meets all the Project objectives, but 

would have greater environmental impacts than the Project. The No Project Alternative 

could reduce visual impacts, depending on the type of development that occurs, but could 

have increased traffic congestion, noise, and air quality impacts as compared to the Project. 

Among the alternatives to the Project, the Smaller Footprint Alternative would be the 

environmentally superior alternative. However, as noted above, the Smaller Footprint 

Alternative would not be environmentally superior to the Project because of greater, 

potentially significant and unavoidable visual impacts. 

1.3 Organization of the Final EIR 

This Final EIR is organized as follows: 

Section 1.0—Introduction 

Describes the report, environmental review process, and environmentally superior 

alternative. 

Section 2.0—List of Commenters and Responses to Comments 

Section 2.0 includes a complete copy of written comment letters and minutes of the public 

hearing. The individual comments within each letter and the minutes are marked and 

enumerated in the margins. Responses to comments follow each letter, numbered to 

correspond to the comments in the letter; similarly, responses follow the public hearing 

minutes. 

Section 3.0—Errata and Revisions 

Section 3.0 of the Final EIR contains errata and revisions to the Draft EIR. The errata and 

revisions are shown as strikeout for deletions and underline for new text in the pages from 

the Draft EIR. Overall, the errata represent minor modifications to the text of the Draft EIR. 

Section 4.0—Mitigation Monitoring and Reporting Program 

Section 4.0 contains a consolidated list of mitigation, monitoring, and reporting activities 

that the City, in certifying the Final EIR, commits to implementing. CEQA requires that each 

public agency adopt objectives, criteria, and specific procedures to meet its responsibilities 

under the Act and the CEQA Guidelines (Section 21082). 

ES092008001PHX\BAO\082970001 1-3

2.0 List of Commenters and Response to 

Comments 

2.1 List of Commenters 

The Draft Environmental Impact Report (EIR) for the Aegis Senior Living Continuing Care 

Retirement Community - Fountaingrove Lodge Project (Fountaingrove Lodge Project, or the 

Project) was circulated for review by the public and agencies for 45 days. The 45-day 

comment period ran through July 28, 2008. Numerous written comments were submitted to 

the City of Santa Rosa (City) during this review period. In addition, a public hearing was 

held on July 24, 2008 to take verbal comments from members of the public. 

The written and verbal comments received are as follows: 

• Aegis Living 

• Elizabeth Anderson and Thomas Toth, MD 

• Linda Barr 

• Ed Bellone 

• Annette Cooper 

• Allen T. Daugaard 

• Dr. Susan L. Dibble and Dr. Jeanne F. DeJoseph 

• Skip Epperly (Advocates for Responsible Development) 

• Fountaingrove Ranch Master Association (FRMA) 

• Thomas and Judith Glenn 

• Kyra Janssen 

• Jim Johnson 

• Kirt and Brenda Kisling 

• Joseph Magagna 

• Edward Margason 

• Henry McGuckin (letter dated July 18, 2008) 

• Henry McGuckin (letter dated July 25, 2008) 

• Carmen McReynolds, M.D. 

• Native American Heritage Commission (NAHC) 

• Dewey Nelson (letter dated July 17, 2008) 





• Ryan and Sheri Newman 

• North Coast Regional Water Quality Control Board (NCRWQCB) 

• Lynn and William Rood 

• Larry Scharf 

ES092008001PHX\BAO\082970001 2-1

2.0 LIST OF COMMENTERS AND RESPONSE TO COMMENTS 

• Lynda Scigliano 

• Alan Spencer 

• Jim Sturgeon 

• Community Comments (as submitted by Dewey Nelson) 

• Oral Comments made during the Public Hearing (July 24, 2008) 

2.2 Master Responses 

Because of the numerous comments received on similar topics, general or “master” 

responses were drafted to provide a singular, comprehensive response. This section 

provides master responses for the topics of Soils and Seismic Mitigation; Land Use 

Compatibility; Oak Trees and Oak Woodland; Noise; Local Traffic; and Visual Resources. 

2.2.1 Soils and Seismic Mitigation 

A number of the comments submitted raised concerns that mitigation measures for 

potential soils and seismic impacts, described in Section 3.6 of the Draft EIR, are inadequate 

and include studies and analysis that defer evaluation of impacts and findings in a manner 

inconsistent with California Environmental Quality Act (CEQA) requirements. 

Per California Code of Regulations Section 21080, the determination of the significance of an 

impact must be based on substantial evidence, which includes facts, reasonable assumptions 

predicated on facts, and expert opinion supported by fact. Analysis of potential geotechnical 

impacts in the Draft Environmental Impact Report (EIR) was based on 13 different studies 

and analyses completed at the Project site by multiple experts and including extensive field 

data, as well as more general information such as published soils maps and Alquist-Priolo 

Special Studies Maps. This evidence was sufficient to determine that significant impacts 

could occur as a result of seismic ground-shaking, slope instability, seismic-induced ground 

failure, and expansive-soil behavior. Additional evidence is not needed to support the 

identification of potentially significant geotechnical impacts. 

CEQA Guidelines Section 15126.4(B) states that “[f]ormulation of mitigation measures 

should not be deferred until some future time. However, measures may specify 

performance standards which would mitigate the significant effect of the project and which 

may be accomplished in more than one specified way.” When specific mitigation measures 

cannot be firmly established at the time of EIR certification, the lead agency must identify 

probable mitigation measures and make a commitment on the record to their 

implementation. (Sacramento Old City Assn. v. City Council (1991) 229 Cal. App. 3d 1011.) 

This is often the case when a project has been developed to a level where general mitigation 

measures (e.g., seismic bracing) are known, but the specific measures (e.g., special concrete 

moment resisting frame vs. concrete shear wall) have yet to be determined until final 

design. 

Mitigation Measures 3.6-2 through 3.6-5 are based on design standards and codes used on a 

regular basis in California to address geotechnical issues in building construction. These 

standards and codes outline performance standards that minimize hazards to people and 

structures to acceptable safety levels, as required by the state. The detailed site-specific 

analyses described in the mitigation measures will identify the specific approach required to 

2-2 ES092008001PHX\BAO\082970001


meet the performance standards. Because there are additional site exploration and analyses 

to be performed during final project design, the City has identified specific alternative 

mitigations to be incorporated, depending on the results of the findings. (Defend the Bay vs. 

City of Irvine (2004) 119 Cal. App. 4th.) To clarify the purpose of the additional studies and 

that the mitigation measures reduce impacts to a less than significant level, the mitigation 

measures have been revised as follows. 

Mitigation Measure 3.6-2: Incorporate site-specific seismic analysis into Project 

design. 

The site-specific seismic analyses will be performed to identify the active and 

potentially active seismic sources that are capable of generating significant ground 

shaking at the Project site. Analysis may include response spectra, computer 

simulations, and finite element model. These findings will be incorporated into the 

design of Project components prior to approval of the Improvement Plan. The project 

components will be designed in accordance with the applicable building codes (2007 

California Building Code) and will satisfy the seismic performance criteria of their 

intended uses. Code requirements for structures located very near faults are more 

complex than the requirements for structures located outside this region. For 

structures located within the Project region, additional measures such as site-specific 

geotechnical and geological investigations and additional structural analysis and 

detailing are required. If the studies result in a significant redesign of the project, 

then recirculation of the EIR may be required. 

Mitigation Measure 3.6-3. Incorporate site-specific slope stability analysis into 

Project design. 

AdditionalThe site-specific investigations and analyses will be performed during 

final design by the Applicant. The investigations will include drilling soil borings 

and recovering soil samples within and outside the boundaries of the proposed 

development site. The investigation will also include identification and 

characterization of the horizontal and vertical (depth) extents of slope instability. The 

findings will be incorporated in the analyses that will evaluate slope stability, 

including landslides and soil creep, and various slope stability measures. Depending 

on the findings, slope stabilization measures may consist of regrading slopes, 

providing surface and subsurface drainages, and constructing slope strengthening 

elements such as toe buttresses and secant walls. analyses will be performed and the 

findings of the analyses The results of these studies may limit the proposed 

development design, and they will be incorporated into the design of Project 

components prior to approval of the Improvement Plan. If the studies result in a 

significant redesign of the Project, then recirculation of the EIR may be required. 

Mitigation Measure 3.6-4: Incorporate the results of geologic and geotechnical 

investigations and site-specific seismic analysis into Project design. 

As part of a design-level geologic and geotechnical investigations, site-specific 

seismic and geologic hazard analyses will be performed to collect data and to assess 

the potential for seismic-induced ground failure in soil and rock materials adjacent 

to and underlying Project components. The study will include assessments of 

ES092008001PHX\BAO\082970001 2-3


seismic-induced geologic hazard potential at the Project site, such as liquefaction, 

slope failure during earthquakes, and loss of bearing capacity of foundation soils. If 

such potentially problematic soils and/or slopes are found, the effects of these 

seismic-induced geologic hazards to the performance of Project components will be 

evaluated and incorporated into the design. 

Mitigation measures may include excavation of potentially liquefiable soils during 

construction and replacement with engineered backfill, in situ ground treatment 

(such as compaction grouting, deep soil mixing, and jet grouting) to prevent 

occurrence of liquefaction and loss of soil bearing, construction of perimeter system 

to contain the problematic soils, and strengthening slopes using toe buttresses and 

secant walls. Potential slope failure within and outside the boundaries of the 

proposed development site that may impact Project components will be assessed. 

Portions of the Project site that are susceptible to slope instability hazards are likely 

to be susceptible to slope failure as a result of strong seismic ground shaking. 

The results of these studies may limit the proposed development design, and they 

will be incorporated into the design of Project components prior to approval of the 

Improvement Plan. If the studies result in a significant redesign of the Project, then 

recirculation of the EIR may be required. 

Mitigation Measure 3.6-5: Develop appropriate design features for locations where 

potential problems have been identified through design-level geotechnical 

investigations. 

Design-level geotechnical studies will be conducted to develop appropriate design 

features for locations where potential problems are known to exist. If potentially 

problematic soils are found, appropriate design measures may include excavation of 

potentially problematic such soils during construction and replacement with 

engineered backfill, ground-treatment processes, redirection of surface water and 

drainage away from foundation soils, and the use of deeper foundations. Covering If 

expansive soils are found, covering them with a moisture-conforming and protecting 

blanket of approved onsite or imported materials of low expansion potential can also 

reduce shrink/swell behavior. Implementation of these standard engineering 

methods would reduce potential impacts to a less-than-significant level. If the 

studies result in a significant redesign of the Project, then recirculation of the EIR 

may be required. 

Mitigation Measure 3.6-6: Evaluate subsurface conditions and analyze excavation 

and grading slopes for stability and incorporate recommendations into grading 

plans and construction operation activities. 

Temporary construction slopes and existing natural or constructed slopes impacted 

by construction operations will be evaluated for stability. In developing grading 

plans and construction procedures, the stability of both temporary and permanent 

cut, fill, and otherwise impacted slopes will be analyzed. Construction slopes and 

grading plans will be designed to limit the potential for slope instability, maintain 

adequate drainage of improved areas, and minimize the potential for erosion and 

flooding during construction. During construction, slopes affected by construction 

operations will be monitored and maintained in a stable condition. Construction 

2-4 ES092008001PHX\BAO\082970001


activities likely to result in slope or excavation instability will be suspended during 

and immediately following periods of heavy precipitation when slopes are more 

susceptible to failure. 

Appropriate construction methods and procedures, in accordance with state and 

federal health and safety codes, will be followed to protect the safety of workers and 

the public during trenching and excavation operations. A design-level geotechnical 

investigation will be performed to evaluate subsurface conditions, identify potential 

hazards, and provide information for development of excavation plans and 

procedures. If the studies result in a significant redesign of the Project, then 


2.2.2 Land Use Compatibility 

Several comments received by the City question the compatibility of the proposed Project 

with the existing residential neighborhood, including building size and scale and Project 

proximity to other community care facilities within the City. Other comments are concerned 

with compatibility of the proposed Project and the Fountaingrove Ranch Planned 

Community District Policy Statement (FRPCD Policy Statement), including possible 

requirements regarding flat-padding, grading, and landscape screening. These issues were 

addressed in the Draft EIR; summaries of the analyses presented and the corresponding 

page numbers in the Draft EIR are provided below. 

As stated in the Draft EIR, community care facilities are allowed in any land use designation 

and any zoning district in the City through a Conditional Use Permit (Draft EIR p. 3-113). It 

is the City’s policy to provide incentives for assisted and senior care facilities and for this 

reason community care facilities are permitted under the Santa Rosa 2020: General Plan 

(General Plan) regardless of surrounding land uses (Policy H-D-14, Draft EIR p. 3-114). 

In terms of zoning, the Fountaingrove Ranch area has been zoned as a Planned Community 

since 1972. Since 1981, the Fountaingrove Ranch area has been governed by the FRPCD 

Policy Statement (Draft EIR p. 3-113). As discussed in the Draft EIR, the development plan 

that accompanies the FRPCD Policy Statement, as adopted per Ordinance Number 2196, 

designates the Project site as a Cluster Residential (CR) Land Use Area, which allows for a 

range of land uses, including single-family homes, apartments, group dwellings, child 

nurseries, churches, health care facilities, private recreational facilities, and accessory 

buildings and uses (Draft EIR p. 3-113). The Project site is located within a Housing Bonus 

Area, which per the FRPCD Policy Statement, allows for development density of up 15 units 

per gross acre (Draft EIR p. 3-114). No portion of the site as “tree/vegetative grouping.” 

The Project is consistent with the guidance and requirements of the Development Concept 

Plan in the FRPCD Policy Statement. Some specific guidelines and requirements are listed 

below. 

• Section VI(B)(2) of the Policy Statement states that “[t]he Development Concept Plan is 

general and conceptual in nature; it is intended to illustrate generally buildable and 

generally open areas within Fountaingrove. It is not intended to be specific to the extent 

that it may be exactly scaled. The Plan shall serve as a Framework for specific 

development proposals, and establishes the basic concept of retention of exposed 

hillsides.” 

ES092008001PHX\BAO\082970001 2-5


• Objectives for the entire 1,250-acre Fountaingrove Ranch district include “retain[ing] the 

general topographic and tree mass characteristics of the site and to protect other major 

natural features of the site.” The objectives are intended to provide guidance for the 

whole area, not be used as requirements for individual development projects. The 

Project supports this objective by retaining the general topography of the site (see bullet 

below on flat padding), retaining some of the native trees, and preserving Piner Creek. 

There are no rock outcroppings on the site that would constitute a major natural feature. 

• The Project will be consistent with the General Provisions for Landscaping 

(Section IV(D) in the FRPCD Policy Statement), including compliance with the City’s 

tree removal ordinance and protection during construction of trees to be retained. 

Detailed landscaping plans will be completed during the design review process. 

• Design standards regarding “flat padding” (Section VI(E)(4)) applies to development of 

individual residential units. Though this standard does not apply directly to the Project, 

the Project does meet the intent of the standard by addressing each building foundation 

separately and having “breaks” in the building heights, which decrease as the elevation 

decreases. 

Regarding the proposed building sizes, CR land use criteria do not specify maximum 

building height, lot coverage, and setbacks (Draft EIR p. 3-114). Instead, individual criteria 

are established for each project by its Use Permit. As mentioned above, because the Project 

is designated as a community care facility, it is allowed in any zoning district through the 

Conditional Use Permit process. The Conditional Use Permit is required for community care 

facilities and for development within the FRPCD to establish allowed uses, dimensional 

standards, landscape requirements, parking requirements, and other development 

standards (Draft EIR p. 3-120). It is the Conditional Use Permit application review by the 

City that ultimately determines what the acceptable project size, grading, and landscaping 

requirements. 

General Plan Policy LUL-E-3 requires the City to avoid the concentration of large 

community care facilities in any single residential neighborhood (Draft EIR p. 3-120). In the 

northeast part of the City, existing continuing care facilities include Brighton Gardens, 

Varenna, and Vineyard Commons. Determination of what is considered a “concentration” 

of facilities is made on an individual basis by the City; in the case of the proposed Project, 

the City’s Community Development Department has determined that the Project will not 

create a concentration of community care projects in the area because the facilities are within 

a variety of neighborhoods. 

2.2.3 Oak Trees and Oak Woodland 

Some comments expressed confusion about the number of trees protected under the City’s 

ordinance that would be removed by the Project, how many and what species of trees 

would be required to be replanted on the site, and how the replanted trees would be 

accommodated on the site. These items are addressed below. 

Oak trees within the Project’s Study Area were evaluated in 1999 and then reevaluated in 

April 2006 (see Draft EIR p. 3-42). An inventory and evaluation of all trees over 4 inches in 

diameter breast height (dbh) or 54 inches above grade, unless otherwise noted, was 

conducted, the results of which are reported in the Fountaingrove Lodge Arborist’s Report 

2-6 ES092008001PHX\BAO\082970001


Tree Inventory and Evaluation, included as Appendix E of the Draft EIR. It should be noted 

that the numbers of trees to be removed is the best estimate currently available; during final 

Project design, minor changes may be made in the final designation of trees to be removed. 

However, the evaluation included in the Tree Inventory in Appendix E is an accurate 

representation of the magnitude of the potential impact. 

As described in Impact 3.4-1 of the Draft EIR, of the 513 trees located in the Study Area, 

approximately 338 trees (66 percent) are proposed to be removed during construction of the 

Project, and approximately 175 (34 percent) would be preserved. The trees to be removed 

include 78 valley oaks, 138 coast live oaks, 24 blue oaks, 75 black oaks, 11 California bays, 

and one madrone under protection by the City, including approximately 120 native heritage 

trees (Landesign Group, 2006), as defined by the City Code Title 17. As stated in Appendix E 

of the Draft EIR, many site visits and meetings with the engineers and landscape architects 

were conducted to identify the best quality trees and groups of trees to retain wherever 

possible (see Arborist’s Report Summary, October 9, 2006). Grading, walkways, and other 

features were relocated and revised to preserve quality trees and groves. The City 

recognizes that incorporating tree avoidance directly into the Project design (as described 

above) is not sufficient to reduce the impact of oak tree removal to less than significant 

levels. For this reason, the City will implement the mitigation measures described in the 

Draft EIR (Mitigation Measures 3.4-1a, 3.4-1b, and 3.4-1c). As described in the Draft EIR, 

mitigation for loss of protected native trees will be mitigated primarily with onsite tree 

plantings (Draft EIR p. 3-56). Mitigation Measure 3.4-1a states that the Project shall comply 

with City of Santa Rosa Municipal Code Chapter 17-24, which requires replacement of two 

15-gallon trees for each 6 inches, or fraction thereof, of trunk diameter of a tree to be 

removed (see Draft EIR p. 3-56). Table 3.4-3 in the Draft EIR shows the initially proposed 

replacement, should the trees replaced be 15-gallon container size. Based on the total of 

338 trees to be removed, a total of 2,107 15-gallon sized trees would be required for 

replacement. 

Tree replacement ratio is subject to approval by the City, where the ratio may be modified to 

require a greater number of smaller trees or, conversely, fewer numbers of a larger size (see 

Draft EIR p. 3-56). For example, the City may further refine its replanting requirements for 

fewer, larger (36-inch-box) trees, rather than using a greater number of smaller (15-gallon) 

trees. In this example, based on an estimated onsite tree replacement mitigation factor of one 

(1) 36-inch-box tree for seven (7) 15-gallon trees, a total of 290 thirty-six-inch-box trees 

would be required for replanting (Landesign Group, 2008). A 36-inch-box tree would be 

larger than a 15-gallon tree, at a height of approximately 8 to 10 feet when planted. The 

coast live, valley, and black oak trees are expected to grow approximately 18 inches to 2 feet 

per year after root establishment. Blue oaks are expected to grow slightly slower. 

As specified in the Mitigation Measure 3.4-1a, a tree replacement plan will be submitted to 

the City’s Department of Community Development for approval. The plan shall include the 

number of trees to be removed, the number of replacement trees, and the onsite location of 

the replacement trees. The plan will also include success criteria for tree survival and 

replacement. In general, plantings are expected to be done around the perimeter of 

buildings and along roadways and parking areas, and adjacent to areas of trees to be 

preserved where feasible. Lot coverage (areas of buildings, parking lots, circulation ways, 

paved walkways, and patios) is approximately 46 percent (see Section 2.4.2 of the Draft 

ES092008001PHX\BAO\082970001 2-7


EIR), or about 4.53 acres. This leaves up to 5.3 acres on the site on which the trees can be 

planted, an area that can accommodate 290 trees.Approval of the Tentative Map and 

Conditional Use Permit for the project will not be provided until the Applicant submits an 

acceptable tree replacement plan approved by the City. 

To preserve and protect trees that will not be removed as part of the Project, Mitigation 

Measures 3.4-1b and 3.4-1c will be implemented. These mitigation measures include 

showing all trees to be preserved and trees to be removed on all plans as well as 

implementation of best management practices (BMP) during construction to protect tree 

trunks and areas within the drip line and root protection zones, a standard construction 

practice for projects involving oak and native tree removal. The Mitigation Monitoring and 

Reporting Program in the Final EIR outlines the responsible entity for mitigation, 

monitoring, and reporting activities. 

Several commenters stated impacts to oak woodland had not been addressed or adequately 

mitigated. These items are addressed below. 

Descriptions of the oak woodland are presented in several places, including Section 3.4.1 of 

the Draft EIR and Section 4.1.2 of Appendix I, Biological Resources Assessment Report 

(BRAR). It should be noted that the BRAR Study Area described in Appendix I extended 

beyond the boundaries of the Project site, and so estimated areas of habitat are slightly 

larger than what is present on the Project site. Approximately 6.08 acres of mixed oak 

woodland are present in the BRAR Study Area; approximately 5.78 acres are present on the 

Project site itself. The oak woodland on the Project site includes dense, crowded native 

evergreen and deciduous oaks, intermingled with other species. The trees vary widely in 

condition, ranging from sparsely-foliaged trees with extensive branch dieback to 

densely-foliaged, excellent specimens, as is common in areas with poor soils and crowded 

trees. Many trees show extensive decay and dieback. Although protected and heritage trees 

within the oak woodlands are afforded special review and protection under the City’s Tree 

Ordinance, the oak woodland vegetation type within the Study Area as classified by 

Holland (1986) is not one of the oak woodland types included on the List of California 

Natural Communities as a “special” community for which lead and trustee agencies would 

require an impact assessment in environmental documents. 

Although the quantity of oak woodland that would be lost as a result of the Project is not 

explicitly stated in the Draft EIR, the quantity is implicitly provided in two ways. Because 

most of the trees on the site are within the mixed oak woodland habitat, the removal of 

approximately 66 percent of individual trees (see Draft EIR Impact 3.4-1) would roughly 

correspond to removal of approximately 3.8 acres (66 percent of 5.78 acres). Conversely, as 

noted in the Draft EIR in Section 2.4.2, approximately 8 acres of the site will be impacted by 

grading and construction activities, leaving just under 2 acres undisturbed. Because of 

efforts by the Applicant and the City to minimize oak tree impacts, almost all of the 

undisturbed area will consist of oak woodland. This would correspond to removal of 

approximately 3.8 acres of oak woodland. During the Design Review process, the City will 

work with the Applicant to further reduce these impacts as feasible. 

As noted by several commenters, oak woodland provides ecological benefits such as 

wildlife habitat that would be impacted by loss of oak woodland. These impacts were 

evaluated and mitigation provided as described in the Draft EIR in Impact 3.4-3 (loss of 

2-8 ES092008001PHX\BAO\082970001


raptor and migratory bird nesting habitat and impacts to nesting non-special-status birds); 

Impact 3.4-4 (impacts to roosting and maternity colonies of special-status bat species); and 

Impact 3.4-7 (disturbance to existing wildlife corridors). All impacts will be mitigated to a 

less than significant level. 

As described in Impact 3.4-1, the loss of protected and heritage valley oaks and other native 

trees is a potentially significant impact, and by implication, the City agrees that loss of oak 

woodland is also a potentially significant impact. Mitigation Measures 3.4-1a, 3.4-1b, and 

3.4-1c would mitigate impacts to oak woodland as well as to individual trees. Under 

Mitigation Measure 3.4-1a, replanting of native tree species typical of mixed oak woodland 

will be done on an area of up to 5.3 acres in size. 

2.2.4 Noise 

Several comments received by the City state that the analysis of noise impacts in Section 3.10 

of the Draft EIR does not accurately address the impacts that would occur. In addition, 

several commenters questioned the feasibility of Mitigation Measure 3.10-2 to implement 

noise-reducing measures for rooftop mechanical equipment, given the proposed design of 

the roof. 

Descriptions of Project operations that could generate noise are included in several parts of 

the Draft EIR, including Section 2, Project Description; Section 3.3, Air Quality; and 

Section 3.13, Traffic, and include vehicle traffic and mechanical equipment noise. Predicted 

noise levels from the Project were compared to existing noise levels, which were determined 

by taking 24-hour continuous noise measurements in two locations in the neighborhood (see 

Appendix O Noise Study in the Draft EIR). As described in the Noise Study (Appendix O to 

the Draft EIR) and Impact 3.10.1, traffic from the Project would increase noise levels by less 

than 1 decibels A scale (dBA) over current levels, and impacts would be less than 

significant. 

Commenters requested additional clarification of noise impacts from delivery trucks and 

“24/7 operations.” An estimated four delivery truck trips per day would occur as part of 

Project operations, as described in Section 3.3.3 of the Draft EIR. Delivery trucks would 

operate during daytime hours. Although a brief increase in noise may occur from individual 

delivery trucks, the noise would be similar to Federal Express, UPS, and other delivery 

trucks that already operate in the neighborhood. The only nighttime operation will be shift 

changes of a small number of employees (5 employees on-shift at 10:00 p.m. and 30 

employees off-shift at 10:30 p.m.; see page 5 of the traffic study in Draft EIR Appendix P). 

Nighttime operations will otherwise be typical of residential areas. Common areas that 

could be used for entertainment are in the center of the parcel, oriented toward the golf 

course; noise from activity in these areas would not significantly affect neighboring areas. 

As described in Impact 3.10-2, mechanical equipment may be located on the Care Center 

rooftop. Mechanical equipment will be typical of residential buildings and include 

ventilation and air conditioning equipment. The location of equipment on the rooftop, while 

unlikely to increase noise levels above the existing noise levels in the neighborhood north of 

the Project site, could be noticeable to the adjacent neighborhood, depending on the 

placement and type of equipment used, and could result in a significant noise impact. 

Mitigation Measure 3.10-2 describes noise insulation features that will be incorporated into 

ES092008001PHX\BAO\082970001 2-9


the Project design as needed. Where equipment is mounted on a sloped roof, it is installed 

within a well so that it does not protrude from the roof and sound insulation is provided by 

the walls of the well. CEQA Guidelines Section 15126.4(B) states that “[mitigation] measures 

may specify performance standards which would mitigate the significant effect of the 

project and which may be accomplished in more than one specified way.” Mitigation 

Measures 3.10-is based on a performance standard that will be implemented during final 

design. 

Construction noise impacts are detailed in the noise study (Appendix O to the Draft EIR) 

and are described in Impact 3.10-3 in the Draft EIR. Noise produced by construction 

activities would be audible and exceed existing noise levels in the vicinity of the Project site 

during the construction period, constituting a significant but temporary noise impact. 

Mitigation Measure 3.10-3 outlines BMPs for the contractor to minimize construction noise 

impacts to the degree feasible. Because residents are assumed to be at home during the 

night, the mitigation measure correctly identifies daytime hours (7:00 AM to 7:00 PM, 

Monday through Saturday) as the time when the number of people in the neighborhood is 

at its lowest. Construction duration is expected to be 19 months; the greater noise-producing 

construction activities would last only a portion of this time during earthwork and 

foundation construction activities. Because impacts are short-term, and noise levels would 

be reduced through the BMPs in Mitigation Measure 3.10-3, noise impacts from construction 

will be less than significant. 

2.2.5 Local Traffic 

Several comments were made regarding adequacy of the analysis of traffic impacts along 

Thomas Lake Harris Drive and its intersections and requested clarifications about the 

location and timing of Mitigation Measure 3.13-1, Add a traffic signal on Thomas Lake 

Harris Drive. 

Data from the traffic analysis performed by The Crane Transportation Group (see Draft EIR 

Appendix P) was used to evaluate potential traffic impacts from the Project, as described in 

Section 3.13 of the Draft EIR. An exact prediction of the amount of traffic on the possible 

routes used by the visitors and residents cannot be accurately made and such exhaustive 

impact analysis is not required by CEQA. To comply with CEQA, the analysis focused on 

the main routes that would carry the majority of traffic. By concentrating analysis on 

the intersections with greatest potential for impact, the need for mitigation is 

similarly focused where appropriate. Minor traffic routes and intersections, including 

Stonefield Lane, were not considered by the City as major locations with 

potential Project impacts and therefore were not included as part of the focuses traffic study 

(2006 Crane Report, p. 6). See also Response to Comment Epperly-14. The number of trips 

generated by the Project were estimated using a standard estimation measure (based on 

facility type) generated by ITE Trip Generation Handbook, a commonly used source. Based 

on the Handbook, a project of this size and type would generate approximately 422 daily 

round trips (dispersed over 24 hours). To further focus the impact analysis, trips occurring 

during the AM and PM peak hours were considered as they would yield the greatest 

potential for congestion. One-way trips generated by the Project were estimated to be 

29 (AM peak hour) and 44 (PM peak hour). As shown on Figure 9 in the traffic study in 

Draft EIR Appendix P, the Project would generate an additional two cars per hour 

2-10 ES092008001PHX\BAO\082970001


(peak PM) at the intersection of Thomas Lake Harris Drive and Cross Creek. This is not a 

significant impact to this intersection; no stop signs are required as a result of the Project. 

Several comments received regarding traffic impacts appear to have resulted from 

commenter misunderstanding of the documents provided in the Draft EIR Appendix P. 

CEQA is intended to be a dynamic process by which the lead agency researches, analyzes, 

and determines the potential environmental impacts of a project. This process is not 

necessarily linear and the lead agency can reconsider issues and technical opinions as the 

EIR is developed. Although data and analysis from the Crane Transportation Group study 

in Appendix P were used in preparation of the Draft EIR, the conclusions presented in the 

Draft EIR were drawn independently by the City’s EIR consultant and the City after 

considering the study data. 

As described in the first paragraph of Impact 3.13-1, the Project would increase the average 

delay for left turns to Fountaingrove Parkway at the intersection of Fountaingrove Parkway 

and Thomas Lake Harris Drive West by 20 seconds during the AM peak hour and 

29 seconds during the PM peak hour. These additions in traffic are substantial in relation to 

the existing traffic load and would result in significant delay impacts. As described in the 

second paragraph of Impact 3.13-1, the impact to the intersection of Fountaingrove Parkway 

and Thomas Lake Harris Drive East would be less than significant because delays would be 

increased there by approximately 1 second per vehicle. Therefore, the traffic signal included 

in Mitigation Measure 3.13-1 would be installed at the intersection of Fountaingrove 

Parkway and Thomas Lake Harris Drive West. Addition of the traffic signal would improve 

the level of service at the intersection over current conditions, which would reduce the 

impact to a less than significant level. Mitigation Measure 3.14 has been clarified as follows. 

Mitigation Measure 3.13-1: Add a traffic signal on Thomas Lake Harris Drive. 

A three-legged signal shallwill be installed at Thomas Lake Harris (West) and 

Fountaingrove Parkway. This traffic signal would alleviate the need for a westbound 

right-turn deceleration lane and an eastbound left-turn acceleration lane on Thomas 

Lake Harris Drive. In addition to the traffic signal, there will be a need to increase 

the radius of the curb return on the northeast quadrant of the intersection to improve 

the flow of the westbound to northbound right turn. The traffic signal would be 

interconnected (timed) with the existing traffic signals at the intersection of 

Fountaingrove Parkway and Round Barn Boulevard, as well as the intersection of 

Fountaingrove Parkway and Altruria Drive. This would result in an improvement 

over the existing LOS. 

The City does not require improvements to be made before actual construction; installation 

of the traffic light will occur at the City’s discretion. Financing of the traffic light will come 

from payment by the Applicant. The Traffic Impact Fee was combined with the Public 

Impact Fee to be incorporated into a single Community Facilities Fee (CFF), which is paid 

regardless of improvements or signals installed and is collected with the issuance of a 

building permit. The CFF is deposited into a fund for Citywide improvements and used as a 

financial resource for Public Works Capital Improvement Projects. 

While Project impact to the collector (neighborhood) streets surrounding the site is 

considered less than significant, the City will require construction vehicles to access the site 

ES092008001PHX\BAO\082970001 2-11


using the west intersection of Thomas Lake Harris Drive and Fountaingrove Parkway; this 

will limit construction traffic in the adjacent neighborhoods. 

Impact 3.13-3 considers whether the Project could result in an increase in hazards due to a 

design feature (e.g., sharp curves or dangerous intersections) or incompatible uses. While 

the impact analysis determined that the Project would not result in a significant increase in 

traffic along Thomas Lake Harris Drive, to further reduce potential hazards to pedestrians 

who want to cross Thomas Lake Harris Drive, a new pedestrian crossing will be included as 

a condition of Project approval. This is not considered a mitigation measure under CEQA 

because it is not being implemented to lessen a significant impact. The Applicant will install 

a speed table to reduce potential hazards to pedestrians who want to cross Thomas Lake 

Harris Drive; the crossing would be a raised speed table marked as a pedestrian crossing 

equipped with a pedestrian-activated flasher (Draft EIR p. 3-165). 

2.2.6 Visual Resources 

A number of the comments raise concerns that the analysis in the Draft EIR does not 

properly account for the visual effects of the grading that will occur on the site, the retaining 

walls that will be required, and the massing of the buildings. In some cases, these comments 

suggest that the analysis is deficient because the EIR does not include a grading plan or 

cross sections of the site. Other comments question the accuracy of the simulations, 

suggesting that they do not accurately portray the site grading, retaining walls, and 

structures. 

As indicated in Section 3.1.3 of the Draft EIR, the analysis of the Project’s visual effects was 

based on review of the visual simulations presented in Figures 3.1-4 through 3.1-7. As the 

text in Section 3.1.3 indicates, these simulations were prepared using a high-end threedimension 

(3-D) visualization software. This software was used to integrate the data 

available from the site grading plan, the architectural plans for the buildings, and the 

landscape plan to create a highly accurate 3-D digital model of the Project. This model, in 

turn, was used as part of a systematic process to create accurate simulations of the Project as 

it would appear in the views from the four analysis viewpoints, including removal of trees 

required for Project construction. Given the reliance on the detailed data on Project design 

to build the 3-D model of the Project, the use of a widely accepted software program to 

create the 3-D model and simulations, and the systematic protocol followed to permit 

proper scaling of the Project features and placement in the views, the resulting simulations 

provide highly accurate depictions of the Project’s appearance. The simulations provide an 

accurate depiction of the end results of the proposed grading of the site and the construction 

of the retaining walls and buildings; these aspects of the proposed project have been taken 

into account in the analysis of the Project’s visual impacts. 

The trees and other landscaping visible in the simulations were rendered to reflect the size 

and level of maturity they would have approximately 5 to 10 years after their installation. 

Thus, the simulations represent the appearance that the Project would have in 5 to 10 years 

when the trees would be small and provide limited screening but before the trees attain 

their full maturity and provide a more complete level of screening. More detail on tree 

replanting is included in Master Response Oak Trees and Oak Woodland. 

2-12 ES092008001PHX\BAO\082970001


In response to comments indicating an interest in seeing depictions of the Project as it would 

appear immediately after construction and before the landscaping has grown out, a 

supplemental set of simulations has been prepared. These simulations, presented in this 

document as Views 1, 2, 3, and 4, depict the views of the Project from each of the Key 

Observation Points as they would appear immediately after completion of construction and 

installation of the landscaping. As review of these simulations indicates, although the 

recently planted trees and shrubs would provide some level of screening, the retaining walls 

and structures would be more visible than would be the case in the simulations presented in 

the EIR, which depict the level of landscape maturity and screening that would exist 5 to 

10 years after project completion. 

The CEQA Guidelines include no provisions that require that visual resource analyses 

include grading plans or project cross sections as a part of their analyses. However, in 

Appendix C of its Design Guidelines, the City requires that applications for certain 

developments (which would include projects like Fountaingrove Lodge Project) include a 

“three dimension Visual depiction.” The Guidelines specify that “[t]he three dimension 

visual depiction must illustrate how the completed project will look as seen from public 

areas” and provide a range of options for the form that this depiction might take. One of the 

options is “[a] computer generated simulation.” Because this visual analysis includes four 

computer-generated simulations of the Project, it is consistent with the City’s requirements. 

The City does not require that the visual analysis must also be accompanied by a grading 

plan and cross sections. 

As described in Impact 3.1-3, implementation of the Project would result in new sources of 

light with the addition of nighttime security lighting along driveways, in outdoor parking 

lots, and near building entrances. The presence of this lighting on a site that now does not 

contain substantial sources of nighttime illumination has the potential to substantially affect 

nighttime views in the area. To some degree, the building massing and the trees retained 

and planted on the site will attenuate these effects, but if unshielded and poorly directed, 

the light fixtures could cause offsite light impacts. Mitigation Measure 3.1-3 requires strict 

conformance with the City’s Lighting Design Guidelines and the Principles of Low-impact 

Lighting Design. These guidelines and principles include measures such as restricting 

outdoor lighting to areas where it is essential for safety and security and use of light fixtures 

that eliminate uplighting and that are shielded to prevent light spill. Incorporation of these 

measures will be confirmed during the design review process and will minimize the amount 

of nighttime light that leaves the site. No significant impacts will occur. 

2.3 Comments and Responses to Comments on the Draft EIR 

This section contains, in alphabetical order, copies of the comment letters and public hearing 

transcript on the Fountaingrove Lodge Project EIR. Individual comments within the letters 

and transcript have been enumerated, and responses to each comment are provided. 

ES092008001PHX\BAO\082970001 2-13

ES082008001BAO_Fountaingrove_publicComments_v3.indd_090408_lho 

AEGIS – 1


AEGIS – 2 

AEGIS – 3 

AEGIS – 4 

AEGIS – 5 

AEGIS – 6


AEGIS – 7 

AEGIS – 8 

AEGIS – 9 

AEGIS – 10 

AEGIS – 11


AEGIS – 12 

AEGIS – 13 

AEGIS – 14 

AEGIS – 15 

AEGIS – 16 

AEGIS – 17 

AEGIS – 18


AEGIS – 19 

AEGIS – 20 

AEGIS – 21 

AEGIS – 22


AEGIS – 22


Response to Comment Letter from Aegis Living 

Note: Response numbers correspond to comment numbers labeled in the margin of the 

letter. 

1) The Project Objective is correctly written on pages (pp.) iii and 2-2 in the Draft EIR as 

“Create approximately 135 community care facility units.” While the Applicant may 

propose construction of 136 units, it is not the specific objective of the City to do so. 

The Project Components section on page (p.) iii of the Draft EIR has been amended 

as follows: Eight Six two-bedroom community care units in the form of duplexes and 

detached cottages. 

Section 2.1, Background and Project Origin, section on p. 2-1 of the Draft EIR has 

been amended as follows: “The Project site is defined as two three lots designated in 

the Development Concept Plan as Cluster Residential land use.” 

Section 2.4.1, Project Components, description of the Main Building on p. 2-7 of the 

Draft EIR has been amended as follows: “The building will be two and three stories 

over a lower-level parking structure and will have a maximum height of 49 feet.” 

Section 2.4.1, Project Components, description of the Flats on p. 2-7 of the Draft EIR 

has been amended as follows: “The two and three-story building will have a 

maximum height of 37 feet, with two tower exceptions (elevator tower at 46 feet and 

stairway tower at 41 feet) that total 5 percent of the building footprint.” 

2) Section 2.4.1, Project Components, description of Offsite Improvements on p. 2-11 of 

the Draft EIR has been amended as follows: “A raised crosswalk on Thomas Lake 

Harris Drive between the Flats Building and Employee Housing (Lot 3)at Gullane 

Drive will be added.” 

3) Section 2.4.1, Project Components, description of the Loading/Staging Area and 

Trash/Recycling Enclosures on p. 2-11 of the Draft EIR has been amended as 

follows: “Trash and recycling enclosures are provided in three major locations: at the 

southwest corner of the Care Center, in the covered parking area under the west 

wing ofnext to the Main Building and at the northwest corner of the employee 

housing. In addition, smaller trash/recycle rooms will be located within the main 

building, flats building, and care center. in an area of The total area of all 

trash/recycling locations is approximately 810 ft 2.” 

4) Comment noted. Requirements for tree replanting are described in more detail in 

Mitigation Measure 3.4-1a of the Draft EIR and in Master Response Oak Trees and 

Oak Woodland of this Final EIR document. The exact number and size of the 

replacement trees and/or other tree mitigation would be determined through the 

development permit process and may consist of a variety of tree sizes and types. 

5) As noted in Impact 3.4-6 of the Draft EIR, a focused rare plant survey was conducted 

on October 5 and 14, 2005, June 16, 2006, and February 16 and April 9, 2007. 

However, it should have been noted that these rare plant survey dates corresponded 

to the general blooming periods for observing and identifying all but two, not seven, 

of the special-status plant species with potential to occur at the Project site, as 

2-22 ES092008001PHX\BAO\082970001


identified in Table H-1 Special-Status Plant Species Potentially Occurring within the 

Fountaingrove Lodge Study Area in Appendix H to the Draft EIR. These two species 

are streamside daisy, which has a low potential of occurrence and blooms between 

July and September, and wooly-headed lessengia, which has a very low potential of 

occurrence and blooms in mid- to late August. This correction is shown in 

Section 3.0, Errata and Revisions, of this Final EIR. Because the rare plant surveys 

were conducted over a period of 3 years, during early, mid-, and late season 

blooming periods; the wooly-headed lessengia and streamside daisy have, 

respectively, very low and low potential for occurrence; and the multiple focused 

rare plant surveys did not reveal the presence of any special-status plant species. 

Potential impacts to special-status plant species are considered to be less than 

significant, as noted in Impact 3.4-6. However, it is still possible that rare plant 

surveys may be required by the applicable resource agencies, including California 

Department of Fish and Game (CDFG) and U. S. Fish and Wildlife Service (USFWS), 

based on their review of the EIR and Rare Plant Survey Report, included as 

Appendix G to the Draft EIR. 

6) Table 3.4-3 indicates in table footnote “c” that olive trees do not require replacement 

under the City of Santa Rosa Tree Ordinance (City Code Chapter 17-24 Trees). 

Requirements for tree replanting are described in more detail in Mitigation 

Measure 3.4-1a of the Draft EIR and in Master Response Oak Trees and Oak 

Woodland of this Final EIR document. 

7) Comment noted. Requirements for tree replanting are described in more detail in 

Mitigation Measure 3.4-1a of the Draft EIR and in Master Response Oak Trees and 

Oak Woodland of this Final EIR document. 

8) The first bullet in Mitigation Measure 3.4-3 states that “[t]o avoid impacts to nesting 

avian species, Project activity shall be avoided to the degree feasible during the 

breeding season (generally, March 1 through September 15).” The specific dates of 

the breeding season to avoid nesting avian species will be confirmed with the 

resource agencies. 

9) Section 3.6, Geology, Soils, and Seismicity has been amended on p. 3-68 as follows: 

“Investigation of Fault Surface Rupture Hazard, Fountaingrove Lodge, Santa Rosa, 

California (Giblin, 2007). This study included additional trenching excavation and 

logging to resolve discrepancy regarding a possible faulting through the northeast 

portion of the Project site.” 

10) Section 3.6.1, Setting, description of Topography and Drainage, has been amended 

on p. 3-69 as follows: “Local drainage features within the Project vicinity site include 

subdued drainage swales, closed or nearly closed drainage depressions, and abrupt 

changes in stream direction and gradients.” 

11) Section 3.6.1, Setting, description of Bedrock has been amended on p. 3-70 as follows: 

“Scattered test pits dug by Giblin Associates showed lava flow rocks, agglomerate, 

tuffaceous, and sedimentary rocks. Bedding observed indicated that the rocks in the 

central portion of the property are folded in an anticline (concave downward). Beds 

are gently folded with dips varying from gently eastward at the higher elevation in 

ES092008001PHX\BAO\082970001 2-23


the eastern property area to moderately down to the west in proximity to Thomas 

Lake Harris Drive. A northwest strike interrupts these rocks to form a crude layering 

or bedding with a moderate westerly dip of about 25 to 30 degrees.” 

12) Figure 3.6-4, Local Geology Map, has been replaced with Plate 3 of Giblin Associates’ 

Investigation of Fault Surface Rupture Hazard Report, December 2007. The revised 

figure is included in Section 3.0, Errata and Revisions, of this Final EIR. 

13) Comment noted. The 1997 version of Special Publications 42 was used during 

preparation of the Draft EIR. The reference in Section 3.6.4 contains a typo and 

should read: 

“1992. Fault Rupture Hazard Zones in California, Alquist-Priolo Special Studies 

Zones Act of 1972 with Index to Special Studies Zones Maps. California Division of 

Mines and Geology Special Publication 42, Revised 1997.” This correction is included 

in Section 3.0, Errata and Revisions, in this Final EIR. 

14) Section 3.6.1, Setting, description of Local Faulting has been amended on p. 3-84 as 

follows: “California Geological Survey Special Publication 42 requires a site-specific 

fault study if a site is within an Alquist-Priolo zone.” 

15) Comment noted. No formal revision to the Draft EIR is required. 

16) Comment noted. No formal revision to the Draft EIR is required. 

17) The second bullet on p. 3-86 has been amended as follows: 

A 20- to 25-foot-thick landslide colluvial soil deposit in the swale near the north end 

of the Project site. This deposit, consisted of debris flow and pond sediment, and the 

underlying bedrock appear to be part of an ancient landslide movement. 

18) The last paragraph on p. 3-120 has been amended as follows: “Progressive care 

needs of residents would be addressed by the proposed 36-unit Care Facility by 

providing high-acuitysecurity assisted living and memory support/Alzheimer’s 

care.” 

19) Comment noted. The City does not agree with the commenter’s position on the 

Community Facilities District. Measure “O” does not provide all the funding 

necessary for police and fire services to operate according to their public obligations. 

Measure “O” was designed to target existing and past financial shortcomings, not to 

address future growth. Therefore, additional funding is necessary through a 

Community Facilities District where growth is creating additional demands for fire, 

police, street maintenance, and similar City services. Mitigation Measure 3.11-2a is 

considered by the City as a mandatory component of the proposed Project to 

mitigate its impact on fire and police services. 

20) See Master Response Local Traffic. 

21) See Master Response Local Traffic. Applicant will be solely responsible for signal 

construction and installation as required by the City with conditioning of the 

Project. There is no longer a separate Traffic Impact Fee to be issued for the Project. 

The Traffic Impact Fee was combined with the Public Impact Fee to be incorporated 

2-24 ES092008001PHX\BAO\082970001


into the Community Facilities Fee (CFF), which is paid regardless of improvements 

or signals installed, and is collected with the issuance of a building permit. The CFF 

is deposited into a fund for Citywide improvements and used as a financial resource 

for Public Works Capital Improvement Projects. 

22) CEQA draws a distinction between individual project impacts and cumulative 

impacts, which are created as a result of the combination of the project evaluated in 

the EIR together with other projects causing related impacts. There are no significant 

individual Project impacts, including traffic impacts (see Draft EIR pp. 3-163 through 

3-165). However, as described in Draft EIR Section 4.1.13, Transportation and Traffic 

(cumulative impacts), Mendocino/Fountaingrove, Mendocino/Bicentennial, and 

U.S. 101 Northbound Ramps/Old Redwood intersections would remain at level of 

service (LOS) F under the analyzed cumulative scenario. This incremental 

contribution by the Project to this existing traffic condition is considered significant 

and unavoidable. As noted in Section 4.1.1.13, various projects are proposed or 

underway for improvements to address these issues, as mitigation; however, even 

with these projects, U.S. 101 and some associated ramps are expected to remain at 

LOS F. No additional mitigation for this cumulative impact has been proposed at 

this time. 

ES092008001PHX\BAO\082970001 2-25


Gerut, Mary/BAO 

From: Galbraith, Joel [JGalbraith@ci.santa-rosa.ca.us] 

Sent: Tuesday, July 29, 2008 8:11 AM 

To: Gerut, Mary/BAO 

Subject: FW: Fountaingrove Lodge 

Attachments: 3881054766-To The Editor.docx 

From: Niewald, Anette 


To: Galbraith, Joel 


Anette Niewald 

Community Development/Planning Division 

City of Santa Rosa 

(707) 543-3226 

aniewald@srcity.org 

From: Tom Karsten [mailto:tk@mkgrp.com] 

Sent: Monday, July 28, 2008 9:28 PM 

To: Niewald, Anette 


From: Elizabeth Anderson [mailto:norcaltraveler@sbcglobal.net] 


To: scott@hallandbartley.com 

Cc: ncaston@sonic.net; pacisco@aol.com; Vicki@15000inc.com; Tom Karsten; davidpoulsen816@msn.com 

Subject: Fountaingrove Lodge 

To the Planning Commission: 

8/1/2008 

Page 1 of 1 

Attached is a letter regarding the Fountaingrove Lodge project. Thank you for your kind attention to this very 

important matter. 

Sincerely, 

Dr. Thomas L. Toth & Elizabeth Anderson 

4464 Kilarney Circle 

Santa Rosa, Ca 95403 

707-576-7972


ANDERSON – 1 




July28,2008 

 

DearMr.Bartley: 

LetuspredicatethisletteronthepremisethattheonlypositiveaspectsoftheFountaingroveLodge 

projectarethemarketingtotheLGTBcommunityandhousingforemployees.Quitehonestly,wewish 

wehadhadthevisionandthecapitaltoembarkonsuchaprojectourselves. 

However,wehaveveryseriousconcerns.Sincepastbehaviorisanexcellentindicatoroffuture 

behavior,itisreasonabletohavetheexpectationthatthecurrentplanspresentedtothePlanning 

CommissionbyAegisminimizethetrueimpactofsuchamassiveprojectonarelativelysmallpieceof 

landandtheneighboringhomes.Inreality,thisisanotheraggressiveandinvasiveprojectthatwill 

destroytheintegrityofaquietresidentialneighborhood.Thisisthesameasbuildingahotelsuchasthe 

VineyardCreekHotel&Spainaquietneighborhoodwiththeattendantimpactsofnoise,trafficsafety 

issues,lossoftrees,&lossofwildlife. 

Noonewaspreparedfortherapeandpillageofthelandthatoncehadopenspaceandbeautifultrees 

thatisnowVarenna.4storybuildingsnowareplacedonthehillside.Almostallthetreesaregone. 

Plantingyoungtreesisnotatruemitigationofremovingtheoldheritageoaks.Newtreeswillnotreach 

thesize&grandeurthedestroyedtreesinthelifetimeofanyoneinvolvedinthisproject!Varennais 

muchlargerinscopethanthevisionthatwasoriginallypresentedtothePlanningCommission. 

Varenna,uponclosescrutiny,ismerelyahighendtimeshare. 

SantaRosaneedsseniorhousingfortheLGBTcommunityandforlowincomeseniors.However,the 

parcelunderconsiderationisnottheappropriateplaceforaprojectofthissizeandmagnitude.Why 

notalongRoundBarnBlvd,ifitmustbeinFountaingrove,wherethereiscommercialland.Varenna, 

BrightonGardensandVineyardCommonsareallincommercialzones.Whymakeanexception? 

Thiscommercialventurewillhaveahighnegativeimpactforthe2storycondominiums(Stonefield)and 

thesingle&2storysinglefamilyhomes(TheOaks)thatcurrentlyexistoneithersideoftheproperty. 

Thesehomesareverymodestlysizedwithnoneover2,150squarefeet.Additionally,anadditionalof 

242parkingspacesdestroystheconceptofresidentialneighborhood.AftercarefullyreviewingEIRand 

observingongoingbuildingatVarenna,wehaveeveryreasontobelievethatthehulking3story 

behemothslatedtobecomepartoftheFLisnotevenremotelyanaccuratedepictionofthefinalresult. 

Itshouldbenoted,thatthereisalreadyaprominentbusinesssituatedacrossfromTheOaksonThomas 

LakeHarrisinthejurisdictionofSonomaCounty.ParadiseRidgeWineryalreadyhasadistinctimpacton 

theneighborhoodintermsoftrafficandnoise. 

Thebestofallworldswouldbetoprotectthislandasmitigationtothedamageincurredwhen 

developerswereallowedtobuildontheridgetopsaboveSantaRosa.However,iftheFountaingrove 

Lodgeshouldbeapproved,atleastthesizeandscopeoftheFLshouldbereducedandplacementofthe 

singleunit“casitas”couldbeplacednearcurrenthomesonGuillaneandthelargecommercialbuildings



andparkinglotsbeplacedinthemiddleoftheproject.Webelievethereisroomforcompromiseso 

thattheimpactonsinglefamilyhomeswouldbereduced. 

Thankinadvanceforconsideringallpointsofviewonthisveryimportantmatter.Wehavefaiththat 

thePlanningCommissionwillresearchthematterandinvestigatethetrueintentionsofAegis.Wealso 

hopethatthecommissionwilllookattheEIRforVarennaandcomparethevisionoriginallysetforthto 

theCommissionandseewhathasactuallytranspired. 

 

Sincerely, 

Dr.ThomasL.Toth,MD& 

ElizabethAnderson 

 

4464KilarneyCircle 

SantaRosa,Ca95403 

7075767972


Response to Comment Letter from Elizabeth Anderson and Thomas Toth, MD 


letter. 

1) Potential impacts related to the scale of the Project are addressed in Section 3.1, 

Aesthetics and Visual Resources, and Section 3.9, Land Use and Planning, in the 

Draft EIR. Compatibility with surrounding land uses is further discussed in Master 

Response Land Use Compatibility of this Final EIR. Potential impacts of the Project 

on loss of trees/wildlife, noise, and traffic are described, respectively, in Sections 3.4, 

3.10, and 3.13 of the Draft EIR. Impacts to the surrounding areas will be less than 

significant with the implementation of mitigation measures. 

2) The Project is an allowed land use on the site and is consistent with applicable land 

use regulations, as described in Section 3.9 of the Draft EIR and in Master Response 

Land Use Compatibility of this Final EIR document. No significant land use impacts 

will occur as a result of the Project. 

The parcels around Round Barn Drive are potentially large enough to fit the Project 

but are currently owned by private parties. As discussed in Section 5.5 in the Draft 

EIR, other locations for the Project were evaluated; no alternative locations were 

identified that could meet the Project objectives. 

3) Potential impacts of the Project on views are described in Section 3.1 of the Draft EIR 

and in Master Response Visual Resources of this Final EIR document. Potential 

impacts of the Project on land use are described in Section 3.9 of the Draft EIR and in 

Master Response Land Use Compatibility of this Final EIR document. As noted in 

Master Response Visual Resources, the visual simulations were done correctly and 

present an accurate depiction of the Project. As noted in Master Response Land Use 

Compatibility, the Project is an allowed land use on the site and is consistent with 

applicable land use regulations. Impacts to land use and views will be less than 

significant with the implementation of mitigation measures. 

4) The Project site is unrelated to previous developments that have been implemented 

on ridgetops in the City. Mitigation required for completed development projects on 

ridgetops in the City will have been previously implemented and no further 

mitigation for those projects would be required. A Fountaingrove Lodge Project 

substantially reduced in size and scope would not meet the Project objectives. The 

Project site is generally too narrow to accommodate one of the larger buildings at the 

location currently planned for the cottages/duplexes. 

ES092008001PHX\BAO\082970001 2-29


file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Barr.htm 


Sent: Friday, July 25, 2008 1:28 PM 


Subject: FW: EIR/Aegis/Thomas Lake Harris 

From: Linda Barr [mailto:wileysgram@vom.com] 



Subject: EIR/Aegis/Thomas Lake Harris 

July 25, 2008 

Dear Mr. Galbraith, 

My name is Linda Barr and I live at 2160 Wedgewood Way in Fountaingrove. 

My neighbor and I attended the meeting last night where the EIR for the Aegis project 

was discussed. I am vehemently opposed to approval of this project. I feel that the 

density of the project is way to great for the size of the parcel. In fact, I feel that only 

low density single family dwellings should be built there. I agree with the woman who 

was concerned about the light that will be generated at night by apartments, villas, 

rooms, restaurants and the parking lot, to say nothing of the noise generated by all 

their generators, air conditioners, and delivery trucks. Fountaingrove is basically a 

residential neighborhood. As our homes are expensive, we pay high property taxes and 

should be able to expect to have privacy and protection from noise and light pollution. 

The intended project will create both kinds of pollution. I am appalled too that the 

planning commission would allow the destruction of so many old and beautiful trees. 

Far fewer trees would have to be removed if the parcel was developed as low density 

single family dwellings. I also resent all the extra traffic that this project will generate, 

and I resent the installation of yet another stop signal on Fountaingrove Parkway. I 

have been a resident of Fountaingrove for two years and I have seen a tremendous 

change in the amount of traffic, and in the amount of time that it takes me to get from 

the 101 Highway up to my house on Wedgewood Way due to the extra stop signals. 

The one at Varenna is particularly irksome. I also agree with the gentleman who 

pointed out how traffic has been reduced to a single lane for a long time as a result of 

on going construction at Varenna. I believe that the same kind of disturbance will be 

cast upon us during construction of the Aegis project on Thomas Lake Harris. I beg the 

city council and the city planning commission to deny this project. 

Incidentally, the gentleman from Florida who plans to move to Aegis, and the woman 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Barr.htm (1 of 2)8/1/2008 2:10:08 PM 

BARR – 1 

BARR – 2 

BARR – 3 

BARR – 4


file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Barr.htm 

representing the Council on Aging and particularly aging gays were not addressing the 

environmental issues. They were attempting to garner public sympathy for 

homosexuals and their plight as retirees. Let me say this, their plight is no different 

than anyone else's. Many of us live alone and face old age without the companionship 

of family. Being gay is nothing special as far as I'm concerned. Further more I think 

that the exclusiveness of this gay project should be illegal too. Why do the gays need a 

gay restricted residence? If any homosexuals were turned away from residency at 

Varenna, they would be screaming bloody murder and claiming segregation. So how do 

they get off being able to have a gay retirement village? Will black people be able to 

have a black restricted retirement village? How about Italians? Or Jews? This whole 

project is ridiculous in my opinion. 

I do not have the email addresses of all the other city council persons. Will you please 

forward my letter to them to. Thank you very much. 

Sincerely, 

Linda Barr, a concerned citizen of Fountaingrove 

578-7299 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Barr.htm (2 of 2)8/1/2008 2:10:08 PM


Response to Comment Letter from Linda Barr 


letter. 

1) See Master Response Land Use Compatibility. 

2) See Master Responses Visual Resources and Noise. For explanation of how Impact 

3.13-3 presents and accurate impact evaluation of the Project’s outdoor lighting 

plans, see Response to Community Comments – 13. 

3) See Master Responses Land Use Compatibility and Oak Tree and Oak Woodland. 

Developing the parcel at a lower density does not necessarily reduce the number of 

trees removed. The proposed Project concentrates buildings on areas of the site, 

allowing other areas to be preserved. If single-family homes were constructed 

instead, the spacing of such homes could result in even greater tree impacts. 

4) As discussed in Master Response Local Traffic and in Draft EIR Impact 3.13-1, 

installation of a traffic light is necessary to reduce delays at the Fountaingrove 

Parkway intersection with Thomas Lake Harris Drive. The Project would add an 

additional average delay for left turns to Fountaingrove Parkway by 20 seconds 

during the AM peak hour and 29 seconds during the PM peak hour at an 

intersection with existing conditions below City standards. This is a potentially 

significant impact that requires mitigation through installation of a traffic light. 

Draft EIR Section 2.4.3 includes a description of how construction vehicle traffic will 

access the Project site and where the staging locations will be located. Some of the 

offsite improvements (i.e., sidewalk along Thomas Lake Harris, sewer and water 

connections) will require temporary lane closures. Some of the onsite improvements 

(i.e., retaining walls) may require temporary lane closures. The Project is not 

anticipated to require lane closure beyond what is typical for constructions projects. 

2-32 ES092008001PHX\BAO\082970001






Subject: FW: 

Attachments: scan0001.jpg 

scan0001.jpg 

-----Original Message----- 

From: Ed Bellone [mailto:edbellone@sbcglobal.net] 



Subject: 

Joel, 

Hope all is well with you, long time no see. Please include the attached thoughts 

in your deliberations. 

Thanks, 

Ed Bellone 

1


BELLONE – 1

Response to Comment Letter from Ed Bellone 



letter. 

1) See Master Responses Land Use Compatibility and Visual Resources. 

ES092008001PHX\BAO\082970001 2-35


COOPER – 1 

Message 


Sent: Monday, July 28, 2008 8:55 AM 


Subject: FW: Fountaingrove Retirement Development Hearing 

From: Annette Cooper [mailto:ACooper@KeeganCoppin.com] 

Sent: Sunday, July 27, 2008 3:14 PM 


Subject: Fountaingrove Retirement Development Hearing 

I attended the Public Hearing on Thurs.July 24,2008....I wanted to comment the that I felt the majority of 

the comments seem to be directed at the Merits of whether this Proposed Site is suitable for development; 

as opposed to comments as to the merits of this specific project It's important to recognize that the nature 

of a Planned Development contains many lifestyle resources onsite that keep the residents within that 

community,and minimize the need to have to go anywhere..thus having positive impact on minimizing the 

traffic being generated. It's equally important to implement an intelligent plan to meet the needs of the 

baby boomers as they make their way into retirement....Finally;it's incumbent on the Planning 

Commission to determine that any opposition taken into consideration MUST be made on the actual 

merits of the project,and reasonable concerns regarding implementation of the development....It's critical 

that any opposition based on an antiquated cultural bias toward gender preference is recognized as 

prejudice,and should not be allowed to stand.....Acceptance of a Senior Gay Housing Project has the 

potential to attract an upscale cultural class that will have a positive financial impact on this society;with 

minimal impact on schools,and extended community resources. I realize the City is in an on-going 

balancing act to meet the growing housing needs of the society,while maintaining a decent quality of life 

for the community at large.There are many factors that need consideration,and Fountain grove Lodge 

appears to be meeting most of the criteria for positive housing expansion in our City.Thank you for your 

time,Annette Cooper...320 Gilbert Dr. Santa Rosa,CA.95405 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Cooper.htm8/1/2008 2:10:08 PM

Response to Comment Letter from Annette Cooper 



letter. 

1) Comment noted. As described in Section 2 of the Draft EIR, the Project objectives 

include provision of approximately 135 units of community care facility units, 

provision of quality senior care, and provision of housing for seniors with 

convenient access to medical care facilities, highways and transportation, retail, and 

recreation amenities. These objectives support policies and goals in the General Plan 

that call for projects and services to support the needs of seniors in the City (City of 

Santa Rosa, 2002). 

ES092008001PHX\BAO\082970001 2-37


DAUGARRD – 1 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Daugaard.htm 




Subject: FW: Another Varenna? 

From: allend315@comcast.net [mailto:allend315@comcast.net] 

Sent: Friday, July 18, 2008 10:35 AM 

To: Galbraith, Joel; scott@hallandbartley.com 

Subject: Another Varenna? 

Gentlemen, 

Thank you for your letter Re: Another Varenna??? I plan on attending the meeting but will 

probably not speak as I am sure there will be many more qualified persons in attendance who will 

voice opposition to the building of this facility on Thomas Lake Harris Road. The population in 

general has been asked by the Governor to conserve water. In addition, the Water Dept. as well as 

PG&E have semi-regular ads on TV asking that we cut back on our water usage and to use 

electrical appliances during the non prime time usage hours. I would like the Planning 

Commission to explain why, if our current resource levels are being strained, they continue 

to okay the building on new big projects before new resources become available. 

I fear that despite this perfunctory community meeting their minds are already made up and the 

project will be built. I believe one of my neighbors when he said"...Santa Rosa has the best 

government that money can buy!". 

Allen T. Daugaard 

2072 Stonefield 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Daugaard.htm8/1/2008 2:10:08 PM

Response to Comment Letter from Allen T. Daugaard 



letter. 

1) As described in Impact 3.14-2 of the Draft EIR, the water demand associated with 

this Project is included in the General Plan evaluation of water supply, given that the 

land use of the Project is consistent with the FRPCD Policy. The water demands for 

this Project were also included in SCWA’s Urban Water Management Plan 2000, 

which is also the City’s Urban Water Management Plan. Because current water 

demands are 23,000 acre-feet per year (afy), and only a portion of the development 

anticipated in the City’s General Plan has occurred, the City’s water supplies are 

currently sufficient to meet the present and future demand associated with this 

Project. No significant impacts to water supply would occur as a result of the Project. 

See also Draft EIR Section 3.14.1 Setting discussion of Domestic Water Supply on 

p. 3-167. 

As discussed in Impact 3.14-4 of the Draft EIR, existing electric and natural gas grid 

supply is sufficient to support the Project and is provided for in the General Plan. No 

significant impacts to energy supply would occur as a result of the Project. It should 

be noted that guidance to restrict utility use during peak hours relates to electric 

transmission capacity during peak summer use periods, not resource supply. 

ES092008001PHX\BAO\082970001 2-39


DIBBLE – 1 

DIBBLE – 2 

DIBBLE – 3 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Dibble.htm 


Sent: Thursday, July 24, 2008 1:20 PM 


Subject: FW: Fountaingrove Lodge EIR 

From: Sue Dibble [mailto:sue.dibble@gmail.com] 

Sent: Thursday, July 24, 2008 10:49 AM 


Subject: Fountaingrove Lodge EIR 

To: Joel Galbraith, Supervising Planner and Scott Bartley, Chair Planning Commission 

From: Dr. Suzanne L. Dibble & Dr. Jeanne F. DeJoseph 

We are priority members and future residents of Fountaingrove Lodge and we wanted to add our 

comments in support of the EIR. Our two biggest concerns had been the need for removal of trees 

and the increased traffic. 

After readingthe EIR on the website, we were very pleased to note that significantly 

moretrees would be planted than would be removed. We are also pleased that thetrees that will be 

planted will not be oaks since "sudden oak death" is presentin Sonoma County. We do have a 

little concern about keeping oak trees that arein poor quality (e.g. trees 16, 19) since poor quality 

oak trees provide a setup for the virus. We believe that Santa Rosa has been at the forefront 

inresponsible community planning to decrease greenhouse gasses, and this increaseof trees would 

support that plan. 

We were also concerned about traffic from the standpoint of safety. The proposed traffic light at 

Thomas Lake Harris Drive will provide an opportunity to control the flow of traffic and increase 

the safety of all of the residents of that area, not just those of Fountaingrove Lodge. Additionally 

although we currently have two cars, when we move to Santa Rosa we plan to sell one, and 

purchase an electric car for local travel. 

We are grateful to Aegis for providing this type of senior housing. And, having toured 

Varenna, we are looking forward to living in a home designed and built with the quality that 

Aegis clearly provides for residents of its properties. 

We are also grateful to the Planning Commission for releasing the draft EIR, and hope 

that you will proceed with all due speed. We are currently completing a renovation on our home 

in San Mateo in preparation for sale when Fountaingrove is complete. We are so looking forward 

to becoming active, participating members in our new community of Santa Rosa.. 

Thank you. 

-- 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Dibble.htm8/1/2008 2:10:08 PM


Response to Comment Letter from Dr. Susan L. Dibble and Dr. Jeanne F. 

DeJoseph 


letter. 

1) Comment noted. As described in Master Response Oak Trees and Oak Woodland, a 

variety of native trees, including oaks, will be replanted onsite to mitigate for loss of 

protected trees. Greenhouse gas impacts are discussed in Section 3.3 of the Draft EIR 

and in Response to Comment Epperly -15. 

2) Comment noted. Traffic impacts are discussed in Section 3.13 of the Draft EIR and in 

Master Response Local Traffic. 

3) Comment noted. 

ES092008001PHX\BAO\082970001 2-41






Subject: FW: DEIR Fountaingrove Lodge comments 

Attachments: DEIR COMMENTS.PDF 

8/1/2008 


From: Gigi LaFontaine [mailto:gigi.lms@sbcglobal.net] 


To: scott@hallandbartley.com; ncaston@sonic.net; pacisco@aol.com; vicki@15000inc.com; tk@mkgrp.com; 

davidpoulsen816@msn.com; Galbraith, Joel; Morris, Erin; Meredith, Marie 

Cc: Skip Epperly; kyraj@aol.com; 'Susan Nowacki'; 'Ed and Carol Margason'; ulrikegf@yahoo.com; phoeben@pacbell.net; 

'lynn and william rood'; 'Dewey Nelson'; 'Jim MacMillan'; judithg@sonic.net; chezmac@earthlink.net; 

alcognata@yahoo.com; walkerkelly@comcast.net; jim@jimjohnsonassociates.com; teperry@juno.com; 

lc543orps@earthlink.net 

Subject: DEIR Fountaingrove Lodge comments 

On behalf of Skip Epperly (scnr19@sbcglobal.net) the Supplemental comments to the DEIR Fountaingrove Lodge 

is attached. 

Skip Epperly


EPPERLY– 1 

EPPERLY– 2


EPPERLY– 2 

EPPERLY– 3 

EPPERLY– 4 

EPPERLY– 5


EPPERLY– 6 

EPPERLY– 7 

EPPERLY– 8 

EPPERLY– 9 

EPPERLY– 10


EPPERLY– 10 

EPPERLY– 11 

EPPERLY– 12 

EPPERLY– 13


EPPERLY– 13 

EPPERLY– 14 

EPPERLY– 15


EPPERLY– 15


EPPERLY– 15 

EPPERLY– 16 

EPPERLY– 17 

EPPERLY– 18 

EPPERLY– 19 

EPPERLY– 20 

EPPERLY– 21 

EPPERLY– 22 

EPPERLY– 23


EPPERLY– 23 

EPPERLY– 24


EPPERLY– 24


Response to Comment Letter from Skip Epperly (Advocates for Responsible 

Development) 


letter. 

1) Comment noted. The City disagrees and believes that the Draft EIR has adequately 

analyzed the Project’s impacts to air quality, aesthetics, biology, greenhouse gases, 

seismicity, traffic, land use compatibility, and that the mitigation measures provided 

mitigate potentially significant levels to less than significant. See specific responses 

to these issues as follows: aesthetics (Response to Comment Epperly-2 and 

Epperly-3), biology (Response to Comment Epperly-4 through Epperly-11), 

greenhouse gases (Response to Comment Epperly-15), seismicity (Response to 

Comment Epperly-13), traffic (Response to Comment Epperly-14), and consistency 

with area plans (Response to Comment Epperly-16 through Epperly-22). No 

comments specific to air quality appear to have been made by the commenter. 

2) Aesthetic impacts are evaluated in Section 3.1 of the Draft EIR and are further 

discussed in Master Response Visual Resources. Site drawings do accurately portray 

the Project’s height, mass, and density (see Master Response Visual Resources). 

Visual impacts by the Project were appropriately based on these site drawings; 

therefore, the conclusions derived from the impact analysis, including the 

incorporation of mitigation measures, are accurate. Removal of the oak trees and the 

site topography were incorporated into the visual analysis and visual simulations 

included in the Draft EIR. As a visible design element, retaining walls were analyzed 

in the Draft EIR (p. 3-14, 3-21, 3-22) and incorporated into the simulations (see 

Master Response Visual Resources). 

3) See Master Responses Visual Resources and Oak Trees and Oak Woodland and 

Response to Comment FRMA – 16. 

4) As described in Section 3.4 of the Draft EIR, the only onsite riparian habitat is within 

the 50-foot buffer of Piner Creek. No direct impacts to Piner Creek or its associated 

riparian vegetation will occur; no mitigation is required. 

5) See Master Response Oak Tree and Oak Woodland. 

6) See Master Response Oak Trees and Oak Woodland with mitigation, impacts to 

protected and heritage trees would be less than significant. 

7) See Master Response Oak Trees and Oak Woodland. 

8) See Response to Comment Public Hearing – 58. 

9) See Master Response Oak Trees and Oak Woodland and Response to Comment 

Public Hearing – 58. 

10) See Response to Comment Epperly – 4. The Study Area described in the Biological 

Resources Assessment Report in Appendix I extended beyond the boundaries of the 

Project site, and so estimated areas of habitat are slightly larger than what is present 

on the Project site and described in the Draft EIR. 

2-52 ES092008001PHX\BAO\082970001


11) Potential impacts to wetlands are discussed in Impact 3.4-2; no significant impacts 

would occur. Also see Response to Comment NCRWQCB – 4. 

12) Buildout as allowed in the City’s General Plan and the FRPCD Policy Statement are 

used as the basis for projecting water demand in the SCWA Urban Water 

Management Plan. See also Response to Comment Daugaard -1. 

13) See Master Response Soils and Seismic Mitigation. 

14) See Master Response Local Traffic. There is no specific requirement in CEQA for 

determining which intersections (or other facilities) should be analyzed. The traffic 

analysis therefore focused on the main routes that would carry the majority of the 

traffic. Any additional traffic from the Project at other intersections will be low. 

15) See Response to Comment Public Hearing – 58. 

16) See Master Comment Land Use Compatibility. 

17) The Project is consistent with General Plan Policy UD-A-4; the grading contours and 

stepped buildings will blend with the overall hillside nature of the site (see Draft EIR 

Appendix C – General Plan Consistency Table). 

18) The Project is consistent with General Plan Policies UD-H-1 and UD-H-6, and Goal 

UD-H. See Draft EIR Appendix C – General Plan Consistency Table for an 

explanation of how the Project is consistent with these goals and policies. 

As described in Appendix C, the Project is inconsistent with General Plan Policy 

UD-H-3. The City has considered the Applicant’s site plans as drawn since only 

5 percent of the site area contains slopes over 25 percent, and of those only about 

one-third would be altered. In addition, none of the areas with slopes over 

25 percent would be visually prominent or significant. Other design measures to 

reduce the impact include placement of buildings and parking facilities to maximize 

retention of existing tree clusters that best blend with the natural setting; prioritized 

grading; stepped building design; and architectural features. Final design will be 

subject to approval by the Design Review Board. 

19) The Project is consistent with General Plan Policies OSC-D-3 and OSC-E-1, and Goal 

OSC-E, as described in Draft EIR Appendix C – General Plan Consistency Table. For 

example, the Project will preserve the most important existing wildlife corridor, 

which is along Piner Creek. 

20) The Project is consistent with General Plan Goal NS-C, as described in Draft EIR 

Appendix C – General Plan Consistency Table. 

21) The Project is consistent with General Plan Policy LUL-E-3, as described in Draft EIR 

Appendix C – General Plan Consistency Table. Also see Master Response Land Use 

Compatibility. 

22) The Smaller Footprint and State Density Bonus alternatives evaluated in Section 5 of 

the Draft EIR would be consistent with General Plan Goals and Policies and would 

meet most of the Project objectives. As described in Response to Comment FRMA-16, 

an alternative small enough to avoid or substantially lessen potentially significant 

ES092008001PHX\BAO\082970001 2-53


impacts such as impacts to trees and visual resources would be far too small to 

achieve most of the Project objectives. 

23) As discussed in Section 5 of the Draft EIR, section 15126.6 of the California 

Environmental Quality Act (CEQA) Guidelines specify that an environmental 

impact report (EIR) must describe a reasonable range of feasible alternatives to the 

project that could feasibly attain most of the basic project objectives and would avoid or 

substantially lessen any of the significant environmental impacts of the proposed 

project (emphasis added). An alternative to the Project with a moderate reduction in 

size would not avoid or substantially lessen most impacts from the Project, including 

visual, habitat, and traffic impacts. In order to avoid or substantially lessen such 

impacts, a smaller version of the Project, for example, would have to be limited 

primarily to the grassland areas and reduced at least one floor in height. A project of 

this size would be far too small to achieve most of the Project objectives; it would 

accommodate only a fraction of the objective of 135 units and would not have room 

to accommodate the community care facility or the employee housing. Seismicrelated 

impacts would be similar for any project built on the site. 

24) As discussed in Draft EIR Section 5.0, Alternatives, in general all the alternatives, 

including the No Project Alterative, would be expected to have impacts similar to or 

greater than the Project impacts. The Smaller Footprint Alternative and the State 

Density Bonus Alternative meet the Project objectives discussed in Section 2.2, 

Project Objectives, while the No Project Alternative may not, depending on the 

development that occurs. The Smaller Footprint Alternative would reduce the level 

of biological impacts compared to the Project, but would result in greater, potentially 

significant and unavoidable visual impacts. The State Density Bonus Alternative 

meets all the Project objectives, but would have greater environmental impacts than 

the Project. The No Project Alternative could reduce visual impacts, depending on 

the type of development that occurs, but could have increased traffic congestion, 

noise, and air quality impacts as compared to the Project. Among the alternatives to 

the Project, the Smaller Footprint Alternative would be the environmentally superior 

alternative. However, as noted above, the Smaller Footprint Alternative would not 

be environmentally superior to the Project because of greater, potentially significant 

and unavoidable visual impacts. 

2-54 ES092008001PHX\BAO\082970001


FRMA – 1


FRMA – 2 

FRMA – 3 

FRMA – 4 

FRMA – 5 

FRMA – 6 

FRMA – 7 

FRMA – 8 

FRMA – 9 

FRMA – 10 

FRMA – 11 

FRMA – 12 

FRMA – 13 

FRMA – 14 

FRMA – 15


FRMA – 15 

FRMA – 16 

FRMA – 17 

FRMA – 18 

FRMA – 19 

FRMA – 20 

FRMA – 21 

FRMA – 22 

FRMA – 23


FRMA – 23 

FRMA – 24 

FRMA – 25 

FRMA – 26 

FRMA – 27 

FRMA – 28 

FRMA – 29 

FRMA – 30


Response to Comment Letter from Fountaingrove Ranch Master Association 

(FRMA) 


letter, not the commenter’s numbering within the letter. 

1) Scoping comments submitted during the scoping period were considered during 

preparation of the Draft EIR, as described in Section 1.4 of the Draft EIR. Responses to 

the enumerated comments are provided below. 

2) Compatibility of the FRPCD Policy Statement (amended 1992) with the General Plan is 

outside the scope of this EIR. The Project is consistent with both the General Plan and 

the FRPCD Policy Statement, as described in Section 3.9 of the Draft EIR and in Master 

Response Land Use Compatibility. 


4) The Project is consistent with the General Plan, the Design Review Policy, and 

Ordinance 2196, as described in Impact 3.9-1 in the Draft EIR and in Master Response 

Land Use Compatibility. 

5) The Project is consistent with Ordinance 2196 as described in Impact 3.9-1 in the 

Draft EIR and in Master Response Land Use Compatibility. 

6) The Project does not include “phasing” or a “Lodge Two.” The Project is consistent with 

Design Review Board policies and Ordinance 2196 as described in Impact 3.9-1 in the 

Draft EIR and Master Response Land Use Compatibility. 


8) Compatibility of the Project with surrounding land uses and the environment of the 

neighborhood is determined primarily through the evaluation of aesthetic, noise, and 

traffic impacts of the Project. With implementation of mitigation measures, the Project 

will not have significant impacts to views, noise, and traffic; see, respectively, Sections 

3.1, 3.10, and 3.13 in the Draft EIR. Therefore, the Project will not have a significant effect 

on the environment of the neighborhood. In addition, the Project is consistent with 

applicable land use plans and policies for the site, as described in Impact 3.9-1 in the 

Draft EIR and in Master Response Land Use Compatibility. 

9) The Project does not include an “Emerald Isles” or a “Lodge II.” Cumulative effects and 

the cumulative scenario analyzed are described in Section 4.1 of the Draft EIR; as 

described there, only cumulative traffic impacts to U.S. 101 ramps would be significant; 

all other cumulative impacts would be less than significant. 

10) See Section 3.1 of the Draft EIR and Master Response Visual Resources. Four computergenerated 

simulations of the Project were created to support the visual impacts analysis. 

11) The analysis of cumulative impacts is included in Section 4.1 of the Draft EIR; as 

described there, only cumulative traffic impacts to U.S. 101 ramps would be significant; 

all other cumulative impacts would be less than significant. 

12) See response to Comment FRMA-8. 

ES092008001PHX\BAO\082970001 2-59


13) The analysis of the Project’s effects on visual resources was based on the view areas that 

would be the most sensitive to the visual changes likely to be brought about by the 

Project (see Draft EIR p. 3-9 and Master Response Visual Resources). 



16) See Response to Comment Epperly-23. 


18) The Project is compatible with the FRPCD Policy Statement, as described in Draft EIR 

Impact 3.9-1 and Master Responses Land Use Compatibility and Visual Resources. 

19) Potential impacts to aesthetics, including building massing and plantings, were 

evaluated in Section 3.1 of the Draft EIR and are further discussed in Master Response 

Visual Resources; with mitigation, no significant aesthetic impacts would occur. 

Information on the size of individual buildings is provided in the Draft EIR in 

Section 2.4. The Project would not physically impede use of the Oaks Homeowners’ 

Association pool facility; “privacy” is not a resource area evaluated under CEQA. 


21) A “will serve” letter from SCWA is not necessary. The City Department of Utilities has 

determined that there is sufficient water to serve the site. As described in Section 3.14 of 

the Draft EIR, SCWA provides the City with its potable water supply. The City’s 

entitlement to SCWA water is 29,100 acre-feet per year (afy). Because current water 

demands are 23,000 afy, and only a portion of the development anticipated in the City’s 

General Plan has occurred, the City’s current entitlement is sufficient to meet the present 

and future demand associated with this Project. 

22) Project impacts to traffic, including operational traffic generation, were evaluated in 

Section 3.13 of the Draft EIR; no significant traffic impacts from operation of the Project 

were identified. Cumulative traffic impacts were evaluated in Section 4.1.13 of the 

Draft EIR; cumulative traffic impacts to U.S. 101 ramps were identified as significant. See 

also Master Response Local Traffic. 


24) As described in Section 2.4.3 of the Draft EIR, construction staging areas will be located 

within the Project boundary on the proposed surface parking areas. Following 

construction, the City will review the streets for any damage and repair accordingly. 


26) The Project will not block emergency evacuation routes. As noted in Impact 3.13-4 of the 

Draft EIR, the installation of a signal at the intersection of Thomas Lake Harris and 

Fountaingrove Parkway will improve emergency access to and from the site. The 

Project’s increased demand on emergency services is evaluated in Impact 3.11-2 of the 

Draft EIR; with mitigation, impacts will be less than significant. 

27) See response to FRMA – 26. 

2-60 ES092008001PHX\BAO\082970001



29) See Mitigation Measure 3.13-1 (Add a traffic signal on Thomas Lake Harris Drive) in the 

Draft EIR, which notes that installation of a new signal alleviates the need for a 

westbound right-turn deceleration lane from Fountaingrove Parkway onto Thomas Lake 

Harris Drive. 

30) See Master Response Soils and Seismic Mitigation for explanation of how Mitigation 

Measures 3.6-2 through 3.6-5 in the Draft EIR comply with CEQA requirements. 

ES092008001PHX\BAO\082970001 2-61


GLENN – 1 

GLENN – 5 


Sent: Wednesday, July 23, 2008 7:31 AM 


Subject: FW: Planning Commission Hearing FountainGrove Lodge 7/24/08 

From: Judith Glenn [mailto:judithg@sonic.net] 

Sent: Thursday, July 17, 2008 10:11 AM 

To: scott@hallandbartley.com 

Cc: Galbraith, Joel 

Subject: Planning Commission Hearing FountainGrove Lodge 7/24/08 

I have lived at 3591 Blackhawk Circle in Santa Rosa for over five years. I am concerned that the proposed Fountaingrove 

Lodge project is out of character with the residential community setting that it will be residing in. Aegis Corporation has 

proposed that this 10 acre site be a Residental Care Facility for the Elderly and has proposed 242 parking spots and living 

units for over 135 residents. This will in my opinion cause problems degrading the existing visual characteristics (section 

3.1-2 of Draft EIR) of the site and its surrounding due to its large size, scale (up to three story building) and virtual use of 

the entire ten acre spot with buildings and parking spots. Secondarily I am concerned about the loss of protected heritage 

Valley Oaks and other native trees (Section 3.4.-1 of the EIR). It is my understanding that Heritage Valley Oaks are 

diffiicult to replace and that removing the majority of these trees (over 80 heritage Valley Oaks) is inconsistent with 

prohibitions previously applied to Fountaingrove Ranch Homeowners. Thirdly, I am concerned about the massive grading 

(section 3.6-3) and use of large retaining walls that this project will require. If Vareena is an example this project will be 

massive and out of synch with the neighborhood. Lastly, I am concerned about the increased traffic on Thomas Lake 

Harris and Fountaingrove Parkway (section 3.13-1 of the EIR) due to estimated 400 plus trips per day as indicated in the 

EIR Volume II Appendix P. After over two years of development at Vareena lanes are still closed the majority of the time 

and traffic is slowed down and backed up 

frequently. 

I feel that this project could be mitigated by downscaling it considerable or by Aegis buying more adjacent land and putting 

in an underground garage. 

Thank you for your time and consideration, we remain, 

Sincerely, 

Thomas & Judith Glenn 

3591 Blackhawk Circle 

Santa Rosa, CA 95403 

file://C:\Documents and Settings\mgerut\My Documents\Fountain Grove\Comment_Letters\Glenn.... 


8/1/2008 

GLENN – 2 

GLENN – 3 

GLENN – 4

Response to Comment Letter from Thomas and Judith Glenn 



letter. 

1) Impacts to visual resources are evaluated in Section 3.1 of the Draft EIR and further 

detailed in Master Response Visual Resources. With implementation of mitigation to 

provide a natural-appearing landscape composition along the periphery of the site, 

as described in the Draft EIR, impacts to visual resources will be less than significant. 

2) See Section 3.4 of the Draft EIR and Master Response Oak Trees and Oak Woodland 

for discussion of impacts to heritage valley oaks and other native trees. The City 

does not prohibit the removal of heritage trees. A Tree Removal Permit is required 

and trees can be approved for removal if certain findings can be made. The baseline 

oak mitigation requirements for all projects within the City limits are established by 

the City’s tree ordinance. With implementation of mitigation, impacts to oak trees 


3) Draft EIR Section 2.4.2, Project Design Features, discusses how the Project design 

includes limited contour grading of portions of the site so that buildings will blend 

in with the overall hillside nature of the surrounding area (p. 2-11). See Master 

Response Visual Resources for more detailed discussion of retaining walls and their 

appearance. 

4) Traffic impacts from the Project were evaluated in Section 3.13 of the Draft EIR and 

are described in further detail in Master Response Local Traffic. See also Response to 

Comment Barr – 4. 

5) See Response to Comment McGuckin 7/18-2. 

ES092008001PHX\BAO\082970001 2-63






Subject: FW: Fountaingrove Lodge DEIR, 7.24 Public Hearing 

Attachments: EIR response to Joel G and cc's to Commissioners (July 17).doc 

EIR response to 

Joel G and cc... 


From: kyraj@aol.com [mailto:kyraj@aol.com] 



Cc: scott@ballandbartley.com; ncaston@sonic.net; pacisco@aol.com; Vicki@15000inc.com; 

tk@mkgrp.com; davidpoulsen816@msn.com 

Subject: Fountaingrove Lodge DEIR, 7.24 Public Hearing 

Joel Galbraith, 

I am sending this e-mail to you in hopes that the attachment will be included in the 

Public File to be forwarded to the Planning Commissioners tomorrow, in preparation for the 

Public Hearing at the PC meeting next Thursday. 

Thanks, 

Kyra Janssen 

546 1233 

1


JANSSEN – 1 

JANSSEN – 2 

July 17, 2008 

To: Joel Galbraith, Supervising Planner 

Department of Community Development 

City of Santa Rosa, California 

From: Kyra Janssen, homeowner 

4406 Ballybunion Lane 

Santa Rosa, CA, 95403 

RE: Draft EIR for Fountaingrove Lodge (Aegis Senior Living 

Continuing Care Retirement Community 

I am writing this letter in anticipation of the Public Hearing before the Planning Commission on July 24 

regarding the Draft EIR for the Fountaingrove Lodge project. This proposed project is slated to be built across 

the street from my residence, with views of its massive 3-story Main Building, as well as of the 36-bed Assisted 

Living/Alzheimer’s Care Unit and of the main entry driveway to the Project visible from several perspectives in 

and around my home. 

In 2006 I was an active member of the group that participated in the Scoping Meeting with CH2MHill to put 

forth issues to be analyzed in the Environmental Impact Report, and contributed to the follow-up document sent 

under the auspices of the Fountaingrove Ranch Master Association (dated 12/27/06, final version). 

Now, since June 13 it was published, I have been studying the two Volumes of the Draft EIR (a formidable 

document!) in search of substantive responses to our concerns. I have found it to be adequate and responsive to 

our issues in certain respects, but not in others. It is a given that there are limitations inherent in any EIR 

because they are bound by legalistic requirements expressed in bureaucratic language, e.g., 14 CEQA-mandated 

areas with specifications as to what must be (or cannot be) looked at, rigid criteria for rating the “Significance” 

of an identified Impact, and the use of generalized, “pre-packaged” proposed Mitigation Measures). These 

attributes are useful to assure objectivity and consistency among EIRs. However, the unique characteristics and 

conditions under which a specific Project is being proposed, become obscured. But, even within the limitations 

of a generic EIR, there are certain areas of this Fountaingrove Lodge DEIR that have been inadequately 

addressed in my opinion. 

At the Public Hearing on July 24 th I intend to present some of my specific ideas concerning those aspects of 

this EIR that I feel have not been adequately addressed. I will be speaking not only as a homeowner who will 

be directly affected by whatever happens on this piece of property, but also as a citizen who feels that adherence 

to a planning process that assures transparency and accountability is vital to good governance in our city. 

cc: Scott Bartley, Chair, Planning Commission 

Nick Caston 

Patti Cisco, Vice Chair 

Vicki Duggan 

Tom Karsten 

David Poulsen 

John Walsh


Response to Comment Letter from Kyra Janssen 


letter. 

1) Comment noted. Areas that the commenter believes were inadequately addressed in 

the EIR were not identified in the comment letter. 


2-66 ES092008001PHX\BAO\082970001


JOHNSON – 1 





From: Niewald, Anette 




Anette Niewald 

Community Development/Planning Division 

City of Santa Rosa 

(707) 543-3226 

aniewald@srcity.org 

From: Tom Karsten [mailto:tk@mkgrp.com] 


To: Niewald, Anette 


From: Jim Johnson [mailto:jim@jimjohnsonassociates.com] 


To: scott@hallandbartley.com; ncaston@sonic.net; pacisco@aol.com; Vicki@15000inc.com; Tom Karsten; 

davidpoulsen816@msn.com 

Subject: Fountaingrove Lodge EIR 

To the Santa Rosa Planning Commission: 


This letter is to call your attention to the oldest, most historical part of Santa Rosa that will be destroyed by the 

proposed development called the Lodge and point out the inappropriate size, style, and mass of this huge 

complex. We have lived in Santa Rosa for almost 30 years. In 1996 we moved into Stonefield, a small compact 

neighborhood of modest homes near the bustling Fountaingrove Parkway. My wife and I decided to spend the 

rest of our life in Stonefield for two reasons—the panorama of the Santa Rosa plain we see from our balcony; 

and the historic piece of Santa Rosa on which we live. 

Unfortunately a gigantic commercial complex of densely-packed rooms and apartments, dining and food 

preparation facilities, noisy loading docks, and hundreds of outdoor parking lots—a overwhelming footprint on 

the land that would be several thousand feet long and as much as 100 feet high—may bury much of these 

historic acres and destroy hundreds of beautiful old trees, including irreplaceable native oaks. This proposed 

commercial facility would be so huge, with so much concrete, bricks, lumber, driveways, and parking lots that 

it will completely overwhelm this historical part of old Santa Rosa, bringing more traffic, noise pollution, air 

pollution and, at night, light pollution. 

This is the land where one hundred fifty years ago stood the Victorian mansions, the unique Round Barn, 

thousands of acres of lush vineyards, and the original winery of Thomas Lake Harris and Kenaye Nagasawa. 

While city planners and developers have already destroyed much evidence of the buildings and vineyards of the 

remarkable historical settlement and habitations that stretch back to the earliest human settlements at Fountain 

Grove, these woods that The Lodge will replace are still what Fountain Grove must have looked like back in the 

seventeenth century when native Indians occupied the mountain overlooking the flat plain that was to become 

file://C:\Documents and Settings\mgerut\My Documents\Fountain Grove\Comment_Letters\Johnso... 

8/1/2008


JOHNSON – 1 

JOHNSON – 2 

Santa Rosa, California. All of us are fortunate that this calm landscape—studded with ancient and gnarled 

heritage oaks—has been preserved. Those so interested that walk this area can find evidence of the settlements 

of those who lived, died, and were buried here over the years. We can find remnants of stone walls and old 

fences built a century ago as proof of this area’s precious history. 

These ten verdant acres are split by active earthquake faults and evidence of ancient landslides. If built, these 

buildings will block the creeks whose waters are restrained by two 50- year-old earthen dams. These buildings 

are so massive and tall that they would take this scenery away from sightseers, residents, and tourists. Imagine 

shoehorning a facility the size of Kaiser on Mendocino Avenue into a quiet wooded street only a few feet away 

from nearby homes. The Lodge would mean years of pollution from the extensive excavations, grading, and 

filling; hundreds of additional trucks, vans, and cars to the dangerous, overcrowded traffic hazards along the 

only non-residential access to the area; restricted emergency evacuation routes in the most dangerous section of 

Santa Rosa with the greatest danger from wildfires. 

I cannot possible imagine any residential area in Santa Rosa that would be more unsuitable and inappropriate 

for this intrusive commercial development. 

Jim Johnson 

Jim@JimJohnsonAssociates.com 

2107 Stine320 Tenth Street, Suite 303 


t. 707.571.0226 

f. 707-526-7939 

file://C:\Documents and Settings\mgerut\My Documents\Fountain Grove\Comment_Letters\Johnso... 


8/1/2008

Response to Comment Letter from Jim Johnson 



letter. 

1) This comment contains references to multiple resources. Impacts of the Project to oak 

trees were evaluated in Section 3.4 of the Draft EIR; see also Master Response Oak 

Trees and Oak Woodland. Impacts to oak trees will be mitigated to less than 

significant. 

Impacts of the Project to visual resources were evaluated in Section 3.1 of the 

Draft EIR; see also Master Response Visual Resources. The evaluation included the 

size and height of the buildings. For explanation of how Impact 3.13-3 presents an 

accurate impact evaluation of the Project’s outdoor lighting plans, see Response to 

Community Comments – 13. Impacts to visual resources will be mitigated to less 

than significant. 

Impacts to air quality, noise, and traffic were evaluated in, respectively, Section 3.3, 

Section 3.10, and Section 3.13 of the Draft EIR; see also Master Responses Noise and 

Local Traffic. Project impacts to air, noise, and traffic from Project construction and 

operation will be mitigated to less than significant. 

As described in Section 3.5 of the Draft EIR, a cultural resources survey of the Project 

site was completed. Despite the potential for historic occupancy of the site, neither 

archival nor field research found evidence of archaeological, historic, or 

paleontological resources on the Project site. 

2) This comment contains references to multiple resources. Potential impacts associated 

with faulting and landslides are discussed in Section 3.6 of the Draft EIR; see also 

Master Response Soils and Seismic Mitigation. The nearest active fault is 

immediately southwest of the Project site, as shown in Figure 3.6-3 of the Draft EIR. 

As described in Impact 3.6-1 in the Draft EIR, recent fault investigation study found 

no evidence of recent fault activity; potential impacts from surface rupture of a fault 

are less than significant. 

No construction activities or Project facilities will be located within 50 feet of Piner 

Creek and the creek will not be blocked; see Figure 2-3 in the Draft EIR. 

Impacts of the Project to visual resources were evaluated in Section 3.1 of the 

Draft EIR; see also Master Response Visual Resources. Impacts to visual resources 

will be mitigated to less than significant. 

Construction impacts to air quality, as described in Impact 3.3-2 in the Draft EIR, 

would be potentially significant; however, with implementation of mitigation to 

control PM10 emissions, impacts would be less than significant. It should be noted 

that construction is estimated to last 19 months (see Section 2.4.3 in the Draft EIR). 

Potential traffic impacts from the Project were evaluated in Section 3.13 of the Draft 

EIR; see also Master Response Local Traffic. The large majority of Project traffic will 

be automobile traffic from residents and employees; with addition of the traffic light 

at Thomas Lake Harris Drive and Fountaingrove Parkway, no significant impacts 

ES092008001PHX\BAO\082970001 2-69


would occur. As described in Impact 3.13-3, traffic from the Project would not result 

in any significant hazards. 

The Project will not block emergency evacuation routes. As noted in Impact 3.13-4 of 

the Draft EIR, the installation of a signal at the intersection of Thomas Lake Harris 

and Fountaingrove Parkway will improve emergency access to and from the site. 

2-70 ES092008001PHX\BAO\082970001


KISLING – 1 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Kisling.htm 




Subject: FW: Residential Care Facility on Thomas Lake Harris 

From: Kirt Kisling [mailto:kirtk@lifelinepro.com] 


To: scott@hallandbartley.com; Galbraith, Joel 

Subject: Residential Care Facility on Thomas Lake Harris 

Dear Sirs: 

Regarding: the Residential Care Facility on 10 acres off of Thomas Lake Harris Drive. 

I am writing to ask that you deny the building of this commercial facility in this residential area. I am 

currently building a home off of Llyn Glaslyn Place and was disheartened to see that the builders of 

Varenna were not held to the same restrictions required of me regarding limits on the height of the building 

and requirements to maintain the slope and nature of the building site. It seems this double standard is 

what is allowing yet another large group of commercial buildings to be built. Please keep this area 

peaceful, quiet and residential. 

Respectfully, 

Kirt & Brenda Kisling 

1420 Snowy Cloud Way 

SR, 95409 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Kisling.htm8/1/2008 2:10:09 PM


Response to Comment Letter from Kirt and Brenda Kisling 


letter. 

1) There are a variety of acceptable building heights in the nonresidential designated 

areas of the Fountaingrove Ranch area. As described in Section 3.9.1 in the Draft EIR, 

the development plan that accompanies the FRPCD Policy, as adopted per 

Ordinance No. 2196, designates the Project site as a Cluster Residential Land Use 

Area. Maximum building height, lot coverage, and setbacks are not specified for 

Cluster Residential land uses, but are established for each project by its Use Permit. 

As a community care facility, the Project is considered a nonresidential land use, 

which is allowed in any zoning district through the Conditional Use Permit process. 

Residential areas in the vicinity are subject to different zoning requirements and 

different restrictions on land use such as building height. See also Master Response 

Land Use Compatibility. 

2-72 ES092008001PHX\BAO\082970001


MAGAGNA – 1 

MAGAGNA – 2 

MAGAGNA – 3 

MAGAGNA – 4 

MAGAGNA – 5 

MAGAGNA – 6 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Magagna.htm 




Subject: FW: Draft Environmental Impact Report, Fountaingrove Lodge Project, File number MJP06- 

041 

From: Joseph Magagna [mailto:jbmagagna@sbcglobal.net] 



Cc: scott@hallandbartley.com 

Subject: Draft Environmental Impact Report, Fountaingrove Lodge Project, File number MJP06-041 

My name is Joseph Magagna and I live at 4956 Lakepointe Circle, Santa Rosa, CA. Following 

are my concerns regarding the above impact report. 

Assuming the Consultants were retained by the Applicants, it appears to me that the report in 

general is biased in favor of the Applicants. If I am correct about who is paying for the report, 

maybe the City of Santa Rosa should retain a Consultant so there would be an independent report 

for review. The report submitted by the Consultants is very inaccurate. 

I understand that there will be medical services available around the clock. There appears to 

be nothing that prohibits medical services being provided to anyone who is not associated with 

the Lodge. It is my understanding that the services would only be limited to Lodge residents. I 

would like to know if I am correct in my assumption as to who would receive medical care. 

The Consultants seem to think that this would be a low noise project. If you think about all the 

activity which the Applicants say would occur, there is no way that there would be "low noise" 

project. 

The visual impacts shown at the meeting were ridiculous. We know from the Varenna 

experience that the final construction would give the appearance of a five story structure instead 

of a 3 story building. The solution to this issue would be to only allow a two story structure. 

Also, Why didn't the Consultant submit plans for a smaller project which I understand that the 

Law requires them to do so. Also the light from the huge parking lot would substantially alter the 

area and destroy the beauty of the area. 

If the current report is approved, traffic on Thomas Lake Harris Drive and Fountaingrove drive 

would become a nightmare. Between construction vehicles, delivery trucks, construction people, 

the noise and danger will become unbearable. 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Magagna.htm (1 of 2)8/1/2008 2:10:09 PM


MAGAGNA – 7 

MAGAGNA – 8 

MAGAGNA – 9 

MAGAGNA – 10 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Magagna.htm 

Between the proposed removal of 80% of the Heritage Oak Trees and the removal of various 

animals from the area, the entire area would be destroyed. It would be a very sad day to allow this 

to happen. 

In case of emergency...wildfire or earthquake, how can emergency personnel handle everyone 

living in the area. 

I have only lived here one year, but I understand that this would be the fourth residential care 

facility on the West end of Fountaingrove. Do we really need this project??? 

When you do approve this project, could you please limit the use of trucks coming and going via 

the Fountaingrove Parkway to the SOUTHWEST entrance to Thomas Lake Harris drive 

Thank You 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Magagna.htm (2 of 2)8/1/2008 2:10:09 PM

Response to Comment Letter from Joseph Magagna 



letter. 

1) The lead agency (in this case, the City) is responsible for the adequacy and 

objectivity of the Draft EIR (see CEQA Guidelines Section 15084 (e)). If the lead 

agency does not prepare the Draft EIR with its own staff, a number of options are 

provided by the CEQA Guidelines (Section 15084 (d)(1 through 5)). The City 

contracted directly with an outside consultant to prepare the EIR for the proposed 

Project. The consultant is not affiliated with the Applicant. Studies prepared by the 

Applicant were reviewed by the consultant and the City for adequacy. The Draft EIR 

reflects the City’s independent judgment. The Applicant is reimbursing the City for 

the costs of the EIR. 

2) No medical services will be provided as part of the proposed Project (see Draft EIR 

p. 2-1). City Code Chapter 21-05.040 (I)(8) considers community care facilities (such 

as the Project) as a nonresidential land use that provides nonmedical residential care. 

However, to reduce the City Fire Department’s need to respond to nonmedical 

emergency calls in community care facilities, Fountaingrove Lodge will provide an 

Emergency Medical Technician qualified or equivalent personnel 24 hours per day in 

the main “assisted living” building and Care Center (see Draft EIR Mitigation 

Measure 3.11-2b on p. 3-132). 

3) See above response to Magagna – 3. In general, only residents and their guests will 

have access to the services and facilities included with the Project. 

4) Noise impacts were evaluated in Section 3.10 of the Draft EIR; with mitigation, noise 

impacts will be less than significant. Also see Master Response Noise. 

5) See Master Response Visual Resources for additional detail on accuracy of 

simulations portraying building height and visual impacts; with mitigation, impacts 

will be less than significant. For a discussion of a smaller project alternative to the 

Project, see Response to Comment McGuckin July 18 – 2. As described in Impact 3.1- 

3 in the Draft EIR, the Project would add new sources of nighttime security lighting 

along driveways, in outdoor parking lots, and near building entrances. Conformance 

to the City of Santa Rosa’s Lighting Design Guidelines and the Principles of 

Low-impact Lighting Design (see Mitigation Measure 3.1-3), which minimize the 

amount of light that leaves the site, would reduce impacts to less than significant. 

6) As described in Section 3.13.3 of the Draft EIR, the average number of construction 

workers onsite during any weekday is 97, and they would work from 7:00 AM to 

3:30 PM. Truck deliveries supplying materials would occur as often as four times a 

day, between 9:00 AM and 3:00 PM. Equipment and materials would be staged in 

the outside parking areas and the proposed driveways would offer turnaround 

locations for equipment and transport vehicles. Assuming most construction 

workers would drive alone, there could be on average 85 to 90 construction worker 

vehicles entering the site before 7:00 AM and leaving before 4:00 PM. Virtually no 

construction worker or truck traffic should occur during the AM or PM commute 

peak periods (from 7:00 to 9:00 AM and 4:00 to 6:00 PM, respectively). Therefore, the 

ES092008001PHX\BAO\082970001 2-75


Project construction-related traffic would have a less than significant impact on the 

critical commute traffic periods. 

7) As described in Section 3.4 of the Draft EIR, impacts to oaks and wildlife would be 

less than significant with mitigation; see also Master Response Oak Trees and Oak 

Woodland. 

8) The City’s Fire Department reviewed the Draft EIR before its publication and Fire 

Department comments have been incorporated in the impact analysis and mitigation 

measures. The Project’s increased demand on emergency services is evaluated in 

Impact 3.11-2 of the Draft EIR; with mitigation, impacts will be less than significant. 

As noted in Impact 3.13-4 of the Draft EIR, the installation of a signal at the 

intersection of Thomas Lake Harris and Fountaingrove Parkway will improve 

emergency access to and from the site. 

9) The Project is consistent with General Plan Policy LUL-E-3, which addresses 

clustering of continuing care facilities. See Master Response Land Use Compatibility 

and Draft EIR Appendix C – Project Compatibility with General Plan Goals and 

Policies. 

10) Comment noted. The City agrees that Fountaingrove Parkway (West) and Thomas 

Lake Harris Drive intersection is the most direct access to the Project site and is 

assumed by the City as the primary access point for construction traffic. The City’s 

detailed limitations on the Contractor regarding construction traffic will occur in the 

final design plans and specifications. 

2-76 ES092008001PHX\BAO\082970001


MARGASON – 1 



Written Comments on Draft Environmental Impact report for the Lodge Project, 




Subject: FW: Written Comments on Draft Environmental Impact report for the Lodge Project.doc 

From: Ed and Carol Margason [mailto:edmarg@pacbell.net] 


To: scott@hallandbartley.com; ncaston@sonic.net; pascisco@aol.com; vicki@15000inc.com; tk@mkgrp. 

com; davidpoulsen816@msn.com; jgalbraith@srcity.com 

Cc: kyraj@aol.com 

Subject: Written Comments on Draft Environmental Impact report for the Lodge Project.doc 

Written Comments on Draft Environmental Impact report for the Lodge Project,. July 28, 2008 

My name is Edward Margason and I am commenting on Table ES-1 in DEIR volume I, for those 

impacts numbered 3.1 and 3.6 and the related report sections. These comments include points 

made in my 3 minute presentation to the Planning Commission on July 24, 2008 and applicable 

scoping comments given to the City on December 12, 2006 as contained in appendix B of DEIR 

volume II. 

Section 2.0, project description, pages 2-1 thru 2-16, is inadequate for determining the specifics 

of project layout and construction. Only three figures of general information, figures 2-1 thru 2-3, 

exist and they are inadequate. There is no figure showing building details such as elevations or 

setbacks; one must go back into the local geology map, figure 3.6-4 to obtain details and that 

figure is confused and obscure. This is a serious omission in the DEIR. Clear and readable site 

plans and elevations which are readily available from the City already show these details and 

must be included in the EIR. The building sketches in the DEIR are not adequate for this purpose. 

Section 3.0, site setting, gives only general views and photos of the site but does not provide the 

type of detailed visual analysis that is required to understand the overall project impact on the 

site. Items A-9 , A-12 and A-20 in our scoping comments specifically ask that architectural 

models and true scale cross sections be part of the mass and scale analyses of the DEIR report but 

they are absent and this is a serious flaw in the EIR. Actually at least two architectural models are 

needed: one that shows the graded site with retaining walls before building construction and one 

that shows the final buildout. 

On July 24 section “B”,enclosed, as drawn by us, was presented and shows the crowding of 

retaining walls and the main building along Thomas Lake Harris,TLH, and the looming height of 

50 to 80 foot-high structures within 15 feet of. TLH. A photo of the Varenna walls was shown to 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Margason.htm (1 of 4)8/1/2008 2:10:09 PM








demonstrate the harsh visual impact of such structural sitings. This fortress-like appearance has 

many City residents angry and they do not want more of such mass and bulk and this was not 

addressed in the lodge DEIR. 

The DEIR photos in section 3 do not address the views into the site nor do they show any 

structures because trees have inserted digitally in front; this is misleading and inaccurate. Photos 

should show the actual buildout appearance. The crowding of the walls along TLH does not allow 

any room for landscape screening of walls since some are within 3 feet of the street and yet the 

DEIR concludes in mitigation measure 3.1-2, page 3-23, that a landscape plan will provide a 

natural-appearing landscape composition along the periphery of the site thus mitigating the 

“significant” 3.1-2 impact. This is not effective mitigation and will do nothing to reduce this 

serious environmental impact on TLH and the existing Oaks and Stonefield neighborhoods. Such 

landscape mitigation has not worked at Varenna and it will not be effective at the lodge project. 

Page Two 

The DEIR does not address the fundamental assumption that project siting will require major 

regrading of most of the 10-acre site by cutting at least 15 feet deep along the east golf course 

boundary and filling up to 15 feet deep along TLH; this is the only reason why the retaining walls 

are needed and yet the DEIR does not analyze this impact. The impact of such grading is not 

adequately addressed in the draft nor is the assumption that 

the lodge project must have a level cut-and-fill building pad. Such siting is fundamentally flawed 

because it’s typical of a 15-acre flat land site elsewhere but does not apply to the sloping and 

wooded 10-acre hillside site proposed for the lodge. 

In the alternatives discussed on page xi of the executive summary, there is no mention of a 

smaller size development having less living units. This is a major flaw in the DEIR and must be 

addressed according to CEQA law. An alternative without affordable employee housing must 

also be discussed since elimination of these structures would allow the senior living units to be 

spread out on the site thereby reducing the impact of concentrated unit construction . 

The cumulative impacts on page xii of the executive summary do not discuss the Lodge II project 

which will be sited across TLH on the opposite side of the Oaks where the sales office has been 

permitted by the City. This is also a serious flaw in the DEIR since this second phase will double 

the project size and number of living units when the entire lodge project is built out. CEQA 

Guidelines Section 15130(b) requires analysis of such cumulative impacts and this cannot be 

deferred nor ignored in the final EIR. 

Grading for unstable or compressible soil repair is mentioned as a generality in impact 3.6-5 on 








page 3-92 but the extent of such soils is not yet defined hence the impact of such grading has not 

and cannot be addressed in the DEIR. This is unacceptable because the final extent of disturbance 

to the site topography hence environmental impact has not yet been determined. The EIR cannot 

defer the evaluation of such impacts until the design phase; they must be determined now by 

further on-site soils studies before a final EIR is completed. 

Section 3.6, pages 3-67 to 3-93, addresses geology and faulting and this section is one of the 

more extensive and responsive parts of the DEIR. Our 2A-1 thru 17 scoping comments in volume 

II apply as follows. Scope comments 2A1 thru 4 are addressed by the DEIR and according to 

Giblin and Associates no active fault was found by them on the lodge site, the nearest active trace 

of the Rogers Creek fault being across the street of TLH in the visible sag pond about 70 feet to 

the west. Bedrock faults were found on the site but Giblin dated them as pre-holocene hence they 

were rated as inactive. One would hope that no active faults were missed in non-trenched areas 

and Giblin should have to certify as to this in the final EIR.. 

Page Three 

The DEIR does not appear to contain a map showing the locations of the Giblin fault trenches; 

this map is missing from his December 7, 2007 study, appendix K of vol. II, which curiously lists 

two plate 2’s. This seems to be an error and should be corrected in the EIR. 

Scope item 2A-5 was addressed as to very strong shaking from nearby 7+ magnitude 

earthquakes. The DEIR states that such hazards are significant and require mitigation. Mitigation 

impact 3.6-2 includes site-specific seismic analyses during design but does not specify if such 

analyses will include such details as response spectra, computer simulations and finite-element 

modeling all of which are needed in this near-fault setting. The EIR is not clear that its 

recommended mitigation of “site-specific seismic analyses in project design” goes well beyond 

normal building code seismic design. The EIR must indicate that code design alone is not 

sufficient for public safety at this site which is in the State of California’s designated Alquist- 

Priolo active fault zone. CEQA law does not allow this consideration to be deferred but must be 

included in the EIR. 

Site and soil stability during earthquakes has not been evaluated in the DEIR but instead is 

deferred to the design phase; also the seismic stability of the City-owned earth dams impounding 

Fountaingrove Lake has not been evaluated. Scoping items 2A6 thru 11 asked that these items be 

addressed in the DEIR but they are not. It is not clear that scoping items 2A14 and 15 were 





covered in the DEIR. Item 2A16 was not even mentioned in the DEIR and field fault trench 

inspections were prohibited to outside consultants; no trespassing signs were posted on the site. 


Response to Comment Letter from Edward Margason 



letter. 

1. Several figures and text in the Draft EIR provide information on Project layout and 

construction. Figure 2-3 shows the location and footprint of all buildings included in the 

Project; a detailed description of each building, including dimensions and design 

features, is included in Section 2.4.1. Profiles and elevations of the Project buildings are 

shown in Figure 2-4. Visual simulations of the Project are shown in Figures 3.1-4 

through 3.1-7. CEQA does not specifically require provision of detailed site plans. 

2. See Master Response Visual Resources. 

3. See Master Response Visual Resources. The height of the main building closest to 

Thomas Lake Harris Drive would be approximately 29 feet above grade as shown in 

Figure 2-4 of the Draft EIR. There would not be “50 to 80 foot-high structures within 15 

feet” of Thomas Lake Harris Drive. 

4. The proposed grading for the site, as well as plans for retaining wall construction, was 

taken into account during the analysis of the Project’s environmental impacts. See 

Sections 3.1 Aesthetics and Visual Resources and 3.6 Geology, Soils and Seismicity in the 

Draft EIR, as well as Master Responses Soils and Seismic Mitigation and Visual 

Resources. As shown in Figure 2-4 and described in Section 2.4.2 of the Draft EIR, the 

design includes limited contour grading of portions of the site so that buildings will 

blend in with the overall hillside nature of the area. 

5. See Response to Comment Epperly – 23; a Project alternative that would avoid or 

substantially lessen most impacts from the Project would not meet most of the Project 

objectives. The affordable employee housing only occupies a footprint of 4,500 square 

feet, approximately 2 percent of the proposed lot coverage (buildings, parking lots, 

circulation ways, paved walkways, and patios). Eliminating the employee housing 

would make very little difference in the level of Project impacts, would not leave enough 

room to allow the remaining structures to be “spread out,” and would not meet one of 

the Project objectives. It would also result in an increase in traffic impacts (with 

additional workers driving to the site) and a corresponding increase in greenhouse gas 

emissions compared to the Project as described in the Draft EIR. 

6. The Project does not include a “Lodge II.” Cumulative effects and the cumulative 

scenario analyzed are described in Section 4.1 of the Draft EIR; as allowed under CEQA, 

the cumulative scenario is the build-out of the General Plan Area within the Urban 

Growth Boundary and build-out of the FRPCD Policy Statement’s Land Use and 

Circulation Plan, not a list of projects. As described in Section 4.1, only cumulative traffic 

impacts to U.S. 101 ramps would be significant; all other cumulative impacts would be 

less than significant. 

7. See Master Response Soils and Seismic Mitigation. 

8. Comment noted. The City agreed with scoping comments and similarly determined that 

additional seismic analysis was required to determine the location of potential faults. 

ES092008001PHX\BAO\082970001 2-81


For this reason, further studies by Giblin were performed, including additional 

trenching excavation and logging to resolve discrepancy regarding a possible faulting 

through the northeast portion of the Project site. The report was reviewed for technical 

accuracy by a third party and the results were determined sufficient for completing the 

Draft EIR analysis. 

9. Draft EIR Appendix K, Geologic Studies, has been amended to include Plate 3. Also see 

Response to Comment Aegis – 12. 

10. See Master Response Soils and Seismic Mitigation. Questions regarding the seismic 

stability of Fountaingrove Dam are outside of the scope of this EIR because the Project 

will not change or otherwise affect Fountaingrove Dam. Potential impacts from a dam 

failure event are addressed in Impact 3.8-4 of the Draft EIR. Because no buildings or 

facilities are proposed for the southern end of the site, no significant impacts would 

occur. 

2-82 ES092008001PHX\BAO\082970001


MCGUCKIN 

JULY 18 – 1 

MCGUCKIN 

JULY 18 – 2 

MCGUCKIN 

JULY 18 – 3 

Adequacy of Fountaingrove Lodge DEIR 




Subject: FW: Adequacy of Fountaingrove Lodge DEIR 

From: Hank McGuckin [mailto:chezmac@earthlink.net] 



Subject: Adequacy of Fountaingrove Lodge DEIR 

July, 18, 2008 

Subject: Adequacy of Fountaingrove Lodge DEIR 

To the Planning Commission: 

The EIR at issue is cavalier at best regarding the significance of environmental impacts.The 

sheer size of the proposed retirement facility will result in an ecological disaster for a prime six 

acre strip of wild woods, including a stream, some wetlands, hundreds of oaks and heritage 

classified trees and a myriad of special status plants and animals. The extent of the proposed 

parking areas alone, will require extensive bulldozing and earth movement not at all compatible 

with successfully saving trees and habitat nor is ecological "sensitivity training" of construction 

workers likely to mitigate the impending destruction of flora and fauna. 

Even a downsized version of the proposal would be ecologically harmful, but at least the extent 

of the damage would be mitigated. As it stands, the proposal is grossly oversized for the site and 

will effectively destroy it. 

In an era when environmental issues must be weighed along with commercial interests, it would 

be short sighted indeed to ignore the heavy, crushing footprint being proposed for the purely 

commercial interests of a few. A few large cities such as Portland, Oregon, have been able to find 

a equitable balance between growth and ecological costs which has resulted in both responsible 

development and preservation of the irreplaceable. Surely a smaller community such as Santa 

Rosa can do as well. 

Sincerely, 

Dr. Henry E. McGuckin 

4450 Lahinch Lane 


file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/McGuckin.htm (1 of 2)8/1/2008 2:10:09 PM


Adequacy of Fountaingrove Lodge DEIR 

7-7=578=6050 

chezmac@earthlink.net 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/McGuckin.htm (2 of 2)8/1/2008 2:10:09


Response to Comment Letter from Henry McGuckin (letter dated July 18, 2008) 


letter. 

1) Project impacts on biological resources are discussed in Section 3.4 of the Draft EIR; 

impacts to oak trees and oak woodland are further detailed in Master Response Oak 

Trees and Oak Woodland. No significant impacts to biological resources would 

occur as a result of Project implementation. Impacts to oak and heritage trees would 

be less than significant with implementation of mitigation, including replanting of 

native trees onsite. Implementation of Best Management Practices (BMP), described 

in Mitigation Measure 3.4-1c, would protect trees and habitat to be preserved during 

construction. As noted in Section 3.4, no direct impacts to Piner Creek would occur 

as a result of the Project. No wetlands or waters under the jurisdiction of the U.S. 

Army Corps of Engineers (USACE) would be impacted by the Project (USACE, 2008. 

February 20 letter to Amy Paravano at WRA on USACE jurisdictional 

determination). Potential impacts from construction of the Project to nesting birds, 

roosting bats, and northwestern pond turtle will be mitigated to a less than 

significant level through preconstruction surveys, avoidance, monitoring during 

construction, and/or other measures. 

2) See response to Comment Epperly-23. 

3) Comment noted. As described in Section 2 of the Draft EIR, the purpose of the 

Project is help to meet housing and service needs of the City’s senior community, 

consistent with the policies and goals in the General Plan that call for projects and 

services to support the needs of seniors in the City. Specific Project objectives are to 

create approximately 135 community care facility units; provide progressive care 

and a range of services to allow seniors to remain within the community; provide 

quality senior care licensed by the state of California; provide employee housing that 

is affordable to the full-time employees needed to operate the facility; and provide 

housing for seniors with convenient access to medical care facilities, highways, 

transportation, retail, and recreation amenities. As discussed in Section 3.9 Land Use 

of the Draft EIR and in Master Response Land Use Compatibility, the development 

of the site is consistent with the land uses designated in the City’s General Plan and 

the FRPCD Policy Statement, which was originally adopted in 1972 and amended in 

1981 and 1992. Development has been planned for the Project site for several 

decades. 

ES092008001PHX\BAO\082970001 2-85






Subject: FW: Statement To Planning commission Regarding Fountaingrove Lodge EIR 

Attachments: STATEMENT TO THE PLA#137846.doc 

STATEMENT TO 

HE PLA#137846.do. 


From: Hank McGuckin [mailto:chezmac@earthlink.net] 



Subject: Statement To Planning commission Regarding Fountaingrove Lodge EIR 

Dear Mr. Galbraith, 

Please forward the attached statement to the planning commission. 

Thank you, 

Dr. Henry E. McGuckin 

4450 Lahinch Lane 


707-578-6050 

1


MCGUCKIN 

JULY 25 – 1 

MCGUCKIN 

JULY 25 – 2


MCGUCKIN 

JULY 25 – 3 

MCGUCKIN 

JULY 25 – 4


MCGUCKIN 

JULY 25 – 4 

MCGUCKIN 

JULY 25 – 5 

MCGUCKIN 

JULY 25 – 6


Response to Comment Letter from Henry McGuckin (letter dated July 25, 2008) 


letter. 

1) See Response to Comment McGuckin July 18-1. 

2) See Responses to Comments McGuckin July 18-1 and McGuckin July 18-2 and 

Master Response Oak Trees and Oak Woodland. 

3) See Response to Comment McGuckin July 18-1 and Master Response Oak Trees and 

Oak Woodland. Mitigation Measure 3.4-3 in the Draft EIR includes pre-construction 

surveys, avoidance as feasible during breeding season, and buffer zones to minimize 

impacts to raptors and nesting birds. Mitigation Measure 3.4-3 and Mitigation 

Measure 3.4-4, provide protection for roosting and maternity colonies for 

special-status bat species, both require tree removal outside of breeding seasons to 

avoid impacts to nesting birds and roosting bats. Trees to be removed are those 

required for removal to construct the Project. 

4) As shown in Figure 2-3 in the Draft EIR, a 50-foot buffer will be established on both 

sides of Piner Creek. This buffer will be maintained during Project construction, and 

no construction activity would take place in the buffer area. Riparian vegetation, 

which extends less than 50 feet from Piner Creek (see Figure 3.4-1 of the Draft EIR), 

would not be removed. 

As discussed in Impact 3.8-2 of the Draft EIR, construction and operation of the 

Project could increase pollutants in stormwater runoff, including in Piner Creek. 

These potential impacts will be mitigated to a less than significant level through 

implementation of Mitigation Measure 3.8-2, Comply with all applicable state and 

local regulations for stormwater management. These regulations require the 

preparation of a Stormwater Pollution Prevention Plan (SWPPP) that outlines BMPs 

to be used during construction, including BMPs for erosion control, sediment 

control, tracking control, wind erosion, and non-stormwater discharges. Regulations 

also require preparation of a Storm Water Mitigation Plan to address 

post-construction water quality impacts per Santa Rosa Area Standard Urban 

Stormwater Mitigation Plan (SUSMP). Also see the Responses to Comments 

NCRWQCB-1, 2, and 3. 

5) As discussed in Section 3.4 of the Draft EIR, special-status plants species are defined 

as species that are: federal- or-state listed or are proposed for listing as rare, 

threatened, or endangered; included in the California Native Plant Society (CNPS) 

Inventory (CNPS List 1 through 3 Plants); or qualifying under the definition of 

“rare” in the CEQA, Section 15380. As discussed in Section 3.4.1 of the Draft EIR, no 

special-status plants were found on the Project site during the rare plant surveys 

performed. As evaluated in Impact 3.4-6, potential impacts to special-status plant 

species will be less than significant. 

As discussed in Appendix I to the Draft EIR, Biological Resources Assessment Report, 

special-status wildlife species are defined as: species that have been listed as 

endangered or threatened, are proposed for listing, or are candidates for such 

2-90 ES092008001PHX\BAO\082970001


listings at the federal or state level. In addition, special status species evaluated 

included species tracked by CDFG in the California Natural Diversity Database as 

Species of Special Concern, Threatened or Endangered Species, Fully Protected 

Species, or USFWS Birds of Conservation Concern; or species protected by the 

Migratory Bird Treaty Act. As evaluated in Section 3.4.3, impacts to these species 

will be less than significant with mitigation. 

6) See Responses to Comments McGuckin July 18-1, McGuckin July 18-2, McGuckin 

July 25-3, and McGuckin July 25-5. 

ES092008001PHX\BAO\082970001 2-91

ES082008001BAO_Fountaingrove_publicComments_v3.indd_090408_lho MCREYNOLDS – 1

Response to Comment Letter from Carmen McReynolds, M.D. 



letter. 

1) See Response to Comment Magagna–8. 

ES092008001PHX\BAO\082970001 2-93


NAHC – 1


Response to Comment Letter from Native American Heritage Commission (NAHC) 


letter. 

1) As discussed in Section 3.5 of the Draft EIR, a surface survey of the Project site was 

completed and archival research was conducted at the Northwest Information 

Center at Sonoma State University to evaluate cultural resources that might be 

present on the Project site. Detailed results of the study are described in the cultural 

resources study in Appendix J to the Draft EIR. Despite the potential for historic 

occupancy of the site, neither archival nor field research found evidence of 

archaeological, historic, or paleontological resources onsite. Mitigation Measures 

3.5-1a and 3.5-1b include provisions to address archaeological resources or human 

remains accidentally discovered during construction. 

ES092008001PHX\BAO\082970001 2-95






Subject: FW: The Lodge at Fountaingrove EIR 

Attachments: EIR Report-Traffic Comments.doc 

EIR Report-Traffic 

Comments.do... 


From: Dewey Nelson [mailto:deweynelson@juno.com] 



Subject: The Lodge at Fountaingrove EIR 

Dear Joel, 

Attached are my comments and recommedations aimed at Appendix P of the EIR for The Lodge 

at Fountaingrove. 

Sincerely, 

Dewey Nelson 

2003 Stonefield Lane 

Santa Rosa, CA 95403-0952 

707-544-6327 

____________________________________________________________ 

Great pay, great benefits, rewarding. Click for information on a healthcare career. 

http://thirdpartyoffers.juno.com/TGL2141/fc/Ioyw6i3oH0aJVCMmHA6OuURfAIBT 

sUrQn0aglyNwD1yGONxqa4sfyV/ 

1


NELSON 

JULY 17 – 1 

NELSON 

JULY 17 – 2 

NELSON 

JULY 17 – 3 

NELSON 

JULY 17 – 4 

Dated October 18, 2007 

Prepared by Dewey Nelson 

DeweyNelson@Juno.Com 

Observations on EIR content: 

Fountaingrove Lodge Draft EIR 

Appendix P Traffic Impact Report 

1) The EIR failed to consider the increased traffic (422 trips per day as indicated in EIR Volume II, 

Appendix P, Traffic Impact Report, Table 8) and to assess the impact on the intersections with 

Thomas Lake Harris Drive (TLH) and its numerous intersections with cross streets and side streets. 

The analysis needs to consider crosswalks, stop signs, speed bumps, etc. as opposed to just traffic 

signals. And decide if the 494 trips per day in EIR Volume II, Appendix D, Table D-1 is accurate. 

2) In EIR Volume II, Appendix P Traffic Impact Report, VII Recommended Improvements A.2. States: 

“TLH Drive (East)/Fountaingrove Parkway – Unacceptable Level of Service & Signal Warrant: 

Drivers using the unsignalized TLH Drive (East)/Fountaingrove Parkway intersection have the option 

of using Fir Ridge Drive to access a signalized intersection with Fountaingrove Parkway. Based upon 

input from City traffic engineering staff, it is not the City’s desire that the TLH Drive 

(East)/Fountaingrove Parkway intersection be considered for signalization due to the ease of access to 

the Fir Ridge Drive intersection with Fountaingrove Parkway.” 

Resolving an Unacceptable Signal Warrant by stating drivers have the option to drive through a 

long out-of-the-way loop in a residential area is ludicrous and totally unacceptable. We are, 

after all, concerned about the safety of our citizens. In addition, Volume I Executive Summary 

Table ES-1 3.13-1 states a traffic signal would change the impact from “Significant” to Less 

than Significant”. 

3) In EIR Volume II, Appendix P Traffic Impact Report, VII Recommended Improvements A.2. States: 

“TLH Drive (West)/Fountaingrove Parkway – Unacceptable Level of Service & Signal Warrant: 

Although AM peak hour volumes at the TLH Drive (West)/Fountaingrove Parkway would be 

approaching signal warrant criteria, the number of vehicles experiencing LOS F delay for left 

turns from TLH Drive (West) will be small. In addition, the intersections along Fountaingrove 

Parkway immediately east and west of TLH Drive (West), at Altruria Drive and Round Barn 

Boulevard, are now both signalized and provide some gaps in traffic flow along Fountaingrove 

Parkway. For this reason, City traffic engineering staff have indicated their desire not to signalize this 

intersection. Should the City wish to provide an improvement measure, consideration could be given 

to providing a median refuge area along Fountaingrove Parkway just east of the intersection to 

facilitate left turns from TLH Drive (West). Resultant operation of left turn movements from TLH 

Drive (West) to Fountaingrove Parkway would be an acceptable LOS D during both the AM and PM 

peak hours.” 

Resolving an Unacceptable Signal Warrant because there are nearby traffic lights makes little 

sense and is totally unacceptable. Again, we are concerned about the safety of our citizens. In 

addition, Volume I Executive Summary Table ES-1 3.13-1 states a traffic signal would change 

the impact from “Significant” to Less than Significant”. 

4) The EIR traffic engineer needs to make his own conclusions rather than rely on the city traffic 

engineer’s “opinions” while ignoring his own data. See EIR Volume II, Appendix P Traffic Impact 

Report, VII Recommended Improvements A.2. and A.3


NELSON 

JULY 17 – 5 

NELSON 

JULY 17 – 6 

NELSON 

JULY 17 – 7 

NELSON 

JULY 17 – 8 

NELSON 

JULY 17 – 9 



Appendix P Traffic Impact Report Continued 

The Planning Commission needs to have the Crane Transportation Group 

revise their EIR to include: 

FRMA Positions 

1) EIR Volume I, Executive Summary, Potential Impacts and Mitigations, Table ES-1, 

3.13 Transportation and Traffic resolves Impact 3.13-1 with traffic signals for the 

intersections of east and west Thomas Lake Harris Drive (TLH) with Fountaingrove 

Parkway and needs to be adopted. However, there is no time frame for installation 

and the project needs to install those traffic signals as a first step in the 

construction process. In my view the increased traffic from construction trucks and 

construction workers will increase traffic to the levels projected when the development 

is complete. 

2) The project needs to install stop signs on TLH at the intersection with Stonefield 

Lane. The EIR failed to consider the increased traffic (422 trips per day as shown in 

Volume II, Appendix P Traffic Impact Report, Table 8) and assess the impact on the 

intersection of TLH with Stonefield Lane. There are 122 residents living on Stonefield 

Lane with a greater number of owner vehicles--each home has a two car garage. Those 

residents, along with their guests, service vehicles, etc. create a great deal of traffic, not 

to mention the pedestrian traffic as the spa, tennis court, and pool are on opposite sides 

of TLH Drive. When making left hand turns or crossing TLH Drive, the sight distance 

is limited in both directions. To the north TLH curves downhill while to the south TLH 

is curved and with a steep downhill, both limiting the visibility of oncoming vehicles. 

3) The project needs to install stop signs on TLH at the intersection with Cross Creek 

Road. The EIR failed to consider the increased traffic (422 trips per day as shown in 

Volume II, Appendix P Traffic Impact Report, table 8) and assess the impact on the 

intersection of TLH with Cross Creek Road. In addition, the latest study indicates there 

are 1000 round trips per day on Cross Creek which means there are 500 vehicles that 

need to enter TLH each day without the benefit of any mitigating action. 

4) The project needs a total TLH traffic study including residents, guests, and service 

vehicles with their impacts on all intersections. Stonefield and Cross Creek are just 

the most obvious intersections needing mitigation for the 422 trips increase projection 

as indicated in EIR Volume II, Appendix P Traffic Impact Report, Table 8. 

5) The project needs to make a recommendation on parking safety as cited in 

Appendix P Traffic Impact Report, VI Project Impacts, A. Significant Criteria 8., 9., & 

10.


Location of Intersections: 



1) West Thomas Lake Harris Drive & Fountaingrove Parkway 

2) Thomas Lake Harris Drive & Stonefield Lane 

3) Thomas Lake Harris Drive & Cross Creek Road 

4) East Thomas Lake Harris Drive & Fountaingrove Parkway


Response to Comment Letter from Dewey Nelson (letter dated July 17, 2008) 


letter. 

1) See Master Response Local Traffic. The Emissions Calculations incorrectly assumed a 

greater number of trips generated by the Project than what was used for the Traffic 

Impact Analysis. This over-estimate occurred because of a double-count of offsite 

workers commuting to the site, which are included in the 382 Community Care 

Center trips in the traffic analysis (Table 3.13-2). Although the emissions analysis 

over-estimated the traffic count, it provided a more conservative evaluation of 

potential air quality impacts. The Project was determined to have 

less-than-significant operational emissions (assuming the greater number of 

494 trips), and no measures to reduce vehicle trips and miles are required (see 

Draft EIR p. 3-37). The conclusion that there is no significant air quality impact from 

trips generated by the project remains unchanged. 



4) See Master Response Local Traffic. Although data and analysis from the traffic 

report in Appendix P to the Draft EIR were used in preparation of the Draft EIR, the 

conclusions presented in the Draft EIR were drawn independently by the City’s EIR 

consultant and the City after considering the study data. The significance criteria 

used for the EIR analysis are listed in Section 3.13.2 of the Draft EIR. 


6) See Response to Comment Epperly–14 and Master Response Local Traffic. The 

Project will not result in an increase in hazards due to design features or 

incompatible uses; see Impact 3.13-3 in the Draft EIR. 


8) See Master Response Local Traffic. A detailed traffic study was conducted for the 

Project and is provided as Appendix P of the Draft EIR. 

9) As described in Section 3.13.3, the parking proposed for the Project exceeds the 

parking required by the City. As described in Impact 3-13.3 in the Draft EIR, the 

Project would not result in any significant increases in hazards. 

2-100 ES092008001PHX\BAO\082970001


NELSON 

JULY 19 – 1 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Nelson19July.htm 






Sent: Saturday, July 19, 2008 3:37 PM 



Dear Joel, 

Below are my comments and recommedations aimed at Appendix P of the EIR for The Lodge at 

Fountaingrove. 

Sincerely, 

Dewey Nelson 



707-544-6327 







1) The EIR failed to consider the increased traffic (422 trips per day as indicated 

in EIR Volume II, Appendix P, Traffic Impact Report, Table 8) and to assess the 

impact on the intersections with Thomas Lake Harris Drive (TLH) and its 

numerous intersections with cross streets and side streets. The analysis needs to 

file:///C|/Documents%20and%20Settings/mgerut/My%20Doc...nts/Fountain%20Grove/Comment_Letters/Nelson19July.htm (1 of 5)8/1/2008 2:10:09 PM


NELSON 

JULY 19 – 1 


consider crosswalks, stop signs, speed bumps, etc. as opposed to just traffic 

signals. And decide if the 494 trips per day in EIR Volume II, Appendix D, 

Table D-1 is accurate. 

2) In EIR Volume II, Appendix P Traffic Impact Report, VII Recommended 

Improvements A.2. States: “TLH Drive (East)/Fountaingrove Parkway – 

Unacceptable Level of Service & Signal Warrant: Drivers using the 

unsignalized TLH Drive (East)/Fountaingrove Parkway intersection have the 

option of using Fir Ridge Drive to access a signalized intersection with 

Fountaingrove Parkway. Based upon input from City traffic engineering staff, it 

is not the City’s desire that the TLH Drive (East)/Fountaingrove Parkway 

intersection be considered for signalization due to the ease of access to the Fir 

Ridge Drive intersection with Fountaingrove Parkway.” 

Resolving an Unacceptable Signal Warrant by stating drivers have the 

option to drive through a long out-of-the-way loop in a residential area is 

ludicrous and totally unacceptable. We are, after all, concerned about the 

safety of our citizens. In addition, Volume I Executive Summary Table ES- 

1 3.13-1 states a traffic signal would change the impact from “Significant” 

to Less than Significant”. 

3) In EIR Volume II, Appendix P Traffic Impact Report, VII Recommended 

Improvements A.2. States: “TLH Drive (West)/Fountaingrove Parkway – 

Unacceptable Level of Service & Signal Warrant: Although AM peak hour 

volumes at the TLH Drive (West)/Fountaingrove Parkway would be approaching 

signal warrant criteria, the number of vehicles experiencing LOS F delay for left 

turns from TLH Drive (West) will be small. In addition, the intersections along 

Fountaingrove 

Parkway immediately east and west of TLH Drive (West), at Altruria Drive and 



NELSON 

JULY 19 – 1 


Round 

Barn Boulevard, are now both signalized and provide some gaps in traffic flow 

along 

Fountaingrove Parkway. For this reason, City traffic engineering staff have 

indicated 

their desire not to signalize this intersection. Should the City wish to provide an 

improvement measure, consideration could be given to providing a median refuge 

area 

along Fountaingrove Parkway just east of the intersection to facilitate left turns 

from 

TLH Drive (West). Resultant operation of left turn movements from TLH Drive 

(West) 

to Fountaingrove Parkway would be an acceptable LOS D during both the AM and 

PM 


Resolving an Unacceptable Signal Warrant because there are nearby traffic 

lights makes little sense and is totally unacceptable. Again, we are 

concerned about the safety of our citizens. In addition, Volume I Executive 

Summary Table ES-1 3.13-1 states a traffic signal would change the impact 

from “Significant” to Less than Significant”. 

4) The EIR traffic engineer needs to make his own conclusions rather than rely 

on the city traffic engineer’s “opinions” while ignoring his own data. See EIR 

Volume II, Appendix P Traffic Impact Report, VII Recommended 

Improvements A.2. and A.3 






NELSON 

JULY 19 – 1 


The Planning Commission needs to have the Crane Transportation 

Group revise their EIR to include: 


1) EIR Volume I, Executive Summary, Potential Impacts and Mitigations, Table 

ES-1, 3.13 Transportation and Traffic resolves Impact 3.13-1 with traffic signals 

for the intersections of east and west Thomas Lake Harris Drive (TLH) with 

Fountaingrove Parkway and needs to be adopted. However, there is no time 

frame for installation and the project needs to install those traffic signals as 

a first step in the construction process. In my view the increased traffic from 

construction trucks and construction workers will increase traffic to the levels 

projected when the development is complete. 

2) The project needs to install stop signs on TLH at the intersection with 

Stonefield Lane. The EIR failed to consider the increased traffic (422 trips per 

day as shown in Volume II, Appendix P Traffic Impact Report, Table 8) and 

assess the impact on the intersection of TLH with Stonefield Lane. There are 

122 residents living on Stonefield Lane with a greater number of owner 

vehicles--each home has a two car garage. Those residents, along with their 

guests, service vehicles, etc. create a great deal of traffic, not to mention the 

pedestrian traffic as the spa, tennis court, and pool are on opposite sides of TLH 

Drive. When making left hand turns or crossing TLH Drive, the sight distance is 

limited in both directions. To the north TLH curves downhill while to the south 

TLH is curved and with a steep downhill, both limiting the visibility of 

oncoming vehicles. 

3) The project needs to install stop signs on TLH at the intersection with 

Cross Creek Road. The EIR failed to consider the increased traffic (422 trips 

per day as shown in Volume II, Appendix P Traffic Impact Report, table 8) and 

assess the impact on the intersection of TLH with Cross Creek Road. In 

addition, the latest study indicates there are 1000 round trips per day on Cross 

Creek which means there are 500 vehicles that need to enter TLH each day 



NELSON 

JULY 19 – 1 


without the benefit of any mitigating action. 

4) The project needs a total TLH traffic study including residents, guests, 

and service vehicles with their impacts on all intersections. Stonefield and 

Cross Creek are just the most obvious intersections needing mitigation for the 

422 trips increase projection as indicated in EIR Volume II, Appendix P Traffic 

Impact Report, Table 8. 

5) The project needs to make a recommendation on parking safety as cited 

in Appendix P Traffic Impact Report, VI Project Impacts, A. Significant Criteria 

8., 9., & 10. 

____________________________________________________________ 

Explore all of Europe's beauty! Click now for great vacation packages! 





letter. 

1) Comments noted. The City could not identify any differences between the comments 

presented in this July 19 letter from the previous letter dated July 17. Please refer to 

the Responses to Comments Nelson July 19 – 1 through 9. 

2-106 ES092008001PHX\BAO\082970001


NELSON 

JULY 22 – 1 









I'm very sorry, but the previous message had errors in the detail which have now been corrected. Dewey 

DeweyNelson@juno.com> 

To: JGalbraith@srcity.org 

Date: Sat, 19 Jul 2008 15:37:23 -0700 


Dear Joel, 

Below are my comments and recommedations aimed at Appendix P of the EIR for The Lodge at Fountaingrove. 

Sincerely, 

Dewey Nelson 



707-544-6327 





8/8/2008 



1) The EIR failed to consider the increased traffic (422 trips per day as indicated in EIR Volume II, Appendix P, 

Traffic Impact Report, Table 8) and to assess the impact on the intersections with Thomas Lake Harris Drive 

(TLH) and its numerous intersections with cross streets and side streets. The analysis needs to consider 

crosswalks, stop signs, speed bumps, etc. as opposed to just traffic signals. And decide if the 494 trips per 

day in EIR Volume II, Appendix D, Table D-1 is accurate. 

2) In EIR Volume II, Appendix P Traffic Impact Report, VII Recommended Improvements A.2. States: “TLH Drive 

(East)/Fountaingrove Parkway – Unacceptable Level of Service & Signal Warrant: Drivers using the unsignalized 

TLH Drive (East)/Fountaingrove Parkway intersection have the option of using Fir Ridge Drive to access a 

signalized intersection with Fountaingrove Parkway. Based upon input from City traffic engineering staff, it is 

not the City’s desire that the TLH Drive (East)/Fountaingrove Parkway intersection be considered for 

signalization due to the ease of access to the Fir Ridge Drive intersection with Fountaingrove Parkway.” 

Not resolving an Unacceptable Signal Warrant by stating drivers have the option to drive through a long out-of-the-way 

loop in a residential area is ludicrous and totally unacceptable. We are, after all, concerned about the safety of our 

citizens. In addition, Volume I Executive Summary Table ES-1 3.13-1 states a traffic signal would change the impact from 

“Significant” to Less than Significant”. 

3) In EIR Volume II, Appendix P Traffic Impact Report, VII Recommended Improvements A.2. States: “TLH Drive 

(West)/Fountaingrove Parkway – Unacceptable Level of Service & Signal Warrant: Although AM peak hour volumes at the 

TLH Drive (West)/Fountaingrove Parkway would be approaching signal warrant criteria, the number of vehicles experiencing 

LOS F delay for left turns from TLH Drive (West) will be small. In addition, the intersections along Fountaingrove 

Parkway immediately east and west of TLH Drive (West), at Altruria Drive and Round 

Barn Boulevard, are now both signalized and provide some gaps in traffic flow along 

Fountaingrove Parkway. For this reason, City traffic engineering staff have indicated 

their desire not to signalize this intersection. Should the City wish to provide an 

improvement measure, consideration could be given to providing a median refuge area


NELSON 

JULY 22 – 1 

along Fountaingrove Parkway just east of the intersection to facilitate left turns from 

TLH Drive (West). Resultant operation of left turn movements from TLH Drive (West) 

to Fountaingrove Parkway would be an acceptable LOS D during both the AM and PM 


Not resolving an Unacceptable Signal Warrant because there are nearby traffic lights makes little sense and is totally 

unacceptable. Again, we are concerned about the safety of our citizens. In addition, Volume I Executive Summary Table 

ES-1 3.13-1 states a traffic signal would change the impact from “Significant” to Less than Significant”. 

4) The EIR traffic engineer needs to make his own conclusions rather than rely on the city traffic engineer’s “opinions” while 

ignoring his own data. See EIR Volume II, Appendix P Traffic Impact Report, VII Recommended Improvements A.2. and A.3 




The Planning Commission needs to have the Crane Transportation Group revise their EIR to include: 


1) EIR Volume I, Executive Summary, Potential Impacts and Mitigations, Table ES-1, 3.13 Transportation and Traffic resolves 

Impact 3.13-1 with traffic signals for the intersections of east and west Thomas Lake Harris Drive (TLH) with Fountaingrove 

Parkway and needs to be adopted. However, there is no time frame for installation and the project needs to install those 

traffic signals as a first step in the construction process. In my view the increased traffic from construction trucks and 

construction workers will increase traffic to the levels projected when the development is complete. 

2) The project needs to install stop signs on TLH at the intersection with Stonefield Lane. The EIR failed to 

consider the increased traffic (422 trips per day as shown in Volume II, Appendix P Traffic Impact Report, 

Table 8) and assess the impact on the intersection of TLH with Stonefield Lane. There are 122 residents living 

on Stonefield Lane with a greater number of owner vehicles--each home has a two car garage. Those residents, 

along with their guests, service vehicles, etc. create a great deal of traffic, not to mention the pedestrian traffic 

as the spa, tennis court, and pool are on opposite sides of TLH Drive. When making left hand turns or crossing 

TLH Drive, the sight distance is limited in both directions. To the north TLH curves downhill while to the south 

TLH is curved and with a steep downhill, both limiting the visibility of oncoming vehicles. 

3) The project needs to install stop signs on TLH at the intersection with Cross Creek Road. The EIR failed to 

consider the increased traffic (422 trips per day as shown in Volume II, Appendix P Traffic Impact Report, table 

8) and assess the impact on the intersection of TLH with Cross Creek Road. In addition, the latest study 

indicates there are 1000 round trips per day on Cross Creek which means there are 500 vehicles that need to 

enter TLH each day without the benefit of any mitigating action. 

4) The project needs a total TLH traffic study including residents, guests, and service vehicles with their impacts 

on all intersections. Stonefield and Cross Creek are just the most obvious intersections needing mitigation for 

the 422 trips increase projection as indicated in EIR Volume II, Appendix P Traffic Impact Report, Table 8. 

____________________________________________________________ 

Looking for insurance? Click to compare and save big. 

8/8/2008 

Page 2 of 2




letter. 

1) Comments noted. The City could identify only one difference between the comments 

presented in this July 22 letter from the previous letters, a change in the phrase 

“Resolving an Unacceptable Signal Warrant…” to “Not resolving an Unacceptable 

Signal Warrant.…” This change does not require a modification in responses; please 

refer to the Responses to Comments Nelson July 19 – 1 through 9. 

ES092008001PHX\BAO\082970001 2-109





Subject: FW: Fw: EIR Report to PC 

Attachments: EIRTrafficPresentation.doc 

From: Gigi LaFontaine [mailto:gigi.lms@sbcglobal.net] 


To: scott@hallandbartley.com; ncaston@sonic.net; pacisco@aol.com; vicki@15000inc.com; tk@mkgrp.com; davidpoulsen816@msn.com; Galbraith, Joel; Meredith, 

Marie; Morris, Erin 

Cc: 'Dewey Nelson'; Skip Epperly 

Subject: Fw: EIR Report to PC 

Comments on the Fountaingrove Lodge Project Draft Environmental Impact Report 

Dewey Nelson


NELSON 

JULY 28 – 1 

NELSON 

JULY 28 – 2




letter. 

1) See Master Response Local Traffic and Response to Comment Nelson July 17 – 1. 


2-112 ES092008001PHX\BAO\082970001


NELSON 

JULY 31 – 1 

NELSON 

JULY 31 – 2 



Sent: Friday, August 01, 2008 8:25 AM 


Subject: FW: Input to the Fountaingrove Lodge DEIR 

Mary, 

This just came in. 

It is after the deadline, but we should respond if there is anything significant. 

Joel 

From: Dewey D Nelson [mailto:deweynelson@juno.com] 


To: Galbraith, Joel; tk@mkgrp.com; davidpoulsen816@msn.com; Vicki@15000inc.com; 

scott@hallandbartley.com; pacisco@aol.com; ncaston@sonic.net 

Subject: Input to the Fountaingrove Lodge DEIR 

Dear Planning Department and Planning Commision, 

The final input from the Advocates for Resposible Development inadvertally did not include my 

comments to the Planning Commision at the July 24th public hearing and so those comments are 

included below. Also, there was a rather huge error on the final page about the need for a traffic 

light at EAST TLH and FGP while it should have said both intersections of TLH (west/east) 

with FGP--you'll see what I mean by reading the last paragraph of my comments. 

Thanks for listening. 

Dewey Nelson 



707-544-6327 

Planning Committee Review of Fountaingrove Lodge 

EIR 

07/24/08 

My name is Dewey Nelson and I live at 2003 Stonefield Lane. My primary 

concerns with the EIR are with traffic which is covered in detail in Appendix P. the 



NELSON 

JULY 31 – 2 


Traffic Impact Report and also in the Executive Summary under 3.13 the Traffic & 

Transportation 

According to the EIR impact report but, depending on where you read, there will be 

an increase of 422 or 494 vehicle trips per day TLH. And yet the report did not 

evaluate the impact of that increase in traffic on all of the intersections with TLH. 

Cross Creek alone has 1000 trips per day, while Stonefield Lane is fed by 122 units 

each with a two car garage—we are talking 200+ vehicles not counting guests and 

service vehicles that are using this one intersection. The EIR Impact Report needs 

to evaluate the traffic exposures on all of these intersections with TLH, not just the 

two mentioned, and with emphasis on all left hand turns including those into the 

Lodge and the dental office on TLH and FGP. 

In Appendix P, both the east and west intersections of TLH with FGP were studied 

and met the requirements for a traffic signal, but no traffic signals were 

recommended. In both cases, input from the city’s traffic engineering department 

was cited and, in my opinion, both reasons are unacceptable. 

But, the Executive Summary Mitigation measure 3.13-1 does state there shall be a 

traffic signal at TLH and FGP, but fails to include both intersections. However, 

also in the Executive Summary table ES-1 3.13-1 it is stated that the traffic signals 

would improve the status of these two intersections from unacceptable to 

acceptable. Not noted is that there will also be a sudden increase of traffic from 

construction workers and heavy construction vehicles which will create an 

immediate safety hazard at the intersections. We, therefore, not only need 

traffic signals at both of these intersections, but they are needed at the 

beginning of construction. 

We are, after all, talking about the safety of our citizens. 




Thank you for listening! 

____________________________________________________________ 

Fly cheap! Click here for great airfare deals. 





letter. Note that this letter was postmarked after the deadline to submit comments to the Draft EIR. 

However, to be responsive to its citizens, the City will include this letter in the list of comment letters 

received. 


2) Comments noted. The City could not identify any differences between the comments 

presented in this July 31 letter from the previous letter dated July 28. Please refer to 

the Responses to Comments Nelson July 28 – 1 and 2. 

2-116 ES092008001PHX\BAO\082970001


NEUMAN – 1 

NEUMAN – 2 

NEUMAN – 4 

NEUMAN – 5 

NEUMAN – 6 

NEUMAN – 7 

NEUMAN – 8 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Neuman.htm 




Subject: FW: EIR meeting Aegis 

From: Ryan J Neuman [mailto:r_neuman@msn.com] 


To: scott@hallandbartley.com; Galbraith, Joel 

Subject: EIR meeting Aegis 

We are unable to attend the meeting today. We however would like to voice our VERY STRONG OPINION 

AGAINST any large projects on Thomas Lake Harris. We are horrified each time we look off our back 

deck to see Varenna a very large eyesore sticking up in what used to be an upscale neighborhood. 

Fountaingrove is the only upscale neighborhood in Santa Rosa and it is being turned from an enjoyable 

place to live to a nightmare. We had hours and hours of horrible pounding with the Varenna building. 

We have young children and are not looking to raise them in a commercial setting. The city of Santa 

Rosa cannot make another mistake on our hill. We have too many elder care facilities as it is. The traffic 

and noise would be horrible if a 24 hour a day facility were allowed to be put in. We did not buy our 

home in a commercial area we bought in a neighborhood and would like to keep it that way. The park in 

our neighborhood is directly across from the proposed site. This facility would not be good for our sleep, 

increased traffic, people and services to a facility like this would be unbearable. Someone has to stop 

these people from taking out trees, I think it is the city's job to protect the Heritage Oaks. PLEASE STOP 

THIS PROJECT FROM GOING FORWARD AND RUINING OUR NEIGHBORHOOD. 

Ryan and Sheri Neuman 

3776 Skyfarm Drive 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Neuman.htm8/1/2008 2:10:10 PM 

NEUMAN – 3


Response to Comment Letter from Ryan and Sheri Neuman 


letter. 




4) See Master Responses Noise and Traffic. 


6) The comment refers to City-owned land west of Thomas Lake Harris Drive across 

from the Project site; given the Project’s separation from the parkland via Thomas 

Lake Harris Drive, it is not anticipated that the Project would affect the use of the 

parkland . Impacts to public recreation, including parks, are addressed in Draft EIR 

Section 3.12. The Draft EIR analyzed whether the Project could increase the use of 

existing neighborhood parks such that substantial physical deterioration of the 

facility would occur or be accelerated. Impacts were considered temporary and less 

than significant; therefore, no mitigation measures were required (Draft EIR p. 3- 

139). 

7) Comment noted. See Master Response Local Traffic. The traffic generated by the 

project will not have any significant impact after mitigation is incorporated. 


2-118 ES092008001PHX\BAO\082970001


NCRWQCB – 1


NCRWQCB – 1 

NCRWQCB – 2 

NCRWQCB – 3 

NCRWQCB – 4


NCRWQCB – 5 

NCRWQCB – 6

ES082008001BAO_Fountaingrove_publicComments_v3.indd_090408_lho




Response to Comment Letter from North Coast Regional Water Quality Control 

Board (NCRWQCB) 


letter. 

1) The City acknowledges the RWQCB’s support of the Draft EIR and “the very 

positive programs and improvements” suggested in it. The City also acknowledges 

the RWQCB’s concerns about potential significant impacts to water quality. 

Potential impacts to water quality are addressed in Section 3.8.3 of the Draft EIR and 

include one potentially significant impact, Impact 3.8-2, Construction and operation of 

the Project could increase pollutants in stormwater runoff. Mitigation Measures 3.8.2, 

Comply with all applicable State and Local Regulations for stormwater will minimize 

water quality impacts from stormwater runoff and fully mitigate this potential 

impact. Mitigation measures shall include the preparation of SWPPP and a SUSMP, 

as discussed in the Draft EIR. These plans will specify site specific management 

activities to be implemented both during and after construction. 

2) The City understands that a Mitigation and Monitoring Plan describing the process 

that has been or will be taken to avoid, minimize, or compensate for loss of or 

significant adverse impacts to beneficial uses of waters of the State should be 

included in the submittal of any permit applications. See Response to Comment 

NCRWQCB-3 for additional information concerning potential impacts to State 

waters within the Study Area. 

3) The City’s zoning regulations do not allow construction with 50 feet of the creek, so 

the Piner Creek buffer zone will be preserved. Impact 3.8-2, Construction and operation 

of the Project could increase pollutants in stormwater runoff, documents the potential 

impacts of development. Mitigation Measure 3.8-2 in the Draft EIR includes 

measures to reduce and minimize these impacts. The mitigation measure has been 

revised to add a requirement for informational signage for pedestrians walking near 

the creek as follows: 

Mitigation Measure 3.8-2: Comply with all applicable State and local 

regulations for stormwater management. 

As described above, compliance with the NPDES General Construction Permit, 

Santa Rosa’s municipal stormwater NPDES permit, the grading ordinance, the 

Santa Rosa Area SUSMP, and the Storm Water Mitigation Plan will minimize any 

water quality impacts. Informational signage will be added along Project 

pathways located near the creek that describe the sensitivity of the buffer area 

and establish appropriate restrictions. 

4) As stated in the Draft EIR, a wetland delineation conducted by WRA in 2006 and 

verified by USACE in February 2008 indicated that there are no wetlands or other 

waters of the U.S., other than Piner Creek, in the Study Area. There will be no direct 

impacts to Piner Creek or its associated riparian vegetation. Three man-made 

stormwater drainages located adjacent to Thomas Lake Harris Drive were 

determined not to be waters of the U.S by USACE. Because these drainages are man- 

ES092008001PHX\BAO\082970001 2-125


made stormwater drainages and were not considered waters of the U.S. by the 

USACE, it is presumed these drainages are not under the jurisdiction of the RWQCB. 

Based on the presumed lack of State waters within the Study Area, this potential 

impact is considered less than significant. However, the City will coordinate with the 

RWQCB to verify that these drainages are not considered State waters prior to 

construction. Should these drainages be determined to be waters of the State by the 

RWQCB, the applicant will coordinate with the RWQCB to mitigate for the 

drainages at a minimum of a 1:1 ratio, or as otherwise agreed upon with regulatory 

agencies. 

5) The City acknowledges the commenter’s attached list of Storm Water and Low 

Impact Development Resources. As noted in Response to Comment NCRWQCB-3, 

the Piner Creek buffer zone will be protected. As noted in Response to Comment 

NCRWQCB – 1, mitigation measures will help minimize impacts from stormwater 

runoff. As described in Mitigation Measures 3.1-2 and 3.4-1a of the Draft EIR, 

landscaping will include primarily native species and the landscaping plan must be 

approved by the City. 

6) The City understands that the Project will need to meet water quality objectives to 

state and federal antidegradation requirements, and that the NCRWQCB may 

require additional project permits, depending on expected project impacts. 

2-126 ES092008001PHX\BAO\082970001






Subject: FW: Lodge project 

Attachments: letter to Mr. Galbraith.rtf 

letter to Mr. 

Galbraith.rtf 


From: lynn and william rood [mailto:lynn.william@mac.com] 



Subject: Lodge project 

Mr. concerns of the DEIR are attached, Lynn and William Rood 

1


ROOD – 1 

ROOD – 2 

ROOD – 3 

ROOD – 4 

ROOD – 5 

ROOD – 6 

Mr. Galbraith, 

After reading the Draft EIR for the Fountaingrove Lodge Project Volume I, we 

have concerns. 

Figure 2-1 Regional Map is incorrect as the Project location is depicted on the 

West side of Highway 101 and Figure 2-3 Project Layout of 2006 is incomplete 

since it does not show the Oaks Development built out as Figure 3.1-1 Project 

Site and Vicinity Location Viewpoints does, of 2006. Could not these erroneous 

maps put in question other information presented in the EIR? 

The 242 parking spaces planned for the Lodge is inadequate for a project of this 

size given the number of visitors to the facility, resident vehicles, cars and trucks 

for other purposes. The description of the planned parking is different throughout 

the EIR: page 2-8, page 2-11 Parking and Transportation and page 3-157. Why? 

Approximately 97 construction workers will temporarily be working at the site, 

where will their vehicles be parked? 

2.4.3 Project Construction states approximately 8 acres of land will be affected 

by grading, would this not infer that a great many more trees would be removed 

than 66% as stated in the EIR? 

A CH2M HILL wildlife biologist conducted a reconnaissance survey on 

March 30, 2007. Why weren't the surveys conducted on different days and 

months of the year and why were no protocol surveys conducted? This brief 

study was inadequate to make a valid wildlife survey. 

3.9 states the Project is not expected to conflict or affect negatively the character 

of the residential neighborhoods. How can this not negatively affect the 

neighborhoods when there will be expected trip rates of: 

40 trips due to employee housing, 382 trips due to visitors to the facility, 68 the 

assumed remaining number of workers living offsite and would contribute 1 trip 

per day, 4 delivery truck trips (only 4?), additionally transportation services 

would be available to residents requiring medical attention or other purposes. 

Are these figures for round trips or one-way trips? 

The addition of 494+ vehicles added to the existing traffic on Thomas Lake would 

negatively affect the area and cause a great inconvenience to the Stonefield 

Development. 

3.13-1 under Mitigation Measures it states that drivers also have the option of 

using the nearby Fir Ridge Drive intersection for signalized access to the 

Fountaingrove Parkway. This statement shows a lack of judgement for the 

following reasons: 1. the statement infers if traffic does use the FRD intersection 

TLHD would not be able to handle the traffic congestion that would occur with


ROOD – 6 

ROOD – 7 

ROOD – 8 

additional vehicles 2. and if vehicles use FRD, traffic would become congested 

there not only because of the existing but because the Fir Ridge Housing Project 

is estimated to add a volume of 346 daily 2-way trips, (Base Case of 2010 Trip 

generation table 3.13-1). 

4.1.13 states any incremental traffic condition by the Project to the existing 

traffic no matter how minute is considered significant and unavoidable and 

after mitigation measures it is significant and unavoidable. 

4.3 states no significant and unavoidable adverse impacts would occur as a 

result of the Project implementation. These statements contradict each other, 

what is being said here? 

In summation, the Draft EIR has made unclear and inexact presentations and 

has inadequately assessed the problems that a Project of this size would 

generate with Thomas Lake Harris Drive and the surrounding areas. It seems 

that a large project such as this should be located in a more convenient area, 

rather than on a 2 lane road. 

Respectfully, 

William C. and Lynn M. Rood 



ROOD – 9


Response to Comment Letter from Lynn and William Rood 


letter. 

1) The “Project Location” label on Figure 2-1 should be pointing to the star, which 

shows the Project location. This label has been moved and the revised figure is 

shown in Section 3 Errata and Revisions in this Final EIR. 

2) Fountaingrove Lodge is designated by the City as a Community Care Facility. City 

code for such facilities requires one space per three beds. With 235 beds proposed 

the Project is required to supply at least 79 parking spaces, significantly less than the 

217 spaces being provided for Project residents. For the apartments reserved for 

onsite staff, the City Code requires one space and 0.5 visitors spaces per studio/onebedroom 

unit and one space and 1.5 visitors spaces for two-bedroom units. Because 

there will be eight single-bedroom units and four two-bedroom units, 22 parking 

spaces would be required. The Project will comply with this parking requirement. 

Therefore, the Project exceeds the overall parking requirements and no significant 

impacts to parking would occur. 

The Draft EIR breaks the total parking down in several different ways. A summary 

of these breakdowns is provided below. A total of 242 parking spaces are planned 

for the Project. 

Resident/Visitor Parking Total 

No. of Spaces 

Main Building Covered Spaces 99 

Flats Building Covered Spaces 18 

Surface spaces (various locations) 89 

Resident parking – cottage garages 14 

Employee Parking Total 22 

Total Spaces 242 

3) See Master Response Oak Trees and Oak Woodland. Onsite trees are concentrated in 

woodland areas, which were avoided to the degree feasible in Project design. For 

this reason, percent of land graded is not equal to percent of trees impacted. 

4) The wildlife study conducted by CH2M HILL on March 30, 2007, was a 

reconnaissance survey. A reconnaissance survey is a preliminary visual survey 

conducted to identify the occurrence and condition of general habitat types as well 

as potential species that could be present or otherwise use the surveyed area. 

As stated in the Draft EIR, the reconnaissance survey and several other sources of 

data (see p. 3-51) were used to identify potential habitat for special-status wildlife 

species known to occur in the vicinity of the Study Area and to determine specialstatus 

species potential to occur within the Study Area (see p. 3-51). The information 

2-130 ES092008001PHX\BAO\082970001


obtained from data sources and the reconnaissance survey was sufficient to identify 

special-status wildlife species potentially present in the Study Area, to evaluate 

potential impacts, and to identify appropriate mitigation measures. See Impact and 

Mitigation Measures 3.4-3, 3.4-4, and 3.4-5. Mitigation measures include preconstruction 

surveys, as needed, for nesting birds, roosting bats, and western and 

northwestern pond turtle. 

5) See Master Response for Local Traffic. The traffic generated by the Project will not 

have any significant impact after mitigation is incorporated. The trip numbers listed 

in Table 3.13-2 Project Trip Generation in the Draft EIR represent two-way trips 

(roundtrips). The Draft EIR figures provided show one-way trips occurring during 

the peak hours. 

6) The analysis of the traffic impacts, the development of the mitigation, and the 

conclusion regarding level of impact described in Impact 3.13-1 did not assume the 

use of Fir Ridge Drive intersection to avoid the Thomas Lake Harris 

Drive/Fountaingrove Parkway intersection. The analysis was based on a trip 

distribution model to primary roadways (see Table 3.13-3). It should be noted that 

the turns at the Fir Ridge Drive intersection with the Project and the Fir Ridge 

Housing Project will be operating at high levels of service, as shown in Table 3.13-5 

(see Base Case plus Project data). 

7) See Response to Comment Aegis – 22. 

8) Comment noted. See Master Responses Local Traffic, Land Use Compatibility, and 

Visual Resources. 


ES092008001PHX\BAO\082970001 2-131

SCHARF – 3 


file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Scharf.htm 




Subject: FW: gay retirees on TLH Dr. 

From: lsantarosa@aol.com [mailto:lsantarosa@aol.com] 



Subject: gay retirees on TLH Dr. 

Dear planning dep't supervisor: I did not attend the meeting yesterday, but have downloaded the 

EIR, and want to let you know that a fourth senior residential complex and/or assisted 

living project in our neighborhood goes violently against my wishes. Filling in vacant land just 

because it may pass the zoning test for what the owner or his sponsor/developer envisions is not 

really urban planning. You may have worked at city hall long enough to dismiss NIMBY 

objections to so many of the projects you manage as a planner, so I may be wasting my 

bandwidth here. Please consider balancing the fact this lot may be zoning-suitable for a facility 

such as this, with the detrimental effects this would have in the hills in which we chose to live. I 

grew up in this part of town, am over 55, and am discouraged and upset each time I drive FG 

Pkwy and see the Monster which took over the lake & overwhelmed the hillsides, Jim Gallaher's 

Varenna may or may not prove to be financially successful, but his years of contributions to the 

city's leaders running for office did have a pay-off in the form of this shocking retirement city in 

what was Fountaingrove. Can we weigh the rights of the landowner to make use of land and the 

city's need for prop. tax revenue and other fees, against the irreversible destruction of nature? 

Isn't it nature and the things these projects threaten & destroy which attracted us here? My name 

is Larry Scharf, I do support property rights and the need to develop the city, but am against 

ripping up this 10 acre wooded parcel. My address is 1960 Fountainview Cir. Thank You. 

The Famous, the Infamous, the Lame - in your browser. Get the TMZ Toolbar Now! 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Scharf.htm8/1/2008 2:10:10 PM 

SCHARF – 1 

SCHARF – 2

Response to Comment Letter from Larry Scharf 



letter. 


2) Comment noted. The Project site has been planned for development since at least 

1972, when the FRPCD Policy Statement was adopted. The site has been part of 

extensive urban planning efforts, including updates to the FRPCD Policy Statement 

in 1981 and 1992 and in the General Plan, as well as prior versions of the General 

Plan. As discussed in Section 3.9 Land Use in the Draft EIR and in Master Response 

Land Use Compatibility, the Project is consistent with the land uses designated in 

the FRPCD Policy Statement, which would allow a range of uses including singlefamily 

and multi-family housing, community oriented uses such as health care 

facilities, and private recreational facilities. As a community care facility, the Project 

is considered a nonresidential land use, which is allowed in any zoning district 

through the Conditional Use Permit process. 

3) See Response to Comment McGuckin July 18-3. As described in Section 2 of the 

Draft EIR, the purpose of the Project is help to meet housing and service needs of the 

City’s senior community, consistent with the policies and goals in the General Plan 

that call for projects and services to support the needs of seniors in Santa Rosa. As 

discussed in Section 3.4 of the Draft EIR and in Master Response Oak Trees and Oak 

Woodland, impacts to biological resources from the Project will be less than 

significant with mitigation. 

ES092008001PHX\BAO\082970001 2-133

SCIGLIANO – 1 


file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Scigliano.htm 


Sent: Wednesday, July 23, 2008 8:32 AM 


Subject: FW: Aegis Construction Plans for Fountaingrove Lodge 

From: Lynda Scigliano [mailto:lscigliano@sonomaselpa.org] 

Sent: Tuesday, July 22, 2008 3:01 PM 


Subject: Aegis Construction Plans for Fountaingrove Lodge 

Santa Rosa City Council Members: 

Joel Galbraith, Supervising Planner 

Scott Bartley, Planning Department 

As a Santa Rosa resident, I am outraged to hear there is yet another retirement facility planned in 

the Fountaingrove area by Aegis Construction! 

This once beautifully wooded area has been over-built with no regard for the countless number of 

trees that have been removed by greedy builders trying to squeeze as many homes and facilities 

in as possible. Not to mention, the increased traffic, air pollution, and demise of a once upscale 

residential neighborhood now becoming commercial! 

Varenna is massive, yet construction continues! Will it ever stop? Who approved this monster? 

Another major annoyance occurs Monday through Friday when Varenna contractors block one 

lane of the Parkway with no regard for the residents trying to get to work at 8:00 a.m. 

Do our City Planners think of nothing beyond increasing revenue at the expense of the 

community? Please consider rersponsible development; the infrastructure just isn't in place for 

continued commercial construction. Thank you. 

Lynda Scigliano 

3704 Newbury Court 

Santa Rosa 95404 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Scigliano.htm8/1/2008 2:10:10 PM

Response to Comment Letter from Lynda Scigliano 



letter. 

1) Comment noted. As described in Draft EIR Sections 3.3 (Air Quality), 3.4 (Biological 

Resources), 3.9 (Land Use), and 3.13 (Traffic and Transportation), Project impacts to 

air quality, biological resources, land use, and traffic will be less than significant with 

mitigation. Also see Master Responses Local Traffic and Land Use Compatibility. 

ES092008001PHX\BAO\082970001 2-135


SPENCER – 1 

SPENCER – 2 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Spencer.htm 





From: sonomarealty8@juno.com [mailto:sonomarealty8@juno.com] 

Sent: Sunday, July 27, 2008 3:18 PM 


Subject: Fountaingrove Lodge 

Dear Sir, 

As a resident of the Fountaingrove area I am concerned about the flawed EIR and its 

inadequacy to project the impact Fountaingrove Lodge will have. Most aspects of the 

development are significant, not insignificant. 

1. visual pollution 

2. noise pollution 

3. traffic impact 

4. natural disturbance 

I think the size and scope of the project should be scaled down. A more sensible balance 

between the development and the site should be established. 

Respectfully submitted, 

Alan Spencer 

3710 Autumn Glen Court 


file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Spencer.htm (1 of 2)8/1/2008 2:10:10 PM

Response to Comment Letter from Alan Spencer 



letter. 

1) Comment noted. Without specific comments defined, the City cannot provide a 

more detailed response. As described in the Draft EIR, the City determined that the 

Project would have less than significant impacts, with the incorporation of 

mitigation, to aesthetics, noise, traffic, and biological resources. See also the Master 

Responses presented in this Final EIR. 


ES092008001PHX\BAO\082970001 2-137


file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Sturgeon.htm 


Sent: Friday, August 01, 2008 1:40 PM 


Subject: FW: Comments re Fountaingrove Lodge 

Here is another late one. 

I don’t see anything new in this one. 

Joel 

From: jets4@aol.com [mailto:jets4@aol.com] 

Sent: Friday, August 01, 2008 12:59 PM 


Subject: Comments re Fountaingrove Lodge 

Dear Joel, I am resending as not sure microsoft outlook which your address put me in sent comments. 

Jim 

STURGEON – 1 







Dear Joel, 

My wife and I attended the EIR hearing last week on the Fountaingrove Lodge Project and have some 

questions/issues with the project. 

1) The density of the project is overwhelming for that small piece of land. The size and height 

should be scaled back to something suitable. The retaining walls will be unsightly. The buildings 

overlooking the residences already there cannot be allowed, especially overlooking the adjacent 

Oaks community pool. 

2) The visuals on the project should be just post of construction before landscaping to show what 

natural landscaping is left e.g., heritage oaks. Then a visual showing added landscaping post 

construction, one year out and then 5 years. Not 20+ years as the current visual depicts. There 

must be an issue with all wildlife. 

3) 24 hour lighting has to be an ongoing issue with nighttime glare, etc. 

4) 24 hour noise has to be an ongoing issue with traffic and delivery vehicles. Traffic is already an 

issue on FG Parkway. 

5) Just adding a streetlight on the corner of TLH Drive and FG Parkway will not mitigate all the 

traffic this 4 th senior facility will bring to the residential area. Why not another type of project e.g., 

residential housing? Then Aegis is planning a 5 th ? We already have a Dr. Office, strip mall and 

Varenna in a residential neighborhood. I moved here for the country feel. 

6) How will this benefit Sonoma County outside of taxes given most of the residents will likely be 

out of county given the cost to be a resident and the narrow use of land. One speaker moved from 

Florida to be a potential resident. 

7) One speaker addressed the safety of these potential residents in other existing facilities such 

as Varenna, Vineyard Commons and Brighton Gardens. Perhaps this safety issue should be 

addressed before adding any additional designated Residential Care. I do not believe we need 

designated facilities as someone should be able to be safe and live anywhere. 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Sturgeon.htm (1 of 2)8/1/2008 2:10:10 PM


file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Sturgeon.htm 

Just some questions. 

Jim Sturgeon 

3631 Helford Place, Santa Rosa, CA 95404 

It's time to go back to school! Get the latest trends and gadgets that make the grade on AOL Shopping. 

file:///C|/Documents%20and%20Settings/mgerut/My%20Documents/Fountain%20Grove/Comment_Letters/Sturgeon.htm (2 of 2)8/1/2008 2:10:10 PM


Response to Comment Letter from Jim Sturgeon 


letter. Note that this email was delivered after the deadline to submit comments to the Draft EIR. 

However, to be responsive to its citizens, the City has included this email in the list of comments 

received. 

1) See Master Responses to Comments Land Use Compatibility and Visual Resources. 

2) See Master Response Visual Resources. The visual simulations included in the 

Draft EIR show the landscaping at 5 to 10 years. 

3) As described in Impact 3.1-3 in the Draft EIR, the Project would add new sources of 

nighttime security lighting along driveways, in outdoor parking lots, and near 

building entrances. Conformance to the City’s Lighting Design Guidelines and the 

Principles of Low-impact Lighting Design (see Mitigation Measure 3.1-3), which 

minimize the amount of light that leaves the site, would reduce impacts to less than 

significant. 

4) See Master Responses Noise and Local Traffic. 

5) See Master Responses Land Use Compatibility and Local Traffic. A residential 

housing project similar to the neighboring Oaks Phases I and II was evaluated as the 

No Project Alternative; see Section 5.1 of the Draft EIR. Such a development could 

result in environmental impacts greater than for the Project on traffic, air quality and 

noise; similar to or greater impacts than the Project on biological resources; and 

lesser impacts than the Project on visual resources. 

6) See Response to Comment McGuckin July 18-3. As described in Section 2 of the 

Draft EIR, the purpose of the Project is help to meet housing and service needs of the 

City’s senior community, consistent with the policies and goals in the General Plan 

that call for projects and services to support the needs of seniors in the City. 

7) It is unclear what the commenter means by “safety.” See Draft EIR Impact 3.7-4 for 

analysis of impacts to emergency evacuation plans for residents of Fountaingrove 

Lodge; impacts would be less than significant. Impact 3.7-5 discusses how operation 

of the Project could subject its residents to hazards inherent in facility design; 

impacts would be less than significant. Analysis of potential impacts to fire and 

emergency services is included in Impact 3.11-2; with mitigation, impacts would be 

less than significant. Impact 3.13-4 provides analysis of traffic-related issues during 

an emergency; impacts would be less than significant. Residential health is governed 

by licensing and permitting requirements set forth by the Community Care 

Licensing Division of the California Department of Social Services (p 3-99). 

2-140 ES092008001PHX\BAO\082970001


COMMUNITY 

COMMENTS – 1 

COMMUNITY 


COMMUNITY 

COMMENTS – 3


COMMUNITY 


COMMUNITY 


COMMUNITY 


COMMUNITY 

COMMENTS – 6


COMMUNITY 


COMMUNITY 


COMMUNITY 


COMMUNITY 

COMMENTS – 9


COMMUNITY 


COMMUNITY 


COMMUNITY 


COMMUNITY 

COMMENTS – 12


COMMUNITY 


COMMUNITY 


COMMUNITY 

COMMENTS – 14


COMMUNITY 


COMMUNITY 


COMMUNITY 

COMMENTS – 17


COMMUNITY 


COMMUNITY 


COMMUNITY 


COMMUNITY 


COMMUNITY 


COMMUNITY 


COMMUNITY 

COMMENTS – 24


COMMUNITY 


COMMUNITY 


COMMUNITY 


COMMUNITY 


COMMUNITY 

COMMENTS – 29


COMMUNITY 


COMMUNITY 


COMMUNITY 


COMMUNITY 

COMMENTS – 33


COMMUNITY 


COMMUNITY 


COMMUNITY 


COMMUNITY 


COMMUNITY 


COMMUNITY 

COMMENTS – 39


Response to Community Comments Letter (as submitted by Dewey Nelson) 


letter. 

1) See Master Response Noise. 


3) Because residents are assumed to be at home during the night, the mitigation 

measure correctly identifies daytime hours (7:00 AM to 7:00 PM, Monday through 

Saturday) as the time when the number of people in the neighborhood is at its 

lowest. This is consistent with the City’s Noise Ordinance, which has established 

criteria for acceptable noise levels throughout Santa Rosa’s residential areas 

according to the time of day: daytime hours 7:00 AM to 7:00 PM, evening hours 

7:00 PM to 10:00 PM, and nighttime hours 10:00 PM to 7:00 AM (see Draft EIR 

p. 3-124). The highest noise levels are allowed during daytime hours. 

4) See Response to Comment Nelson July 17-1. As described in Section 3.3 of the 

Draft EIR, impacts to air quality will be less than significant with mitigation. 

5) See Master Responses Land Use Compatibility and Visual Resources, and Response 

to Comment Kisling – 1. 




9) See Master Response Visual Resources. 

10) See Response to Comment Margason-4. 

11) Comment noted. The City disagrees; see responses above to Community Comments 

1 through 10. 

12) Comment noted. See Master Response for Visual Resources. 



building entrances, a potentially significant impact. CEQA Guidelines Section 

15126.4(B) states that “[f]ormulation of mitigation measures should not be deferred 

until some future time. However, measures may specify performance standards 

which would mitigate the significant effect of the project and which may be 

accomplished in more than one specified way.” Mitigation Measures 3.1-3, Conform 

to the City of Santa Rosa’s Lighting Design Guidelines and the Principles of Low-impact 

Lighting Design, is based on design standards that minimize the amount of light that 

leaves the site; this reduces impacts to less than significant. 

14) Section 15126.4 of the CEQA Guidelines requires that an EIR describe feasible 

measures that could minimize significant adverse impacts. As described in the 

Draft EIR and in various responses throughout this Final EIR, the mitigation 

ES092008001PHX\BAO\082970001 2-151


measures proposed for the Project are feasible and will reduce Project impacts to a 

less than significant level. How each mitigation measure will be implemented and 

success determined, who is responsible for its implementation, where it will occur, 

and when it will occur are listed in the Mitigation Monitoring and Reporting 

Program in Section 4.0 of this Final EIR. 

15) See Response to Comment Community Comments – 13. The City of Santa Rosa’s 

Lighting Design Guidelines and the Principles of Low-impact Lighting Design apply 

to all land uses. 

16) The Project is subject to all Bay Area Air Quality Management District’s (BAAQMD) 

prohibitory rules and regulations, even though permits may not be required (see 

Draft EIR p. 3-33). During construction, PM10 emissions from construction activities 

would be mitigated using the control measures set forth in the BAAQMD CEQA 

Guidelines as described in Mitigation Measure 3.3-2. BAAQMD established the 

guidelines. According to the BAAQMD CEQA Guidelines, implementation of its 

control measures would reduce fugitive PM10 emissions during construction to a less 

than significant level; see p. 3-38 for a list of control measures that would be used at 

the Project site. 

As described in Impact 3.3-2, exhaust emissions from construction equipment and 

heavy-duty diesel trucks used to construct the Project would result in short-term 

emissions of ozone precursors (NOX and ROG). Construction equipment emissions 

(NOX and ROG) are included in the emissions inventory that is the basis for the 

regional air quality plans and are not expected to impede attainment or maintenance 

of the ozone standards in the Bay Area. No mitigation is necessary for this less than 

significant impact. 

17) See Master Response Oak Trees and Oak Woodland. See Final EIR Section 4.0 

Mitigation Monitoring and Reporting Program, which is a CEQA-required 

document, for a list of all mitigation requirements and identified responsibilities for 

implementation and enforcement mechanisms. 

18) See Response to Comment NCRWQCB – 4. 

19) As stated in the Draft EIR, Mitigation Measure 3.4-3 provides protection of nesting 

raptors and migratory birds and nesting non-special-status birds by implementing 

measures to minimize and avoid impacts to avian species during their nesting 

season. Similarly, Mitigation Measure 3.4-4 protects roosting bats. 

Tree removal will be done during the non-nesting season. As described in 

Impact 3.4-3, most birds such as observed on the Project site have large home ranges, 

and existing adjacent habitat could provide alternative habitat during Project 

construction. For information on implementation responsibilities for mitigation 

measures for avian species, see Final EIR Section 4.0, Mitigation Monitoring and 

Reporting Program. 

20) Deer are protected and managed by CDFG as a game species under their Deer 

Management Program. Deer have no special-status conservation designation, such 

as endangered or threatened in California. 

2-152 ES092008001PHX\BAO\082970001


Wildlife movement corridors used by deer and other wildlife are evaluated under 

Impact 3.4-7 (Draft EIR p. 3-61). The most important existing wildlife corridor is 

Piner Creek and its associated wildlife habitat. The City’s zoning regulations do not 

allow construction within 50 feet of the creek, so the Piner Creek buffer zone will be 

preserved. Impacts to wildlife corridors would be less than significant. As stated in 

the Draft EIR, no defined wildlife corridor exists within the Project site in a 

north-south direction, primarily because areas to the north and south of the project 

site are developed residences. 


22) See Master Response Soils and Seismic Mitigation. Implementation responsibility, 

timing, and enforcement mechanisms for mitigation are described in Section 4.0 

Mitigation Monitoring and Reporting Program in this Final EIR. 








26) CEQA Guidelines Section 15126.4(B) states that “[f]ormulation of mitigation 

measures should not be deferred until some future time. However, measures may 

specify performance standards which would mitigate the significant effect of the 

project and which may be accomplished in more than one specified way.” Mitigation 

Measures 3.7-1, 3.7-2, and 3.7-3 require conformance with such performance 

standards, and reduce impacts to less than significant. Implementation 

responsibility, timing, and enforcement mechanisms for mitigation are described in 

Section 4.0 Mitigation Monitoring and Reporting Program in this Final EIR. 

27) Potential impacts associated with wildland fires are evaluated in Impact 3.7-3. 

Mitigation Measure 3.7-3 will minimize fire risk. As described in Impact 3.7-4, no 

significant impacts limiting emergency evacuation would occur from Project 

implementation. As noted in Impact 3.13-4 of the Draft EIR, the installation of a 

signal at the intersection of Thomas Lake Harris and Fountaingrove Parkway will 

improve emergency access to and from the site. 

28) As described in Impact 3.8-1, less than half (45.8 percent) of the site will consist of 

hardscapes. The resulting increased runoff would flow to a new system of storm 

drains and vegetated swales on the site. These new stormwater drainage facilities 

will be designed and sized appropriately to handle this increase in runoff. In 

addition, the drainage facilities will not change the overall drainage patterns on the 

site. Implementation responsibility, timing, and enforcement mechanisms for 

mitigation measures, including Mitigation Measure 3.8-2, are described in Section 4.0 

Mitigation Monitoring and Reporting Program in this Final EIR. Also see Response 

to Comment NCRWQCB – 1. 

ES092008001PHX\BAO\082970001 2-153


29) No specific comment was made. Potential impacts to groundwater recharge are 

addressed in Impact 3.8-3; impacts would be less than significant. 


31) See Master Response Noise. Noise from traffic was considered as part of the Noise 

Analysis (see Appendix O Noise Study in the Draft EIR, p. 6); traffic from the Project 

would increase noise levels by less than 1 decibels A scale (dBA) over current levels, 

and impacts would be less than significant. 


33) See Master Response for Noise and Response to Comment FRMA – 16. 

34) A Community Services District is a tax district that may be created under the City’s 

Special Tax Financing Code, Chapter 4-56 to perpetually fund the City Police 

Department, Fire Department, and/or other City General Fund operations to 

mitigate significant service impacts. Implementation responsibility, timing, and 

enforcement mechanisms for mitigation measures, including Mitigation Measure 

3.11-2a, are described in Section 4 Mitigation Monitoring and Reporting Program in 

this Final EIR. 

As described in Mitigation Measure 3.11-2b, providing an onsite Emergency Medical 

Technician would reduce the Fire Department’s need to respond to non-medical 

emergency calls in community care facilities. Emergency responses to non-medical 

emergency calls in senior living facilities impact Fire department Response times. In 

some cases residents fall or request assistance when they are not injured. Staff must 

have the ability to medically assess the resident to determine if the request is a 

medical emergency or a routine care assistance issue. As described in Impact 3.7-4, 

no significant impacts limiting emergency evacuation would occur from Project 

implementation. As noted in Impact 3.13-4 of the Draft EIR, the installation of a 

signal at the intersection of Thomas Lake Harris and Fountaingrove Parkway will 

improve emergency access to and from the site. 

35) Parking is discussed on pages 3-157 and 3-163 of the Draft EIR. The parking 

provided exceeds the City’s parking requirements; therefore, adequate parking 

capacity is provided and no significant impacts would occur. Also see Response to 

Comment Rood – 2. 


37) A safety analysis was completed by The Crane Transportation Group as part of the 

traffic study (see Appendix P to the Draft EIR). In particular, sight distances were 

evaluated using the speed observed (35 mph), not the theoretical speed limit of 

25 mph and no hazard was identified. As described in Impact 3.13-3, the minimum 

required sight distance is 155 feet, which is lower than Fountaingrove Lodge’s 

driveway design (which ranges from 285 feet to 480 feet) on Thomas Lake Harris 

Drive. Construction equipment will use the onsite staging area to turn around. As 

noted in Impact 3.13-3, although the Project would not result in a significant increase 

in traffic along Thomas Lake Harris Drive, to further reduce potential hazards to 

pedestrians who want to cross Thomas Lake Harris Drive, a new pedestrian crossing 

2-154 ES092008001PHX\BAO\082970001


will be included as a condition of Project approval. The crossing would be a raised 

speed table marked as a pedestrian crossing equipped with a pedestrian-activated 

flasher, located on Thomas Lake Harris Drive between the Flats Building and 

Employee Housing (Lot 3). 

38) No specific comment was made. Potential impacts to emergency access are 

addressed in Impact 3.7-4, no significant impacts would occur. As noted in 

Impact 3.13-4 of the Draft EIR, the installation of a signal at the intersection of 

Thomas Lake Harris and Fountaingrove Parkway will improve emergency access to 

and from the site. 

39) The state of California has published a technical advisory to provide guidance on 

addressing climate change in CEQA review (Office of Planning and Research, CEQA 

and Climate Change: Addressing Climate Change through California Environmental Quality 

Act (CEQA) Review, June 19, 2008). The guidance suggests that a Project’s greenhouse 

emissions be quantified and their significance be determined; it does not direct that 

climate change effects on water supply or other utilities be evaluated. The Project’s 

contribution to cumulative climate change effects is discussed in Section 3.3 Air 

Quality in the Draft EIR and in Response to Comment Public Hearing – 58. 

Operation of the Project may result in a net positive benefit for operational 

greenhouse gas emissions. 

Section 15145 of the CEQA Guidelines states that if a lead agency finds that a 

particular impact is too speculative for evaluation, this conclusion should be noted 

and no further discussions is required. The Climate Action Team Report to Governor 

Schwarzenegger and the Legislature (California Environmental Protection Agency, 

March 2006) analyzed the effects of potential climate change scenarios on 

California’s weather, among other areas. The report states that “There is no clear 

trend in precipitation projections for California over the next century. However the 

consensus of the recent Intergovernmental Panel on Climate Change (IPCC) model 

projections, including several models that were not selected for the present study, is 

for relatively little change in total precipitation, with a tendency toward a slightly 

greater winter and lower spring precipitation” but that “[h]igher temperatures will 

result in more precipitation as rain instead of snow and earlier melt of the snow that 

does fall…Declining snowpack will aggravate the already overstretched water 

resources in California. The snowpack in the Sierra Nevada provides natural water 

storage equal to about half the storage capacity in California’s major man-made 

reservoirs. The snowpack holds the winter precipitation in the form of snow and, 

historically, has released it in the spring and early summer as the snow melts. This 

loss in storage could mean more water shortages in the future. However, the full 

effect of this storage loss will depend in part on whether reservoirs can be managed 

to capture the earlier snowmelt while loosing flood control capacity.” The climate 

change scenarios vary widely in their potential consequences on snowpack, and the 

ability of water agencies around the state to store greater rainfall quantities will 

depend on how much additional storage is constructed and how storage is operated. 

Therefore, a reasonable estimate of effects of climate change on the City’s water 

supply cannot be made, and no further discussion is required. As described in 

Section 3.14 of the Draft EIR, the SCWA provides the City with its potable water 

ES092008001PHX\BAO\082970001 2-155


supply. The water demands for the Project were included in SCWA’s Urban Water 

Management Plan, which is also Santa Rosa’s Urban Water Management Plan. The 

SCWA has policies to encourage water conservation and plans to work with 

customers to address water supply shortages. The City has programs and policies 

for water conservation, water recycling, and others. Such plans and policies will be 

important components in developing a more comprehensive approach to addressing 

potential climate change effects. 

The potential for climate change to affect the ability to provide wastewater treatment 

or solid waste management is highly speculative and cannot be evaluated further. 

2-156 ES092008001PHX\BAO\082970001


PUBLIC 

HEARING – 1 

PUBLIC 

HEARING – 2 

PUBLIC 

HEARING – 3 

PUBLIC 

HEARING – 4 

PUBLIC 

HEARING – 5 

PUBLIC 

HEARING – 6 

Oral Comments made at July 24, 2008 Planning Commission 

Meeting 

Note: This transcript has been created based on tapes from the Planning Commission hearing. Its 

purpose is to record the comments for response purposes. Any errors in spelling or grammar are 

unintended; the transcript was not reviewed by speakers for accuracy. The City apologizes for any 

misrepresentation of speaker quotes. 

Skip Epperly 

I live at 1986 West Bristlecone Court in the city. The community as a whole I believe does 

not object to development of this property but really would encourage any development to 

be a good fit and it be appropriate in size and scope for the area to be developed. We also 

seek to ensure that the projects true environmental impacts are fairly flushed out and 

analyzed so that appropriate mitigation measures and alternatives can be considered by the 

city that reduce the impacts to the greatest extent feasible prior to approval. The proposed 

Draft EIR impact report does not adequately analyze environmental impacts in the areas of 

air quality, aesthetics, biology, greenhouse gases, seismicity, and traffic and has not crafted 

appropriate mitigation measures or alternatives that reduce these impacts. 

In the areas of aesthetics, the EIR concedes that the construction of the project components’ 

removal of trees would degrade the existing visual character and quality of the project site 

and its surroundings, constituting a significant environmental impact. However the analysis 

appears to be inadequate in its determinations. How the impacts have been reduced to 

insignificant is indeed incorrect. 

In biology the DEIR is inadequate and incomplete in its analyses and mitigation of impacts 

to biological resources. Just one of those I'll highlight - the Woodlands habitat area. The 

DEIR neglected to analyze the impacts to the 6.08 acres of the Oak Woodland habitat and 

admitted sensitive biological community on the subject site or to recommend proportionate 

mitigation. Constitutionally mitigation measures must be roughly proportional to the 

impact. Omission of the project’s impacts on habitat loss renders the true proportional 

mitigation inefficient to reduce the project’s impact to biological resources to insignificance 

The riparian habitat we find similarly that the DEIR acknowledges the existence of 0.8 acres 

of riparian habitat but does not analyze it. In addition we failed to see any of the required 

comments from the Dept of Fish and Game. The assessment that was done states that it 

likely meets the definition of the riparian habitat as described by the Fish and Game Code 

and the California Code of Regulations and would require compensatory mitigation for 

habitat losses. CEQA disallows deferral of mitigation that entails study of analyses which is 

being recommended here. 

Seismicity concerns me the most. We find that this area defers study. The deferral is not 

authorized under CEQA law and we encourage the site be studied more completely. 

Edward Margason 

My address is 3635 Thornberry Circle. I'm a registered civil engineer and geologist and I'm 

commenting today on siting retaining walls and grading for the proposed Lodge project in


PUBLIC 

HEARING – 6 

PUBLIC 

HEARING – 7 

PUBLIC 

HEARING – 8 

PUBLIC 

HEARING – 9 

PUBLIC 

HEARING – 10 

PUBLIC 


PUBLIC 


accordance with the CEQA guide sections. The site plans on the Lodge Draft EIR are 

incomplete, contradictory, and misleading because the environmental impact and mass and 

bulk of the Lodge Project are not adequately covered. In order to site the project, about 2500 

lineal feet, 5 to 7 foot high concrete retaining walls are proposed. This will result in a view of 

about 13,000 square feet of wall face area, which is directly visible from Thomas Lake Harris 

Drive. This impact is not covered by the Draft. Sections of the site are not given in the Draft 

but they should be. If they would, they would look like this (holds up a picture). Two 

retaining walls are proposed within 3 feet of Thomas Lake Harris Drive, which is on the left 

at an elevation of 450. The nearest building is only 15 feet back and looms about 50 feet 

above the street. The main 3 story building further back is over 80 feet above Thomas Lake 

Harris Drive. The walls at the street are so close together there is no room for effective 

landscaping and screening. Now, the environmental impact of the 50 to 80 foot high walls 

and building in the narrow Lodge site would look like this. We all recognize this picture. It's 

Varenna done by the Aegis company and it now proposes to a force a 15 foot acre project 

onto a 10 foot acre site. 

The Draft also fails to adequately address the impact in the extent of grading which is 

required to repair the large landslides reported between the building sites by the soil 

engineers of Giblin and Associates. 

In conclusion, the Draft EIR is inadequate and insufficient regarding the environmental 

impact of the mass and extent of grading, retaining walls, buildings, tree removal and 

topography modification which would be required if the Lodge Project were to go ahead. 

Susan Nowacki 

I live at 3734 Skyfarm Drive. I’m here to give a seven point response to the DEIR regarding 

visual impact and the land degradation for the Lodge at Fountaingrove 

1. Three alternatives were considered: No Project, Smaller Footprint with a taller building 

and three, Higher Bonus Density. The Draft EIR is inadequate because it failed to consider a 

less significant project. It’s imperative the DEIR include a full assessment of the impacts 

associated with the mitigated or reduced project with less impact on its surroundings. 

2. The project would have a significant effect on the environment according to CEQA 

Guidelines if built as proposed. The developer’s estimate of 66% of trees being removed is 

highly inaccurate. If a transparency is placed over the project, it becomes evident 95% of the 

existing trees will have to be removed to accommodate the parking areas and the buildings 

as well as earth moving equipment and retaining walls. Even with mitigation of the tree 

removal, it will take 100 years to replace ancient oaks and other trees on the site. The DEIR 

is flawed because it failed to consider the visual impact of this. 

3. The EIR comments on the horizontal mass of the buildings; however, no mitigation is 

proposed to reduce the huge bulk and mass of the buildings. 

4. The city is responsible for certifying the EIR, including grading permits. Massive grading 

was done on the neighboring Varenna project against the city and planning and engineering 

recommendations. This same kind of grading is proposed on the Lodge Project. City 

Ordinance 2196 Section B and B(1) states all land use areas shall seek and retain enhanced 

the hillside character of the site. The DEIR is flawed due to lack of response to this issue.


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


5. Homeowners are required to build respecting the slope of the land and the existing trees. 

The DEIR does not address allowing commercial developers to cut and fill at-will, which is 

what the project is proposing to do, again in conflict with City Ordinance 2196. 

6. The DEIR does not address the suitability of a massive quasi-institutional commercial 

enterprise in the middle of a residential neighborhood and finally the DEIR does not 

acknowledge the current existence of 3 huge retirement centers within a one mile radius of 

this intended project. It is our understanding Aegis plans on building a second phase to the 

Lodge just across and down the street between cluster housing and custom homes. The 

DEIR failed to address the cumulative impact of the intended 5th such facility. Additional 

large retirement centers would forever change the character of the residential neighborhood. 

The City’s general plan does not propose this area to be another Oakmont. Thank you. 

Dewey Nelson 

I live at 2003 Stonefield Lane. My primary concern with the EIR is traffic and traffic is 

covered in detail in Appendix P as well as it’s covered in the Executive Summary in section 

3.13. According to the impact report and depending on where you read it there will be an 

increase of 422 vehicles or 494 vehicles per day on Thomas Lake Harris Drive and yet with 

that increase in traffic the impact report did not evaluate the increase in traffic all the 

intersections on Thomas Lake Harris Drive. You can just think about Cross Creek; no doubt 

you’ve talked about it. There are over a thousand vehicles per day coming out of there. 

Stonefield Lane alone has over 200 vehicles that use that one little intersection to get in and 

out. So we need to have a complete study of Thomas Lake Harris, the impact on all the 

intersections it crosses probably emphasizing the left hand turns which are the most 

dangerous and includes left hand turns into the Lodge as well as out of the Lodge and our 

dental office. 

Moving away from that, the Thomas Lake Harris intersection with Fountaingrove Parkway 

was evaluated and met the requirements for having traffic signals in those two locations. 

There is an east and west of Thomas Lake Harris. They were studied but there were no 

requirements for traffic signals in Appendix P. I cited some information from both in both 

cases from the city engineering and I disagree with both of those items they discussed but I 

was encouraged a little bit when I got back to the executive summary and Section 3.1.-3 

Mitigation. It states there shall be a traffic signal at Thomas Lake Harris Drive and 

Fountaingrove Parkway, but it doesn’t say which one, or both of them. However, I'm 

encouraged if I go back in to the Executive Summary little bit and I see table ES-1 Section 3.1 

3-1 and it states that if there are traffic signals installed in both of those it moves from 

unacceptable to acceptable. 

Not noted was the fact that there is a significant increase of traffic when construction starts. 

We really need those traffic signals now, immediately when construction starts. We are, 

after all, talking about the safety of our citizens. 

Ulrike Gantz 

I live at 2046 Gardenview Place. Unlike those who live in Stonefield and the Oaks, I live 

between Varenna and the proposed Fountaingrove Lodge. For the last 4 years I have been 

listening to the intrusive sounds of construction from Varenna, only to learn that this


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


aggravation can continue for another 4 years during construction of the Lodge. I feel that the 

Draft EIR has failed to adequately study the impact of the noise assessment in Section 3.10 in 

the following ways. 

First, how can a mitigation measure be stated as not-required based on a one day study of a 

quiet residential neighborhood and not be compared to that of noise during normal 

operation of an institutional commercial facility like the Lodge that will be staffed 24/7, will 

receive multiple deliveries, that services four dining outlets, a country store, business center, 

fitness centers, a continued medical care center, etc. and all that to at least 2 loading docks? 

Secondly, how will we be guaranteed the manufacturer’s low noise options for roof top 

mechanical equipment will be installed on a flat roof since the building plans show peaked 

roof tops on all the buildings? There is a history of ongoing issues with Metronics Rooftop 

Equipment in relation to the Stonefield Development directly above. 

Thirdly, how can a construction schedule of 7 AM -7 PM Monday - Saturday be considered 

the time when the number of persons in the adjacent residential area is at its lowest? Please 

note that a large percentage of residents here are retired. 

I question the calculations of the operation emissions table in section D1. It states 68 workers 

comminuting to the site per day but failed to mention that they leave 68 more times. The 

onsite workers would leave 40 times a day. If they live onsite why would they be leaving so 

many times a day? 

There are 146 units to accommodate approximately 221 full time residents and 242 parking 

spaces. The chart shows 382 daily visitors and who are these visitors and where would 

everyone be parking, on the street? 

To service approximately 221 residents and 85 employees there are only going to be 4 

delivery trucks per day? In my hotel purchasing experience, the loading dock was a busy 

place which received multiple deliveries, such as at least 5 types of food and beverages 

service trucks, janitorial services, laundry and dry cleaning restaurant supplies, UPS, Fed- 

Ex, U.S. Postal Service, DHL, messenger yellow freight, to name a few. Equipment rentals, 

copier/printer services, moving vans and the list can go on and on. I hardly think that these 

emissions will be less then the thresholds of significance. 

Henry McGuckin 

Lovely Santa Rosa Creek was in effect destroyed decades ago by reckless development 

blunders and steps are presently underway at the cost of millions to repair some of that 

damage. In these greener times, we really ought to avoid such mistakes in the first place. 

The almost 10 acre site at issue is heavily wooded with oaks. Of the 513 trees counted there, 

338 are slated for destruction including at least 120 heritage trees, which are alive and black 

oaks about a century old with diameters of about 1.5 feet or more and a circumference of 5 

feet or more. Mitigation for this loss of precious woodland is proposed to be hundreds of 15 

gallon replacement trees planted around town or payment to the city of $100 for each 15 

gallon transplant. But century old trees are beyond price and neither 15 gallon transplants 

nor a few thousand dollars can possibility compensate for their destruction. Please don't 

permit it.


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


The reptiles, birds, and mammals which inhabit the woods are also slated for destruction. 

Lizards, frogs, snakes, turtles, deer, skunks, rabbits, foxes, squirrels, turkey, quails, hawks, 

vultures, crows, warblers, finches, mocking birds, blue birds, chickadees, and many more all 

will loose their foraging and nesting sites, and we will loose their presence among us 

forever. The report is cavalier to say the least regarding this loss. 

It tells us, for example, that no raptor has a high potential to occur or nest at this sight and 

only a few cooper’s hawks, white tail kites and long ear owls have moderate potential. But I 

have personally identified each of these species on my walks by the woods. Moderate 

potential, they are already there. The mitigation suggested for the lost nesting sites for 

raptors is to avoid construction activity during the breeding season March 1 - Sept 15, but 

that leaves only late fall and wet winter for heavy construction, so the report suggests an 

alternative, hire a biologist to find all active nests and create buffer zones to protect them. 

But given the narrow shape of the site, adequate buffer zones could completely halt 

construction. So the report offers yet a third suggestion, simply cut down all the trees with 

nesting potential during the winter. No trees, no nest, problem solved. 

Suffice it to say that the Draft Report is woefully inadequate. At the very least this project 

requires significantly downsizing to salvage more of our irreplaceable heritage oaks and all 

the creatures that dwell among them. 

Abe Farkas 

I live at 4434 Bally Bunion Lane. The EIR report does not address Impacts 3.1-1 and 3.1.-2 

aesthetics visual resources in so far as this project calls for the construction of a 3 story 

building in a neighborhood that is comprised of only 2 story homes. The current height 

limits should be respected. The sheer 3 story height, let alone and the mass and size of these 

buildings, must have a substantial negative impact on the aesthetics of our neighborhood. 

Per page 2-7 of the report, the 3 story main building will rise to the height of 49 feet and may 

run to some 600 feet in length. Imagine such a structure being dropped into the residential 

neighborhood in where you live (shows photo) and then also imagine a 3 story care center 

building over looking your swimming pool and being told there will be no significant 

impact on your neighborhood aesthetics. Just imagine that. 

The report fails to adequately address Impact 3.10-2, noises from operating the building on 

adjacent property. The mitigation measure recommended is to place the mechanical 

equipment on the roof of the buildings, yet the photos supplied in Figures 3.1-4 and 3.1-7 

clearly show sloped roofs with no provisions for any mechanical equipment. Given the near 

50 foot height of the proposed building, in addition to the noise this will compound the 

negative impacts on the aesthetics that was to have been addressed in Impact 3.1. (shows 

photo) You cannot hardly see the brown roof tops unless you are looking at the actual 

photo but they are clearly 30 feet or more up in the air, clearly visible. 

Next, this report fails to recognize the mitigation measure called for in Impact 3.4-1 loss of 

protected heritage valley oaks is inadequate and also it does not protect our aesthetic and 

visual resources. Table 3.4-3 calls for 2,107 15 gallon replacement trees, while the data in the 

same report states that 45.8 percent of the total development site will be covered with 

improvements. Where will these thousands of trees go? I ask this question because the 

placement of the building is basically on the zero lot line with three feet or less from the


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


building to the property line. The report fails to show in a realistic way how 2,107 trees can 

be planted in a narrow 3 foot or less strip of land and possibly provide an aesthetic partition 

to shield the neighborhood from view of building that are nearly 50 feet in height. 

The report as presented is inadequate as to Impact 3.9 land use planning in that it ignores 

the cumulative effect of having a disproportionate number of assisted living facilities 

concentrated into a single area. There currently exists the major facility of Varenna as well as 

Brighton Gardens and Vineyard Commons. The proposed Aegis Lodge to be followed by 

Lodge II across the way would install 5 facilities within 1 mile of each other. Neighborhoods 

which could use a facility to balance their land use should be identified. 

Kyra Janssen 

I live at 4406 Bally Bunion Lane. My comments on the Draft EIR pertain again to aesthetics 

and visual resources. Some of things I was going to say have been said. Regarding the 

mitigation to revise the landscape plan to provide a natural appearing landscape along the 

periphery, would that be satisfied when the site has been radically regraded, removing the 

natural contours of the site and most of the trees, and imposing a structural footprint 

referred to by Mr. Margason and Mr. Farkas, leaving little space along the periphery to 

achieve any natural appearing landscapes. So much for the sites. 

Concerning the surroundings, there is no sensitivity to the fact my home and 4 others along 

Gullane Drive would be directly facing the 36 bed 2 story care center facility. In my case, it 

would be from my bedroom window and from my driveway, hardly the typical view across 

the street in a residential neighborhood. 

The picture that Mr. Farkas showed was one of three in Volume 1 that are very misleading 

about the actual impact on the swimming pool on the houses on Gullane and from Thomas 

Lake Harris. In addition, this proposed enterprise fails to take into consideration that the 

community pool and spa for the Oaks homeowners would be hemmed in on the east 

property line by the care center building and on the south by the main entry driveway, to 

the entire project from Thomas Lake Harris with all sorts of different kinds of traffic coming 

and going. Again note those photographs and what they do and do not show. 

A third identified impact in this section not previously discussed concerns lighting. It rates 

as significant that the project would result in new sources of light and glare but less then 

significant if the developers “conform to City of Santa Rosa lighting design guidelines and 

the principles of low impact lightning designed.” That's the mitigation. This is a perfect 

example of a pattern throughout the Draft EIR in which formulated boiler-plate (call them 

what you will) mitigation measures are offered but don’t respond to the specific situation 

and what actually needs to be done. The reality of a 24/7 care center operation, as well as 

extensive outdoor parking areas walkways and driveways that must remained lit all night, 

are simply not addressed. Consider the parking lot at the dental building on the corner. 

Much smaller but the same problem. 

In conclusion, I would point out that of the 49 identified impacts, 22 of them are initially 

rated as significant yet all 22 effortlessly become less then significant, most of them on the 

basis of generic cut and past mitigations. None of these mitigations offer any guarantee that 

the prescribed functions would actually be meaningfully implemented, monitored or 

enforced with restitution if indicated. Unfortunately this gives little assurance that we as


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


citizens can trust that the findings of the EIR will be respected and adhered to. 

Unfortunately recent past history, including the Varenna project, gives the public meager 

cause for optimism in this regard. 

Thomas Glenn 

I live at 3159 Blackhawk Circle. Four small short points: 

- No report from CA Dept of Fish and Game in the EIR report; 

- The removal of over 100 irreplaceable native heritage oak trees; 

- No alternative plan offered for a less significant development is considered in the EIR 

and; 

- Lastly, traffic flow problems have existed for the past 4 years along side Varenna with one 

lane constantly closed before this project was considered. 

Patricia Eastes 

I live at 4550 Kilarney Circle. I want to address Impact 3.13-4, inadequate emergency access 

and Impact 3.7-3, hazard, the project would expose people or structures to a significant risk 

of loss injury or death including wildland fires. According to the EIR, they would be less 

then significant with mitigation. I disagree. An article in the SF Chronicle July 9th 2008 with 

the caption “Wildfire don't let this happen to you” talks about the 1991 firestorm in an 

Oakland area one mile wide which killed 25 people and destroyed over 3,000 homes. I am a 

survivor of that fire. Our neighborhood of 100 homes was the first to go. All 100 homes 

burned to the ground in 16 minutes. Our homes were 10 to 15 yrs old, completely up to 

code, all had smoke detectors and we had been very meticulous about following the city’s 

mandates for clearing brush, cutting tree ladders, etc. We had good, wide roads and easy 

access to them, unlike most of the narrow winding roads so common in the Oakland- 

Berkeley hill area. In the 3,000 degree heat it does not matter much what kind of building 

material has been used; even steel will melt at 2500 degrees. Getting out of the area was 

sheer pandemonium. People panicked; they were going through red lights, making illegal 

turns. It was every man for himself. We were literally running for our lives. 

I’m talking about this because of our situation at Fountaingrove, we do interface with 

wildland. We are in a high fire area. We have a two-way street for evacuation and the fire 

equipment to get in and with another 422 plus cars on the road (that’s the number of 

parking spaces for Fountaingrove) our chances of getting out in time are severely impacted. 

This is California. We have dry seasons. We have droughts. We have wildfires and 

according to the Chronicle article, between June 20th and July 9th of this year there have 

been 1781 wildfires. Is it fair to either the people who move in here or to us who already live 

here to risk our lives with the high density development? My hope is you will consider this 

matter very carefully. 

Frank Miles 

I live at 3640 Kelsey Knolls Drive. I guess I’m the first one to have a positive spin on things. I 

recently moved here a couple of months ago in anticipation of the Lodge being built. 

Unfortunately, I see it will be delayed for a while. Looking at the EIR report I was very


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


pleased to see, although I feel for some of these people talking about the oak trees. I 

understand development was going to go in there anyway, so those trees would have been 

impacted. But at least the report states there will be trees replaced. Granted they will not be 

as old as the tress there, and that extensive landscaping will take place. 

In addition to that I can understand that with a facility such as that is proposed there will be 

probably more people then were anticipated. With the condos I believe I understood were 

going to go up and down but the activities will be controlled there, which you can’t say for 

some of the private facilities and I believe that would be a big benefit. I’m not an engineer, 

not by education like the presentation that you saw, but I was surprised to see the 

presentation by the lady that was sitting right here that stated what Fountaingrove was 

originally planed for and I was pleasantly surprised to see that it said it was planned for 

senior care facilities and such. I’m not quite clear on a lot of the home owners that are 

nearby that bought in that area without seeing this and understanding that this is a 

possibility of this being built in their neighborhood. 

I am looking forward to hopefully see that Lodge built because I recently moved here from 

Florida after selling my house and getting out here with the anticipation that this facility 

will be soon be completed, but as I can see now it is being stretched out into a future date. I 

have enjoyed getting familiar with Santa Rosa. I find it a very pleasant place to live. I’ve 

lived in the Bay Area for over 25 years and moved to Florida being a retiree, but now I see 

this is the place to retire and I hope to soon be retiring in the Lodge. 

Jim Eimers 

I'm a practicing attorney here in Santa Rosa. Before that I was a hospital administrator and 

have been involved in health care and the care of elderly, especially senior housing, in the 

last 25 years. I’m speaking today in hopes that you will look at the EIR in those terms and 

one of the terms is that the elderly population both in this county in the U.S. is growing very 

fast. The number of people over 80 is projected to quintuple in the next 20 years and people 

over 80 are the ones who will need this type of housing. I have been involved with Aegis 

before; I have referred many clients to them. I do estate planning in addition to other work 

and many of my clients are the elderly in the Bay Area and I referred them to Aegis facilities 

all over. I have had nothing but excellent comments back from them. 

I am also a resident on the east side of Santa Rosa and I drive over Fountaingrove Parkway 

everyday to my office on Fountaingrove. I'm in the O’Brian Waters Building. I can say the 

additional traffic lights on Fountaingrove have helped that street immensely. I have been 

doing this for almost 7 years and I believe the light that is slated to be going into Thomas 

Lake Harris, which is right above my office where the dentist office is from where I 

understand, will help slow that whole area down and make it that much safer. I hope that 

you will look at the EIR in those terms thank you. 

Shirley Zane 

I’m the C.E.O on the Council of Aging and I’d like to put my comments on the Draft EIR, 

especially in terms of the advantages of this site being a senior housing, but I’m really going 

to speak why this particular senior housing project is very much needed here in Sonoma 

County and other parts of our county. Elderly gay people living in nursing homes or


PUBLIC 


PUBLIC 


PUBLIC 


assisted living centers or receiving home care increasingly report that they have been 

disrespected, shunned or mistreated in ways that range from hurtful to deadly and even 

leading some to commit suicide. Some have seen their partners and friends insulted or 

isolated, and others live in fear of the day when they are dependent on strangers for their 

most personal care. That dread alone can be damaging, physically and emotionally. 

Fountaingrove Lodge presents us with a unique opportunity to provide a very 

compassionate response to the challenges of aging in the gay and lesbian community. The 

unique mission of the Fountaingrove Lodge really must not be understated. I frequently get 

mail and emails from gay and lesbian seniors that talk about the difficulties of aging as a 

minority. Many older adults in the LGBT community do not have strong ties to their 

families and some have been completely cut off from their families on account of their 

sexual orientation. The loneliness and feelings of isolation that have been expressed to me in 

letters I have received are really heart breaking. We talk a lot about diversity but here’s a 

project that quite frankly exemplifies it. The onsite affordable housing for the workers, the 

green construction, the 1.7 million dollars of fees for the city, and many new jobs in both the 

construction and the service industry are also huge added bonus stated in the EIR. As the 

chief advocate for seniors in Sonoma County I really want to say that I support this EIR 

Draft because we very much need this type of special needs housing for our aging 

population. Thank you. 

Susan Moore 

I live at 3739 Woodborn Place. Up in Fountaingrove it’s pretty obvious to me from the EIR 

that there is going to be development in that area. There is not going to be a green zone, so 

we start talking about trees and all the rest of this, it has already been planned to be 

developed. It’s going to be developed. As a resident of Fountaingrove I would far rather see 

a senior housing project then the sprawl of town houses and I have to follow up with what 

Shirley Zane just said. There was a tremendous AIDS epidemic. The people that are now 

retiring lost most of their friends; many of their families abandoned them. This is a place for 

them to go where they can reconnect with people that will love and care for them in the 

final years of their lives. To me this is extremely important. This is a community that says 

that we really value diversity, that we really value compassion. I think economically it’s a 

very good deal. They are going to develop it; we are going to get their taxes. A lot of other 

projects they are talking about developing may never come to pass in this economy. We 

need the income from this, but much more importantly, much more importantly, you need 

to think about these people that are coming here, that will be wonderful community people, 

they will serve, they will volunteer, they will be an asset to this community. Thank you. 

Annette Cooper 

I’m here because I think it is very important that we support this project. As many people 

have echoed, and I’m going to echo, this site has already been poised for development and 

we face a crisis here in Santa Rosa for housing. I deal with it every day. That’s part of what I 

do as a real estate broker; we try to figure out ways to create more affordable housing, find 

places for affordable housing and create really new models for the 21st century. One thing 

nice about the community that’s being proposed is that it creates an infill that keeps the 

residents there. The residents don’t have to be driving around, they don’t have to go back 

and forth, they can stay right where they are and have most of their needs met. I appreciate


PUBLIC 


PUBLIC 


PUBLIC 


and realize I appreciate the concerns of all the people who expressed themselves. Regarding 

the EIR, I do not know and I don’t care to argue the merits of how that EIR should be 

tweaked, because it will probably have to be. Nonetheless, it’s important to realize that that 

site is posed for development. I think its also important to realize that right now the City of 

Santa Rosa and Sonoma County is in an economic doldrum, just like most of the U.S. and I 

think that this kind of a project shows the rest of the country that we are willing to take 

creative steps to try to expand our community base and do something different and creative 

that will create basically more economic potential for our area. Thank you. 

Ann McGiverin 

I’m very much in support of the project and I haven’t studied the EIR. I have read through 

some of it and I’m quite impressed by the way they are mitigating many of the objections. I 

also want to support the idea that this community really not only welcome, but pave the 

way for such a unique project. One of the things that really impresses me is the beautiful 

architectural design and craftsman style; I think that it is going to look gorgeous up there. 

The trees are going to go one way or the other. If the trees are going to be replaced by some 

trees, it is going to take a long time for them to be as gorgeous as the ones that are leaving. 

But I would rather see a beautifully architecturally designed complex there rather than 

townhouses that are for sale. 

David Hagele 

I live at 5040 Point Place. The Point Place is a cul-de-sac that has had a front row seat to the 

development of Varenna, not from the Fountaingrove side that the majority of the people 

see, but from my deck I’ve been able to see the development and the carving up of the 

hillside, the digging and everything that has been going on there. I was presented with a 

packet when Varenna was first proposed, similar to some of the pictures that you saw here 

with the computer, enhancement the video with the cars driving, all that kind of stuff. I 

have to tell you, what you see in a picture like that is completely different then what 

actually ends up being there. I’m looking at a hillside being carved up now, which I’m sure 

will eventually look good for a mall, but not when you’re replacing something that’s natural 

and what’s already there. Again I understand this site is slated for development. It’s going 

to happen. I moved into Fountaingrove in 1996 , when I first moved into Stonesfield. I have 

been driving past this parcel for over 10 years now and I understand the development is 

going to happen. I want everybody to know that when they say it’s going to be a 3 story 

building you are more than welcome to come stand on my deck and see what a real 3 story 

building really looks like. What you’re not focusing on is it is not being counted from the 

lowest spot and the way the slope goes. It slopes down to Thomas Lake Harris. The view 

from Thomas Lake Harris you’re going to be looking at will appear like a 5 story building, 

like what I’m looking at. From the golf course, when you’re teeing off, “hey that’s a nice 3 

story building.” I just want to make sure that before this thing gets finalized it would be 

great if the whole thing could be chopped down a level. That’s just my personal opinion 

because I’m not going to see it on a day to day basis except driving by, but what I look at I 

know is not a 3 story building and it kind of bothers me a little. Thank you.


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


Commissioner Cisco 

I don’t have a whole lot. One thing I did notice here was the inconsistency of the body of the 

report stating it’s two-story vs. the executive summary which says it’s three. I think that 

needs to be cleared up for me. 

I think would prefer to see more elaboration in the tables where you do the general plan 

consistency analysis, which stands out inconsistent because of the prohibition against 

grading on 25% slopes and I think having a bit more discussion there about the relationship 

with the zoning code and how all of that works together would be much clearer about why 

you can proceed if at first it was deemed inconsistent with the General Plan. 

Lastly under public services, it did indicate a Community Facility District would be formed 

and I guess I’d like a bit more discussion about that. I know there was suppose to be one 

created for Varenna. I don't know if that has happened and would this project join that 

particular Community Facility District or would it become one of its own…just a bit more 

elaboration there. That’s all I have. 

Commissioner Caston 

A few additions: I noticed the same inconsistencies on project description and there are a 

couple of others inconsistencies I’ll forward on in writing if I don’t see them in other 

comments. 

To more substantive comments on the air quality section, the discussion on green house gas 

emission on AB32, there’s a few things to note. 1) This requirement was passed in 2006, now 

it’s 2008. It’s about time to get these levels of significance figured out and even though we 

don’t have them on a state-wide level, the capacity to do so at a local level is in existence 

and we need to use it. We already have existing inventories for the City and all 9 

jurisdictions in the County, so we know what’s there; we know what’s going to be added. 

There’s a decent analysis per residential unit how much greenhouse gases will be created. 

We know how that’s going to impact the existing inventory that the City’s created and the 

City also has goals for reductions of greenhouse gas emissions, which presents us in the 

position where we can actually establish a threshold of significance locally. 

Adding on to that, under regional local regulations on page 3-32, there’s no reference to any 

of those local incentives including our local goals for reduction and I believe that an analysis 

of how this project and any project that comes forward with an EIR will impact the 

inventory that has been taken and our ability to meet our goals under that, establish levels 

of significance consistent with the goals that have been adopted by the City of Santa Rosa 

for reductions in green house gas emissions overall. 

Additionally to working on the greenhouse gases emission section, I think it is also 

important that we take into consideration the mitigation measures that are more unique to 

the project site. Along with the analyses, things such as providing on site housing should be 

analyzed for what their benefits are as a mitigation to greenhouse gas emissions. 

Additionally in the traffic section I noticed that the provision on on-site housing employees 

was not listed as a potential mitigation or at least partial mitigation for the traffic elements 

and I think that should be analyzed and at least discussed as to the reductions that are 

created by providing housing on site.


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


PUBLIC 


And last, this is more of a social demographics issue, but we do live in a county that has per 

capita the highest amount of same sex couples living in it. We have a region within our 

county that has the highest per capita region same sex couples and on that how does that 

factor into our provision of aging facilities for that demographic group and how does that 

impact the environment of our county? So I think that is something that is reasonable to 

examine with this EIR and was brought up in public testimony. 

Commissioner Karsten 

First I’m very imprested with everything I’ve heard from all speakers and I found it very 

helpful. The a couple of things, in addition to what has already been commented on, I 

presume this is the case, but I think it would be helpful to make it very clear that the care 

center and this facility and everything is related to this care center is for the residents only. I 

presume that’s the intent here but reading it causes me some…”concerns” is not the correct 

word…but I question whether or not it really is just for the residents only and is not going 

to be turned into a broader based service provider, if you will, which in turn would 

obviously impact traffic and those types of things. 

The other thing in listening to some of the other comments made here was the issue of the 

schematics and the visual components that you have been provided here. It appeared to me 

there is a bit of an inconsistency with some of the materials that have been provided in the 

packet, especially the elevation of the project Figure 2.4 and 3.14, the scope, the size, the 

elements of architecture, all of these things seem to be what I hear a significant concern to 

from many of the people here. So if we can see if there’s consistency? If I’m wrong about 

that then I’m wrong it appears just looking at them it appears to be inconsistent and maybe 

different generations if you will of schematics, in also additional schematics and visuals, so 

that the community really does have a really good feel for what this project is going to look 

like, not just from 2 or 3 vantage points but I would say half a dozen to 10 or 12 so that 

everybody is fully well versed and informed about how this project really will look like 

when it is done. 

Commissioner Poulsen 

For the most part I think this is fine, but my concern is with the surrounding neighborhood 

and neighbors and how they will be affected. Especially towards lighting, I would like to see 

a better lighting plan provided. Noise, not only after it is built, but during construction, and 

then the other thing was looking at the tree report. It does not come out and list which ones 

are heritage oak trees. That term has been thrown about quite a bit and I would like to see 

what’s happening to "heritage oak trees." 

Chairman Bartley 

I do have a concern about the visual analysis that I think that echoes what Mr. Karsten was 

saying. What jumps at me, and maybe it’s just previous experience has made me wary, but I 

did notice some inconsistencies and I know it is provided by the applicant in terms of the 

graphics but one of the things I noted on the graphics on the 3D simulation is there are a lot 

of rather mature trees have been strategically planted in the simulation and that gives an 

accurate view 20 yrs from now, but doesn’t give an accurate view the day its finished, so I 

think there would be a benefit to see it without some of that extra embellishment.


Response to oral comments made during the Public Hearing (July 24, 2008) 

1) Comment noted. The Draft EIR analysis regarding the Project’s impacts to air 

quality, aesthetics, biology, greenhouse gases, seismicity, traffic, and land use 

compatibility indicates that the mitigation measures provided mitigate potentially 

significant levels to less than significant. See specific responses to these issues as 

follows: aesthetics (Response to Comment Epperly-2 and Epperly-3), biology 

(Response to Comment Epperly-4 through Epperly-11), seismicity (Response to 

Comment Epperly-13), and consistency with area plans (Response to Comment 

Epperly-16 through Epperly-22). No oral comments specific to traffic, greenhouse 

gases, or air quality appear to have been made by the commenter. 

2) Aesthetic impacts are evaluated in Section 3.1 of the Draft EIR and are further 

discussed in Master Response Visual Resources; with mitigation, no significant 

aesthetic impacts would occur. 


4) There will be no direct impacts to Piner Creek or its associated 0.5 acre of riparian 

vegetation (See Impact 3.4-2) and no mitigation is required. 

As required in Section 15082(a) of the CEQA Guidelines, the City mailed a copy of 

the Notice of Preparation that an EIR would be prepared for the Project, as well as a 

copy of the Draft EIR, to the CDFG. While CEQA requires notification of affected, 

responsible, and/or interested agencies, there is no legal requirement for such 

agencies to respond. No comments were received from CDFG. 



7) The proposed grading for the site was taken into account during the analysis of the 

Project’s environmental impacts. As described in the revised Mitigation 

Measure 3.6-3 of the Draft EIR, a site-specific slope stability analysis that will 

evaluate landslide potential will be incorporated into final design. Depending on the 

findings, slope stability measures may consist of regrading slopes. See Master 

Response Soils and Seismic Mitigation. 

8) Comment noted. The City disagrees and believes that the Draft EIR is consistent 

with CEQA requirements for analysis of the Project’s impacts from grading, 

retaining walls, buildings, tree removal, and topography modification, and that the 

mitigation measures provided will mitigate potentially significant levels to less than 

significant. See specific responses to these issues as follows: grading (Response to 

Comment Public Hearing-7 and Master Response Soils and Seismic Mitigation), 

retaining walls (Response to Comment Margason-4), buildings (Response to 

Comment Margason-1), tree removal (Master Response Oak Trees and Oak 

Woodland) and topography modification (Responses to Comments Public Hearing- 

7, Glenn-3, and Margason-4). 

9) See Response to Comment Epperly–23. 

ES092008001PHX\BAO\082970001 2-169


10) Onsite trees are concentrated in woodland areas, which were avoided to the degree 

feasible in Project design. For this reason, percent of land graded is not equal to 

percent of trees impacted. See also Master Response Visual Resources for additional 

detail on accuracy of simulations portraying visual impacts; with mitigation, impacts 


11) As described in Section 2.4.2, the site will be contour-graded so that the buildings 

will blend into the hillside to the degree feasible. Visual impact analysis has 

determined that the building massing creates good scalar transition (see Draft EIR 

p. 3-23). Impacts to aesthetics and views will be less than significant with the 

implementation of appropriate landscaping. Therefore, mitigation to reduce building 

mass is not required. 

12) Draft EIR Section 2.4.2, Project Design Features, discusses how the Project design 

includes limited contour grading of portions of the site so that buildings will blend 

in with the overall hillside nature of the surrounding area (p. 2-11). See Response to 

Comment FRMA-2 and Master Response Land Use Compatibility. 

13) See Response to Comment FRMA-2 and Master Response Land Use Compatibility. 

The Project will be subject to Design Review by the City for approval of building 

design and grading plans. 

14) See Master Response Land Use Compatibility and Response to Comment FRMA-9. 

15) See Response to Comment Nelson July 17-1 for explanation of trips assumed in the 

Traffic Impact Analysis and Emissions Calculation. See Response to Comment 

Epperly – 14 for discussion of intersection evaluations. 



18) Comment noted. As described in Section 2.4.3, construction is expected to last 

approximately 19 months. 

19) See Response to Community Comment-31. 


21) See Response to Community Comments–3. 

22) See Response to Comment Nelson (July 17)–1. 

23) Appendix P (Traffic Impact Report) describes the basis for trip generation of the 

Project using the traffic engineering profession’s standard source of trip rate data: 

Trip Generation, 7th Edition, by the Institute of Transportation Engineers (ITE). As 

shown in Table 8 in the Traffic Impact Report, an estimated 382 non-employee 

round-trips per day would be generated. The 382 trips shown for “Visitors” in 

Table D-1 in Appendix D are for all resident and visitor trips; the “Visitors” label in 

Table D-1 should read “Residents and Visitors.” 

As described in Section 3.13.3, the parking proposed for the Project exceeds the 

parking required by the City. 

2-170 ES092008001PHX\BAO\082970001


24) As described in the Master Response Local Traffic and Response to Comment Public 

Hearing – 23, the number of trips generated by the project were estimated using a 

standard estimation measure (based on facility type) generated by Trip Generation 

Handbook, a national publication from the ITE. The Handbook is a collection of 

information about vehicular traffic that is generated by different land uses. This 

information is based on studies made to determine how many vehicles enter and exit 

a site devoted to a particular land use, and is currently in its 7 th updated edition. The 

total trips for a specific land use in the ITE would include all associated trips. Based 

on their other community care facilities, the Applicant has estimated that, within the 

total trips generated, an average of approximately four delivery trucks per day 

would occur. 

Impact 3.3-2 evaluates long-term emissions from operation of the Project; this impact 



26) Significant impacts to wildlife species are addressed in Section 3.4 of the Draft EIR. 

Potential impacts from construction of the Project to nesting birds, roosting bats, and 

northwestern pond turtle will be mitigated to a less than significant level through 

preconstruction surveys, avoidance, monitoring during construction, and/or other 

measures (see Mitigation Measures 3.4-3, 3.4-4, and 3.4-5). As evaluated in 

Section 3.4.3, impacts to these species will be less than significant with mitigation. 

27) Mitigation Measure 3.4-3 in the Draft EIR includes pre-construction surveys, 

avoidance as feasible during breeding season, and buffer zones to minimize impacts 

to raptors and nesting birds; impacts to these species will be less than significant 

with mitigation. 


29) See Master Responses Land Use Compatibility and Visual Impacts, as well as 

Response to Comment FRMA-19. 

30) See Master Responses Visual Impacts and Noise. 

31) See Master Responses Visual Impacts and Oak Trees and Oak Woodland and 

Response to Comment Glenn-2. 

32) See Master Response Land Use Compatibility and Response to Comment 

Margason-6. 

33) Comment noted. The Draft EIR has addressed the Project’s impacts from grading, 

buildings, landscaping, and topography modification; the mitigation measures 

provided mitigate potentially significant levels to less than significant. See specific 

responses to these issues as follows: grading (Response to Comment Public 

Hearing-7 and Master Response Soils and Seismic Mitigation), landscaping (Master 

Responses Visual Resources and Oak Trees and Oak Woodland), buildings 

(Response to Comment Margason-1), and topography modification (Responses to 

Comments Public Hearing-7, Glenn-3, and Margason-4). 

ES092008001PHX\BAO\082970001 2-171


34) Comment noted. See Master Responses Land Use Compatibility and Visual 

Resources. 

35) See Response to Comment FRMA-19. 



building entrances. Conformance to the City’s Lighting Design Guidelines and the 

Principles of Low-impact Lighting Design (see Mitigation Measure 3.1-3), which 

minimize the amount of light that leaves the site, would reduce impacts to less than 

significant. See also Response to Community Comment-13. 

37) See Response to Community Comment-14. 

38) As required in Section 15082(a) of the CEQA Guidelines, the City mailed a copy of 

the Notice of Preparation that an EIR would be prepared for the Project, as well as a 

copy of the Draft EIR, to CDFG. While CEQA requires notification of affected, 

responsible, and/or interested agencies, there is no legal requirement for such 

agencies to respond. No comments were received from CDFG. 

39) See Master Response Oak Trees and Oak Woodland and Response to Comment 

Glenn-2. 

40) See Responses to Comments Epperly–23. 

41) Comment noted. See Response to Comment Barr-4. 

42) Comment noted. See Response to Community Comment-27. 

43) The Draft EIR notes the location of the Project as being in a Very High Fire Severity 

Zone (see p. 3-98) and evaluates the evacuation needs of Lodge residents (see 

p. 3-100) as well as evacuation of neighboring homes (see p. 3-165). With mitigation 

incorporated, these impacts were determined less than significant. See also Response 

to Comment FRMA-26. 










53) Comment noted. Potential impacts of the Project on views are described in 

Section 3.1 of the Draft EIR and in Master Response Visual Resources of this Final 

2-172 ES092008001PHX\BAO\082970001


EIR document. As noted in Master Response Visual Resources, the visual 

simulations were done correctly and present an accurate depiction of the Project. 

54) See Response to Comment Aegis–1. 

55) See Master Response Land Use Compatibility. As described in Appendix C, the 

Project is inconsistent with General Plan Policy UD-H-3. The City has considered the 

Applicant’s site plans as drawn since only 5 percent of the site area contains slopes 

over 25 percent, and of those only about one-third would be altered. In addition, 

none of the areas with slopes over 25 percent would be visually prominent or 

significant. Other design measures to reduce the impact include placement of 

buildings and parking facilities to maximize retention of existing tree clusters that 

best blend with the natural setting; prioritized grading; stepped building design; and 

architectural features. Final design will be subject to approval by the Design Review 

Board. 

56) See Response to Comment Aegis–19. 


58) The potential impacts of the greenhouse gas emissions from the Project are described 

in Section 3.3.3 of the Draft EIR. The City has not yet established significant 

thresholds for greenhouse gas emissions, which should be done after formal 

consideration and adoption of possible significant thresholds and not on a project 

EIR. The City has been developing programs and policies, alone and in conjunction 

with Sonoma County, to address greenhouse gas emissions and climate change. 

59) On December 18, 2007, the City adopted a Green Building Ordinance that requires 

nonresidential buildings such as the proposed community care facility to achieve a 

minimum of 20 credits in accordance with the LEED® Commercial Green Building 

Rating System. Green building is a method that reduces carbon emissions by using 

materials and construction techniques that promote natural resource conservation. 

The Green Building Ordinance adopted by the City provides a local incentive for 

Greenhouse Gas (GHG) reduction. See also Response to Comment Public Hearing – 

58 above. 

To support the City’s efforts in reducing greenhouse gas emissions, the Project 

includes several measures to reduce operational GHG emissions, including energyefficient 

lighting and appliances. GHG emissions associated with the Project were 

estimated for carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O). 

Emissions of hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur 

hexafluoride (SF6) were not separately estimated and were assumed to be minimal in 

comparison to CO2, CH4, and N2O emissions since the Project would not have the 

types of sources associated with large amounts of HFC, PFC, or SF6 fugitive 

emissions (e.g. large chillers or electrical transmission). 

CO2 emissions associated with Project construction were estimated using the 

URBEMIS2007 version 9.2.4 (URBEMIS) model. At this time, URBEMIS does not 

include CH4 or N2O emission estimates. Construction emissions were calculated for 

exhaust emissions from construction equipment and exhaust emissions from haul 

trucks in the year 2009. Project construction would be expected to result in a 

ES092008001PHX\BAO\082970001 2-173


temporary increase of 279 metric tons of CO2 per year during the 19-month 

construction period. 

For operational emissions, CO2, CH4, and N2O emissions from residential electricity 

use were estimated using the Pacific Gas and Electric (PG&E) average kilowatt hour 

(kWh) consumption per residential customer in 2005 (CEC, 2007). CO2, CH4, and 

N2O emissions from residential natural gas use were estimated using the URBEMIS 

model multifamily natural gas consumption value. The same vehicle assumptions 

used to generate the criteria pollutant operation emissions were used to estimate 

GHG emissions. The California Climate Action Registry (CCAR) General Reporting 

Protocol emission factors were used to estimate emissions from electricity use, 

natural gas use, and vehicle use (CCAR 2008). 

Operation of the Project would be expected to result in 3,140 metric tons of CO2equivalent 

emissions per year. Project CO2 equivalent emissions would account for 

less than 0.01 percent of the 2004 GHG emissions for the entire state of California. 

Therefore, the Project would be expected to be an insignificant source of global GHG 

emissions. 

TABLE 2-1. 

Summary of GHG operational emissions 

Emission Source CO2 Equivalent Emissions (metric tons per year) 

Natural Gas Use 387 

Electricity Use 387 

Transportation Fuel Use 2,366 

Note: Both electricity use and transportation fuel use are indirect sources of GHG emissions because 

these emissions result from sources outside of the control of the Project. 

The Project would not be expected to result in a substantial incremental contribution 

to global atmospheric GHG concentrations. The Project would result in minor GHG 

emissions but these emissions are not necessarily new emission sources. In many 

cases, these GHG emissions would be “redistributed” from existing developments in 

other locations, although the extent of this redistribution is uncertain. The Project is 

located in Sonoma County, which is not a substantial contributor to California 

transportation fuel consumption, natural gas consumption, and electricity use. 

Sonoma County accounts for 1.2 percent of gasoline fuel use and 1 percent of diesel 

fuel use in California (BOE, 2007). Also, Sonoma County accounts for 1.4 percent of 

the state residential electricity use and 1.6 percent of the residential natural gas use 

(CEC, 2008). Therefore, redistributing these emission sources from either within the 

County or from outside of the County, with operation of the Project, would not be 

expected to result in a significant net increase in global GHG emissions. 

Draft EIR Table 3.3-1 has been modified with information acquired since the 

publication of the Draft EIR. See Section 3.0 Errata. 

2-174 ES092008001PHX\BAO\082970001


60) Comment noted. CEQA does not require analysis of social demographics as part of 

an environmental impact assessment. As described in Section 2.1 in the Draft EIR, 

the Project supports the goals and policies established in the Santa Rosa 2020: General 

Plan that call for projects and services to support the needs of seniors in Santa Rosa. 

61) No medical services will be provided as part of the proposed Project; medical 

services are therefore unavailable for both residents and nonresidents alike (see 

Draft EIR p. 2-1). The Project is a private facility with amenities for residents only. 


63) See Response to Comment Public Hearing-36 on site lighting. 

Noise impacts during construction are addressed in Impact 3.10-3. Construction of 

the Project would temporarily but significantly increase noise levels in the vicinity of 

the Project site and along transportation corridors used by construction equipment 

and workers during the construction period (see Draft EIR p. 3-126). With 

incorporation of Mitigation Measure 3.10-3, construction noise impacts would be 

reduced to less than significant levels. As described in Impact 3.10-1, the effects of 

traffic on noise levels would be less than significant. As described in Impact 3.10-2, 

noise from operation of building equipment will be less than significant with 

mitigation. See also Master Response for Noise. 

Heritage oak trees are defined in the Draft EIR p. 3-47 and 3-48. Impacts to heritage 

oak trees are address in Impact 3.4-1; approximately 120 native heritage trees would 

be removed. See Master Response Oak Trees and Oak Woodland and Response to 

Comment Glenn-2. 

64) See Master Response Visual Impacts. 

ES092008001PHX\BAO\082970001 2-175

3.0 Errata and Revisions 

This section contains those pages of the Fountaingrove Lodge Project Draft EIR that have been 

revised based on the comments received during the public review period. Text deleted from 

the Draft EIR is shown in strike-out mode; text that has been added is shown in underline. 

These revisions supersede the Fountaingrove Lodge Project Draft EIR dated June 2008. 

The following pages and figures of the Fountaingrove Lodge Project Draft EIR are included in 

this section. 

Page iii 

Page 2-1 

Figure 2-1 

Page 2-7 

Page 2-11 

Page 3-30 

Page 3-31 

Page 3-61 

Page 3-68 

Page 3-69 

Page 3-70 

Page 3-84 

Page 3-86 

Page 3-91 

Page 3-92 

Page 3-93 

Page 3-94 

Page 3-110 

Page 3-120 

Page 3-164 

Figure 3.6-4 Local Geology Map 

BAO\082970001 3-1

Executive Summary 

Project 

The Aegis Senior Living Continuing Care Retirement Community - Fountaingrove Lodge 

Project (henceforth referred to as the Fountaingrove Lodge Project, or the Project), formerly 

known as Oaks 4 and 5, is a proposed community care facility located in the City of Santa 

Rosa (the City), in central Sonoma County, California. The Project is located within 

incorporated northeast Santa Rosa at 4110 and 4210 Thomas Lake Harris Drive. The 

9.85-acre Project site currently consists of undeveloped land. The Project would create a total 

of 136 community care units and 12 residential units to be used for employee housing. The 

Project applicant has indicated that the facility will be marketed to the gay, lesbian, bisexual, 

and transgender community. 

Project Objectives 

The objectives for the Project are to: 

• Create approximately 135 community care facility units, consistent with the land uses 

designated in the City’s General Plan and the Fountaingrove Ranch Planned 

Community District (FRPCD) Policy Statement. 

• Provide progressive care and a range of services to allow seniors to remain within the 

community. 

• Provide quality senior care licensed by the State of California. 

• Provide employee housing that is affordable to the full-time employees needed to 

operate the facility. 

• Provide housing for seniors with convenient access to medical care facilities, highways, 

and transportation, retail, and recreation amenities. 

Project Components 

The Project includes a community care facility involving four types of units for seniors; 

employee housing; and a range of amenities and services. Community care facilities are 

considered a non-residential land use that provides non-medical residential care. Specific 

components of the Project include: 

• A three-story Main Building with 74 one- and two-bedroom community care units, two 

dining rooms, resident amenities, housekeeping facilities, administrative offices, and 

above and belowground parking areas. 

• A “Flats” building containing 18 one- and two-bedroom community care units. 

Eight Six two-bedroom community care units in the form of duplexes and detached 

cottages. 

BAO\082970001 iii

2.0 Project Description 

This section describes the origin of the Project and approved land uses for the site, the Project 

objectives, the Project location, construction and operation of the Project, and required approvals. 

2.1 Background and Project Origin 

Fountaingrove Ranch is a 1,970-acre area in the North Santa Rosa Planning Area, within the City of 

Santa Rosa in Sonoma County, California. A development plan for Fountaingrove Ranch was first 

proposed in 1972, and the FRPCD Policy Statement (with its accompanying “Fountaingrove Ranch 

Amended Planned Community Map—Land Use and Circulation Plan”) were adopted in 1981 and 

subsequently amended in 1992. The Policy Statement identified, among other things, basic 

development objectives and land uses (City of Santa Rosa, 1992). 

The Project site is defined as two three lots designated in the Development Concept Plan as Cluster 

Residential land use. The intent of this land use is to create and enhance areas for a range of 

attached and detached single-family and multiple-family dwelling types; it permits apartments, 

group dwellings, and health care facilities, among other uses. With the overlain Housing Bonus 

Area in the Development Concept Plan, the allowed residential density on the Project site is 15 

dwelling units per acre (City of Santa Rosa, 1992). 

Santa Rosa City Code Chapter 21-05.040 (I)(8) defines a community care facility as “any facility, 

place or building which is maintained and operated to provide non-medical residential care, day 

care, and/or home-finding services for children, adults, or children and adults” (City of Santa 

Rosa, 2007). 

Several parts of the Santa Rosa 2020: General Plan call for projects and services to support the needs 

of seniors in Santa Rosa (City of Santa Rosa, 2002). These include: 

• Policy H-D-14: “Provide incentives for development of housing for the elderly, particularly for 

those in need of assisted and skilled nursing care. Incentives may include density bonus, 

reduced parking requirements, or deferred development fees.” 

• Goal YF-E: “Establish and continue to pursue programs, mechanisms, and liaison activities 

which will increase the provision of modern senior citizen services in the community, in 

accordance with local and State codes.” 

• Policy YF-E-1: “Continue to develop, manage, and expand the City’s senior services and 

programs as an important social service within the community.” 

• Policy YF-E-2: “Continually monitor and analyze the overall needs of the City’s senior citizen 

population, in order to investigate and implement new and additional programs and activities 

and meet the needs of this segment of the community in an aggressive and effective manner.” 

BAO\082970001 2-1

Mendocino 

£¤ 101 

0 ± 5 10 

Miles 

£¤ 101 

Lake 

£¤ 101 

Austin Creek State Rec Area 

Sonoma 

Point Reyes Natl Seashore 

Marin 

£¤ 101 

Santa Rosa 

Golden Gate National Rec Area 

^_ 

Petaluma 

Project Location 

£¤ 101 

Napa 

Vallejo 

San Rafael--Novato Antioch 

Mount Tamalpais State Park 

Napa 

£¤ 101 

San Francisco 

§¨¦ 580 

San Francisco--Oakland 

£¤ 1 

§¨¦ 280 

£¤ 101 

Glenn 

§¨¦ 980 

San Francisco Intl 

Colusa 

San Mateo 

§¨¦ 880 

§¨¦ 5 

Vacaville 

Fairfield 

§¨¦ 80 

Yolo 

Solano 

Concord 

Contra Costa 

§¨¦ 680 

FIGURE 2-1 

Alameda 

REGIONAL MAP 

Butte 

Sutter 

Li vermore 

FOUNTAINGROVE LODGE PROJECT 

SANTA ROSA, CALIFORNIA 

BAO \\ZINFANDEL\PROJ\SANTAROSACACITYOF\352095FOUNTAINGROVE\GIS\MAPFILES\PROJECT_AREA_WIDE.MXD REGIONAL_MAP.PDF 4/9/2007 15:58:18 

§¨¦ 505

2.0 PROJECT DESCRIPTION 

use is located west of the Project site across Thomas Lake Harris Drive. The Stonefield 

development tennis courts and common space form the southern border of the property. The Oaks 

Fountaingrove Association swimming pool and recreation facility is immediately to the north of 

the Project site. The closest residential area comprises duplex buildings located to the north of the 

site across Gullane Drive and is referred to as Oaks Phase I. Other residential areas in the vicinity 

consist primarily of single- and multi-family homes and condominiums. A seasonal creek, Piner 

Creek, originates in the uplands to the east and crosses the southern extent of the Project site from 

east to west. An AT&T facility that fronts on Thomas Lake Harris Drive is currently located on the 

southern tip of the parcel. 

The Project site is approximately 1,900 feet long and is roughly 40 feet wide at its narrowest at the 

southern end and 350 feet wide at the broadest point toward the north. The site is undeveloped 

and is covered by areas of dense, medium-height annual grasses, tall thickets of dense brush and 

tree stands containing mostly native oak trees. Vegetation is lightest at the northern portion of the 

property near Gullane Drive and in the central area of the site. The Project site is characterized by 

rolling terrain. Elevations on the site range from roughly 400 to 500 feet above mean sea level with 

the northern extent of the property higher than the southern. The site slopes generally upward to 

the east from Thomas Lake Harris Drive. The average slope on the site is 16.58 percent. 

2.4 Project Description 

2.4.1 Project Components 

The Project includes four types of community care facilities for seniors, employee housing, and a 

range of amenities and services. All units will be rented on a month-to-month basis. Specific 

components of the project are shown in Table 2-1. 

The Project site layout is shown in Figure 2-3. Details of the Project components and other Project 

features are as follows: 

• Main Building. The Main Building will contain 74 one- and two-bedroom community care 

units in two main wings that extend north and south from the building center. The building 

will be two and three stories over a lower-level parking structure and will have a maximum 

height of 49 feet. The Main Building will contain two dining rooms, a café, entertainment and 

activity rooms, exercise rooms, a beauty salon, housekeeping facilities, and administrative 

offices. The building footprint is approximately 61,000 square feet. 

• Flats. The Flats Building will contain 18 one- and two-bedroom community care units. The two 

and three-story building will have a maximum height of 37 feet, with two tower exceptions 

(elevator tower at 46 feet and stairway tower at 41 feet) that total 5 percent of the building 

footprint. The building footprint is approximately 18,000 square feet. 

Cottages. The Project will include eight two-bedroom community care units in the form of 

cottages, each one-story with a 25-foot height maximum. Six of the cottages will be provided in the 

form of duplexes; two will be in the form of detached units. The total building footprint of the 

cottages is approximately 15,000 square feet. 

BAO\082970001 2-7

2.0 PROJECT DESCRIPTION 

• Swimming Pool. The pool will be located on the south side of the Main Building. The approximate 

dimensions of the swimming pool are 50 feet long and 20 feet wide at the south end and 35 feet at the 

north end. A patio area will surround the pool. 

• Parking and Transportation. Ninety-nine parking spaces, including three handicapped spaces, will be 

provided with the Main Building. Eighteen underground parking spaces, including one handicapped 

space, will be provided with the Flats Building. Another 106 parking spaces, including five 

handicapped spaces, are provided throughout the site, with the majority near the Main Building. 

Fourteen garage spaces are provided with the cottages. Onsite shuttle service will be provided using 

electric golf carts. 

• Landscaping. Trees and shrubs will be planted throughout the Project site to provide visual screening 

and vertical relief to the horizontal mass of the buildings. The existing vegetation will be preserved to 

the degree feasible. 

• Site Improvements. Site improvements include the addition of sidewalk, curb, and gutter along 

Thomas Lake Harris Drive; vehicle site access from Thomas Lake Harris Drive; sewer and water 

connections; and stormwater drainage and retention facilities. 

• Offsite Improvements. Several offsite transportation and pedestrian improvements will be made. A 

three-legged signal will be added at the intersection of Fountaingrove Parkway and Thomas Lake 

Harris Drive that interconnects with the signals to the east and west of this intersection. The radius of 

the curb return at the intersection will be increased from 30 to 35 feet to facilitate better turning 

movement from westbound Fountaingrove Parkway onto northbound Thomas Lake Harris Drive. A 

raised crosswalk on Thomas Lake Harris Drive between the Flats Building and Employee Housing 

(Lot 3)at Gullane Drive will be added. Improved ADA-compliant curb cuts leading to an improved 

striped pedestrian crosswalk will be added on the easterly side of the intersection of Fountaingrove 

Parkway and Thomas Lake Harris Drive to assist pedestrians crossing Fountaingrove Parkway. 

• Loading/Staging Area and Trash/Recycling Enclosures. During facility operations, loading/ staging 

areas will be located at the southwest corner of the Care Center (approximately 585 square feet [ft 2]) 

and in the covered parking area under the west wing ofnext to the Main Building (approximately 

2,175 ft 2). Trash and recycling enclosures are provided in three major locations: at the southwest 

corner of the Care Center, in the covered parking area under the west wing ofnext to the Main 

Building and at the northwest corner of the employee housing. In addition, smaller trash/recycle 

rooms will be located within the main building, flats building, and care center. in an area of The total 

area of all trash/recycling locations is approximately 810 ft 2. 

• Onsite Amenities and Facilities. Housekeeping services, residential and grounds maintenance, 

emergency response system, and 24-hour onsite management will be included in services provided to 

residents. Programs and services such as aqua aerobics, walking, health screenings, podiatrist services, 

massage therapy, and hydro tub will be provided. Other amenities include private and formal dining 

rooms, a café, entertainment and activity rooms, beauty salon/barber shop, and reading rooms in the 

Main Building. Walking paths and small courtyards are located throughout the site. Other facilities 

include a pet park and a bocce court. Services and site management will be provided by 

approximately 85 full-time employees. 

2.4.2 Project Design Features 

The Project design includes limited contour grading of portions of the site so that buildings will 

blend in with the overall hillside nature of the surrounding area, as shown in 

BAO\082970001 2-11

3.3 AIR QUALITY 

Federal Regulations. Federal air quality policies are regulated through the federal Clean Air 

Act (CAA). Pursuant to this act, the United States Environmental Protection Agency (USEPA) 

has established National Ambient Air Quality Standards (NAAQS) for the following air 

pollutants (termed “criteria” pollutants): carbon monoxide (CO), ozone (O3), nitrogen dioxide 

(NO2), sulfur dioxide (SO2), respirable particulate matter defined as particulate matter less 

than 10 microns in aerodynamic diameter (PM10), fine particulate matter defined as 

particulate matter less than 2.5 microns in aerodynamic diameter (PM2.5), and lead. The act 

was amended in 1977 to require each state to maintain a State Implementation Plan (SIP) for 

achieving compliance with the NAAQS. In 1990, the act was amended again to strengthen 

regulation of both stationary and motor vehicle emission sources. Conformity to the SIP is 

defined under the 1990 CAA amendments as conformity with the plan’s purpose in 

eliminating or reducing the severity and number of violations of the NAAQS and in 

achieving expeditious attainment of these standards. The federal CAA also requires the 

USEPA to designate areas (counties or air basins) as attainment or nonattainment with 

respect to each criteria pollutant, depending on whether the area meets the NAAQS. An area 

that is designated nonattainment means the area is not meeting the NAAQS and is subject to 

planning requirements to attain the standard. 

State Regulations. The California Air Resources Board (ARB) oversees California air quality 

policies and is responsible for preparing and submitting the SIP to the USEPA. California 

established California Ambient Air Quality Standards (CAAQS) in 1969. These standards are 

generally more stringent and include more pollutants than the NAAQS. The California CAA 

was approved in 1988 and requires each local air district in the state to prepare an air quality 

plan to achieve compliance with the CAAQS. Similar to the USEPA, the ARB designates 

counties in California as attainment or nonattainment with respect to the CAAQS. 

The federal and state ambient air quality standards represent levels established to avoid 

specific adverse health effects associated with each pollutant. Table 3.3-1 presents the federal 

and state attainment status for each pollutant. 

TABLE 3.3-1 

Ambient Air Quality Standards 

Aegis Senior Living Continuing Care Retirement Community – Fountaingrove Lodge Project Draft EIR 

Criteria Pollutant 

Carbon Monoxide 

Nitrogen Dioxide 

Federal Standard (Averaging 

Period) a 

Federal 

Attainment 

Status 

State Standard (Averaging 

Period) b 

State 

Attainment 

Status 

35 ppm (1 hour) Attainment 20 ppm (1 hour) Attainment 

9 ppm (8 hour) Attainment 9 ppm (8 hour) Attainment 

0.053 ppm 

(annual arithmetic mean) 

Attainment 

Ozone 0.0758 ppm (8 hour) Nonattainment 

Fine Particulate Matter 

(PM2.5) 

0.030 ppm (annual arithmetic 

mean) c 

-- -- 0.18 ppm (1 hour) c Attainment 

15 μg/m 3 


Attainment 

3-30 BAO\082970001 

N/A 

0.07 ppm (8 hour) Nonattainment 

0.09 ppm (1 hour) Nonattainment 

12 μg/m 3 


35 μg/m 3 (24 hour) d Unclassified No separate Standard (24 hour) 

Nonattainment

TABLE 3.3-1 

Ambient Air Quality Standards 

Aegis Senior Living Continuing Care Retirement Community – Fountaingrove Lodge Project Draft EIR 

Criteria Pollutant 

Particulate Matter 

(PM10) 

Sulfur Dioxide 

Lead 

Federal Standard (Averaging 

Period) a 

--Revoked d 

Federal 

Attainment 

Status 

State Standard (Averaging 

Period) b 

20 μg/m 3 


3.3 AIR QUALIT 

State 

Attainment 

Status 

Nonattainment 

150 μg/m 3 (24 hour) Unclassified 50 μg/m 3 (24 hour) Nonattainment 

0.030 ppm 


Attainment -- -- 

0.14 ppm (24 hour) Attainment 0.04 ppm (24 hour) Attainment 

-- -- 0.25 ppm (1 hour) Attainment 

1.5 μg/m 3 

(calendar quarter) 

Attainment 

1.5 μg/m 3 

(30 day average) 

Attainment 

Sulfates No Federal Standards 25 μg/m 3 (24 hour) Attainment 

Hydrogen Sulfide No Federal Standards 0.03 ppm (1 hour) Unclassified 

Vinyl Chloride No Federal Standards 0.01 ppm (24 hour) 

Visibility Reducing 

Particles 

Notes: 

ppm: parts per million, by volume. 

μg/m 3 = micrograms per cubic meter. 

No Federal Standards 

Extinction coefficient of 0.23 per 

kilometer — visibility of 10 miles 

or more (0.07 TO 30 miles or 

more for Lake Tahoe) due to 

particles when relative humidity 

is less than 70 percent 

Information not 

available 

Unclassified 

a National standards, other than ozone, particulate matter, and those based on annual averages or annual arithmetic means, 

are not to be exceeded more than once a year. The ozone standard is attained when the fourth-highest 8-hour concentration 

in a year, averaged over 3 years, is equal to or less than the standard. For PM10, the 24-hour standard is attained when the 

expected number of days per calendar year with a 24-hour average concentration above 150 µg/m 3 is equal to or less than 1. 

For PM2.5, the 24-hour standard is attained when 98 percent of the daily concentrations, averaged over 3 years, are equal to 

or less than the standard. 

b California standards for ozone, carbon monoxide, sulfur dioxide (1-hour and 24-hour), nitrogen dioxide, and suspended 

particulate matter (PM10, PM2.5, and visibility-reducing particles) are values that are not to be exceeded. All others are not to 

be equaled or exceeded. 

c The nitrogen dioxide ambient air quality standard was amended on February 22, 2007 to lower the 1-hour standard to 

0.18 ppm and to establish a new annual standard of 0.03 ppm. These changes become effective after regulatory changes are 

submitted and approved by the Office of Administrative Law, expected later this year. 

d On September 21, 2006, the USEPA promulgated a new 24-hour PM2.5 standard and revoked the annual PM10 standard. To 

attain the PM2.5 standard, the 3-year average of the 98 th percentile 24-hour concentration at each population-oriented monitor 

within an area must not exceed 35 μg/m 3 . These changes became effective December 17, 2006 (USEPA, 2007). 

Source: 2006 State Area Designations effective July 2007, National Area Designations current as of September 2006 (ARB, 

2007). 

The following provides a brief summary of the pollutants for which the Bay Area has been 

designated to be in nonattainment (ozone and particulate matter). 

• Ozone. Ozone is a gas created when nitrogen oxides (NOX) and volatile organic 

compounds (VOCs) chemically react in the presence of ultraviolet sunlight. NOX and 

VOCs are referred to as ozone precursors. Major sources of ozone precursors are 

combustion processes; incomplete combustion of fuel; and the evaporation of solvents, 

fuels, and paints. Ozone is a 

BAO\082970001 3-31

3.4 BIOLOGICAL RESOURCES 

• Be present during open trench work construction activities that require special attention 

in sensitive areas 

• Prepare construction monitoring and compliance reports that analyze the effectiveness of 

the mitigation measures. 

After Mitigation: Less than significant 

Impact 3.4-6: Implementation of the Project could result in impacts to special-status plant 

species. 

Analysis: Less than significant 

A focused rare plant survey was conducted on October 5 and 14, 2005, June 16, 2006 and 

February 16 and April 9, 2007. The rare plant survey corresponded to the general blooming 

periods for observing and identifying all but seventwo of the special-status plant species with 

potential to occur at the Project site. These are the streamside daisy, which has a low potential 

of occurrence and blooms between July and September, and wooly-headed lessengia, which 

has a very low potential of occurrence and blooms in mid- to late August. Clara Hunt’s milk 

vetch, Jepson’s leptosiphon, fragrant fritillary, Colusa layia, Mount Diablo cottonweed, 

serpentinestreamside daisy, and wooly-headed lessengia. The focused rare plant surveys did 

not reveal the presence of any special-status plant species. For this reason, the potential 

impacts to special-status plant species is considered to be less than significant. 

Mitigation: No mitigation required 

Impact 3.4-7: Project implementation could result in disturbance to existing wildlife 

corridors. 


The most important existing wildlife corridor on the Project site is Piner Creek and its 

associated riparian habitat. Piner Creek flows in an east-west direction across the southern 

end of the Project site. In addition to wildlife associated with aquatic and riparian habitat, 

other wildlife species are expected to use this corridor to access the undeveloped areas to the 

east and west of the Project site, particularly Fountaingrove Lake to the east. However, the 

Project would not affect Piner Creek or its migration corridor. The buffer to be set up under 

Mitigation Measure 3.4-5b for protection of western pond turtle will also help to protect any 

other migrating wildlife. 

No defined wildlife corridor exists within the Project site in a north-south direction, primarily 

because areas to the north and south of the project site are developed residences. Any 

north-south movement of wildlife is not expected to be negatively affected by the Project 

because the Project site has no significant wildlife corridor in this direction and because of the 

site’s juxtaposition with the golf course, which provides an alternate corridor in the 

north-south direction. 

Additional traffic related to residential use after construction would have minimal effect and 

would not significantly impact wildlife movement corridors. 


BAO\082970001 3-61

3.6 GEOLOGY, SOILS, AND SEISMICITY 

• Preliminary geologic hazard evaluation for the Aegis Senior Retirement Community (Cotton, 

Shires and Associates, 2005). This study included review of existing data and examination/ 

analysis of historical aerial photos. 

• Assessment of Geologic Hazards for The Oaks, Phases 4 and 5 (Giblin, 2006a). This study 

included review of existing data, aerial photo interpretation, and geologic mapping. 

• Geotechnical Investigation for The Oaks, Phases 4 and 5 (Giblin, 2006b). This study included 

review of existing data, aerial photo interpretation, geologic mapping, and subsurface 

investigation (shallow test pits). 

• Review of Engineering Geologic Concerns for the Oaks Senior Living Project (Joyce Associates, 

2006). This study included review of existing data and aerial photos and reconnaissance of 

the site and surrounding areas. 

• Investigation of Fault Surface Rupture Hazard, Fountaingrove Lodge, Santa Rosa, California 

(Giblin, 2007). This study included additional trenching excavation and logging to resolve 

discrepancy regarding a possible faulting through the northeast portion of the Project site. 

• Peer Review – Investigation of Fault Surface Rupture Hazard – Fountaingrove Lodge 

(Kleinfelder, 2008a). This letter provided third-party peer review of the Giblin 2007 

investigation and additional trenching. 

• Response to January 7, 2008 Peer Review Letter Regarding Slope Instability and Landslide 

Comments, Investigation of Fault Surface Rupture Hazard, Fountaingrove Lodge (Giblin, 2008a). 

This letter responded to and provided more information regarding comments on slope 

instability. 

• Preliminary Evaluation of Slope Stability, Fountaingrove Lodge, Santa Rosa, California (Giblin, 

2008b). This letter provided additional information on the slope stability analysis 

performed. 

• Geotechnical Peer Review, Preliminary Evaluation of Slope Stability, Fountaingrove Lodge 

(Kleinfelder, 2008b). This letter provided third-party peer review of the additional 

information on slope instability provided by Giblin. 

Data and information included in reports of these studies were used to evaluate geologic and 

geotechnical conditions and to identify the potential hazards described in this section. 

3.6.1 Setting 

Topography and Drainage 

The Project site is located within the north-central portion of the California Coast Range 

physiographic province, which extends approximately 600 miles from the Oregon border to 

the Santa Ynez River, near Santa Barbara. The physiographic province is characterized by 

elongated ranges and narrow valleys that trend in a north to northwest direction, 

approximately parallel to the coast. Structural features, including faults and synclinal folds, 

largely control topography within the province and reflect both previous and existing tectonic 

regimes (Norris and Webb, 1990). 

3-68 BAO\082970001


The Project site is situated east of the Santa Rosa Plain, in the lower foothills of the Sonoma 

Mountains. The site lies within an area of gently to moderately rolling terrain on a narrow 

strip of undeveloped land located between Thomas Lake Harris Road on the west and a golf 

course fairway on the east. Maximum site relief is on the order of 100 feet, with ground 

surface elevations ranging from about 400 to 500 feet above mean sea level. The site 

generally slopes downward in a west-southwest direction. East of the site, the ground 

surface rises to higher elevations of the Sonoma Mountains. West of the site, a series of 

relatively steep, southwest-facing slopes descends to the Santa Rosa Plain. 

Local drainage features within the Project vicinity site include subdued drainage swales, 

closed or nearly closed drainage depressions, and abrupt changes in stream direction and 

gradients (Giblin, 2006a). A seasonal, west-flowing creek is located a few hundred feet north 

of the Project site. A second creek, Piner Creek, flows across the south end of the site. Flows 

in Piner Creek are controlled by the Fountaingrove Lake dams, located approximately 800 

feet east of the site. 

Geology 

Geologic Setting. The California Coast Range physiographic province is located along the 

complex boundary margin between two tectonic plates: the North American Plate and the 

Pacific Plate. Geologic conditions in the Project area have been and continue to be primarily 

controlled by the interaction of these two massive blocks of the earth’s crust. Under the 

current tectonic regime, the Pacific Plate moves northwestward relative to the North 

American Plate at a rate of about 4 centimeters per year (WGCEP, 2003). Although relative 

motion between the two plates is predominantly lateral (strike-slip), an increase in 

convergent motion along the plate boundary within the past few million years has resulted 

in the formation of mountain ranges and structural valleys of the Coast Ranges province. 

See Figure 3.6-1 for a regional geology map. 

At the latitude of the Project site, the San Andreas fault system comprises several major 

faults, including the San Andreas, Rodgers Creek-Healdsburg, Maacama, and 

Concord-Green Valley Faults. In addition to these, many other named and unnamed faults 

within the region accommodate relative motion between major faults and relieve 

compressional stresses that also act along the plate boundary. See Figure 3.6-2 for the 

regional fault map. 

The nearest fault to the Project is the Rodgers Creek-Healdsburg fault, the main trace of 

which has been identified within several hundred feet of the site. The slip rate on the 

Rodgers Creek fault is estimated to be approximately 9 mm/year with a recurrence interval 

for large earthquakes estimated at approximately 222 years (Giblin, 2006a; Appendix K). 

Faults can be described by one of two activity classes: active and potentially active, as 

defined by the CDMG (CDMG, 1992). Active describes Historic and Holocene faults that 

have had surface displacement within about the last 11,000 years. Potentially active 

describes faults showing evidence of surface displacement during Quaternary time (the past 

1.6 million years). A third class of faults, pre-Quaternary age faults, are classified as inactive. 

This classification is not meant to imply that inactive fault traces will not rupture, only that 

they have not been shown to have ruptured within the past 1.6 million years and that the 

probability of fault rupture is low. 

BAO\082970001 3-69


Active and potentially active faults within the Project site limits and immediate vicinity 

have been mapped and documented by a number of government agencies. The United 

States Geological Survey and CDMG have published numerous maps and reports on faults 

of various types, ages, and levels of activity. The faults nearest to the Project site are shown 

on Figure 3.6-3. 

Surficial Deposits. Soil deposits found onsite typically comprise a thin layer of brown, 

porous silt, surficial deposit overlying gravel, cobble, and occasional boulders. Over much 

of the Project site, a clayey soil was encountered beneath this gravelly deposit (Giblin, 2007). 

Slope-wash and ravine fill are classified as colluvial-type deposits, which consist of loose 

sediments at the foot of a slope brought there principally by gravity and slope wash. 

Substantial accumulations of fill were found in the drainage swales in the northern and 

south-central portions of the Project site (Giblin, 2006b). The existing fill appears to be 

related to past grading, filling, and stockpiling of materials in the drainage swales. The fill 

appears to be about 4 to 5 feet thick and consists of soft to medium-stiff sandy clay with 

cobbles and occasional boulders. Laboratory tests indicated that the soils exhibit a moderate 

expansion potential (Giblin, 2006b). 

Below the existing fill deposits, natural sandy clays and sandy silts were found. These soils 

were observed to be porous, highly organic, and compressible. They generally exhibited a 

low to moderate expansion potential. In the swale areas onsite, sandy clays of high 

expansion potential were observed below the weak porous upper soils (Giblin, 2006b). 

Bedrock. Published maps indicated that rock in the Project vicinity comprises primarily two 

geologic units: the Miocene-Pliocene age sedimentary rocks of the Petaluma Formation and 

the Pliocene age Sonoma Volcanics (Giblin, 2006a). The Petaluma Formation includes poorly 

indurated to lightly cemented sandstone, siltstone conglomerate, mudstone, and claystone 

and is reported to include some tuffaceous and diatomaceous beds locally. The Petaluma 

Formation is considered highly susceptible to landslides and slope instability. Although 

published maps indicate that the Petaluma Formation is located west and beyond the 

Project site, volcaniclastic sedimentary rocks encountered in the 2006 geologic hazards field 

investigation by Giblin Associates could be interpreted to be part of the uppermost portion 

of the Petaluma Formation, as shown in Figure 3.6-4. 

Published maps and previous geologic work performed indicate that the bedrock comprises 

various rock types predominantly within the Sonoma Volcanics unit. This unit is composed 

primarily of andesitic to basaltic lava flows and, as a result ranges, from relatively weak 

sediments to hard and strong lava flows. Scattered test pits dug by Giblin Associates 

showed lava flow rocks, agglomerate, tuffaceous, and sedimentary rocks. Bedding observed 

indicated that the rocks in the central portion of the property are folded in an anticline 

(concave downward). Beds are gently folded with dips varying from gently eastward at the 

higher elevation in the eastern property area to moderately down to the west in proximity to 

Thomas Lake Harris Drive. A northwest strike interrupts these rocks to form a crude 

layering or bedding with a moderate westerly dip of about 25 to 30 degrees. The test pits 

also indicated that rock in the swale areas are generally cemented sands and gravels and 

tuffaceous siltstone. Surficial geologic units observed in test pits and scattered outcrops in 

the Project vicinity are described below; see Figure 3.6-4 for the Giblin Associates mapping 

of geologic units. 

3-70 BAO\082970001


Special Publication 42, which states that no structure for human occupancy should be located 

within 50 feet of an active fault. 

To meet requirements of the Alquist-Priolo Special Studies Zones Act, earthquake fault zone 

boundaries have generally been established approximately 500 feet on either side of major, active 

fault traces and approximately 200 to 300 feet on either side of well-defined, minor fault traces. 

Exceptions to this general pattern of earthquake fault zone delineation periodically occur where 

faults are obscured, poorly located, locally complex, and/or not vertical. Because of these criteria 

for determining zone boundaries, an earthquake fault zone designated by CDMG for a particular 

fault may be wider than the actual fault zone occupied by traces of the fault. Conversely, due to 

specific zoning criteria, mapped fault traces not shown to be sufficiently active or well-defined 

may not be included within the designated Alquist-Priolo earthquake fault zone. Therefore, in 

some cases the actual zone of potential surface rupture may not be entirely included within the 

CDMG-designated earthquake fault zone. 

All but the extreme northeast corner of the Project site is located within the Alquist-Priolo 

earthquake fault zone designated for the Rodgers Creek-Healdsburg fault. California Geological 

Survey Special Publication 42 requires a site-specific fault study if a site is within an Alquist-Priolo 

zone. Due to its location within the earthquake fault zone, a number of site-specific fault studies 

have been performed within and adjacent to the site. Results of these studies are summarized 

below, without any new interpretations. 

• Alquist-Priolo Special Studies Map (CDMG, 1976). The 1976 Alquist-Priolo map prepared by 

CDMG depicted three northwest-trending fault traces located southwest of the Fountaingrove 

Lake north dam. The locations of these faults were largely drawn by compiling previously 

published maps with little, if any, field verification. Two fault traces are shown projecting 

through the Project site, one through the central portion and another through the southern 

portion. 

• TMI Property, Fountain Grove Ranch (Harding-Lawson Associates, 1980). Two fault traces were 

identified during the Fountain Grove Ranch Environmental Impact Report (EIR) studies that 

project through or immediately adjacent to the Project site. One northwest-trending fault trace 

passes through the northern portion of the site, and a 50-foot building setback was 

recommended surrounding this fault trace. The second fault trace, considered to be the main 

active trace of the Healdsburgh-Rodgers Creek, was estimated to exist in the southernmost end 

of the Project site with a northwest orientation. A building setback zone was provided in the 

EIR that encroaches into the Project site. The locations of these traces were estimates at the time 

and, appropriately, the EIR stated that additional investigation by trenching may modify the 

setback zones. 

• Alquist-Priolo Special Studies Zone Map (July 1, 1983). The CGS updated the earthquake fault 

maps, and the modified data show that an active fault does not pass through either the 

northern nor southern portions of the Project site. The main fault trace was relocated in the 

1983 updated maps about 150 feet further southwest and outside the Project site. 

Stonefield Development (Moore & Taber, 1983). A geotechnical investigation was performed for a 

residential development south of the Project site. The investigation 

3-84 BAO\082970001


addition of material (surcharge) to the slope, application of foundation loads, or seismic 

loading. Slope shear strength can be reduced through erosion or removal of supporting 

material at the slope toe, increased pore water pressure within the slope, and weathering/ 

decomposition of supporting soils. Zones of low shear strength within slopes are generally 

associated with the presence of certain clays, bedding, or fracture surfaces. 

Strong earthquakes often cause landslides, particularly in areas already susceptible to 

landslides due to other factors, including the presence of existing landslide deposits. 

Landslides are typically a major effect of ground shaking during earthquakes with 

magnitudes of 5 and greater, especially where earth materials are water-saturated. Failure of 

steep slopes, collapse of natural-stream banks, and reactivation of existing landslides may 

occur widely during a major earthquake. 

There are numerous landslides depicted on published geologic and slope stability maps in 

the Project vicinity. The recent trenches excavated by Giblin (2007) encountered evidence of 

landslides and slope instability of varying sizes and ages within the Project site. These 

landslides and soil instability were grouped into three categories, based mainly on the 

landslide age (Giblin, 2007): 

• An older bedrock displacement affecting much of the Project site. This displacement is 

likely to have occurred between 40,000 to 80,000 years before present, during seismic 

events. Because the displacement occurred tens of thousand of years ago and is relatively 

small, the potential for renewed movements is judged to be very low. 

• A 20- to 25-foot-thick landslide colluvial soil deposit in the swale near the north end of the 

Project site. This deposit, consisted of debris flow and pond sediment, and the underlying 

bedrock appear to be part of an ancient landslide movement. The potential for renewed 

movements is judged to be moderate. 

• Landslide deposits on the west-facing slopes adjacent to and east of Thomas Lake Harris 

Drive. These landslides are old, but they show evidence of recent movements (small open 

tension cracks). The potential for movements is judged to be high. Areas where heavy soil 

creep was suspected to be occurring were also observed during previous subsurface 

explorations, including the two drainage swales on the property. Maps and cross sectional 

drawings that show the landslide and soil instability areas are presented in Appendix L 

(Giblin, 2007). 

Dam Failure and Inundation 

The California Division of Safety of Dams has stated that it has no concerns regarding the 

seismic safety of the Fountaingrove dams using current seismic criteria (Giblin, 2006a). 

Earthquake-induced waves in lakes and bays are known as seiches. The size and behavior of 

a seiche would depend on a number of factors, including the magnitude of the earthquake, 

the water depth, and the configuration of the water body and shoreline. 

Strong seismic shaking from an earthquake on the Healdsburg-Rodgers Creek fault may 

produce a seiche in Fountaingrove Lake. If a seiche were to occur, a number of factors suggest 

that the amount of water overtopping the dams would be limited: 

3-86 BAO\082970001

Reference: Giblin Associates, Investigation of Fault Surface Rupture Hazard Report, Plate 3, November 2007. 

ES032007014BAO_Fountaingrove_GeologyMap_082708_lho 

FIGURE 3.6-4 

LOCAL GEOLOGY MAP 

FOUNTAINGROVE LODGE PROJECT 

SANTA ROSA, CALIFORNIA


Impact 3.6-2: The Project could result in exposure of people or structures to loss, injury, or 

death due to strong ground shaking from local and regional seismic sources. 

Analysis: Significant 

Based on the activities of major regional seismic sources (Table 3.6-2), it is likely that the 

Project will be exposed to at least one moderate or greater earthquake located close enough 

to produce strong ground shaking at the Project site. The greatest potential for strong 

seismic ground shaking within the Project site comes from the Healdsburg-Rodgers Creek 

Fault due to its close distance to the site. 

In the event of a maximum credible event on the Healdsburg-Rodgers Creek Fault, the 

average estimated horizontal peak ground acceleration on a rock or shallow soil site within 

the Project vicinity range from approximately 0.4 to 0.9g, estimated using the Abrahamson 

and Silva (1997) and Idriss (1994) attenuation relationships. Because seismic waves attenuate 

with distance from their source, estimated bedrock accelerations are highest for portions of 

the Project vicinity nearest to the fault zone and decrease with distance from the fault. Local 

soil conditions may amplify or dampen seismic waves as they travel from underlying 

bedrock to the ground surface. 

In addition to the Healdsburg-Rodgers Creek fault, the Maacama, Hayward, and San 

Andreas Faults also present significant potential for strong ground shaking within the 

region. Fault data for potential seismic sources significant to the Project site are presented in 

Table 3.6-2. 

Mitigation Measure 3.6-2: Incorporate site-specific seismic analysis into Project design. 

The site-specific seismic analyses will be performed to identify the active and potentially 

active seismic sources that are capable of generating significant ground shaking at the 

Project site. Analysis may include response spectra, computer simulations, and finite 

element model. These findings will be incorporated into the design of Project components 

prior to approval of the Improvement Plan. The project components will be designed in 

accordance with the applicable building codes (2007 California Building Code) and will 

satisfy the seismic performance criteria of their intended uses. Code requirements for 

structures located very near faults are more complex than the requirements for structures 

located outside this region. For structures located within the Project region, additional 

measures such as site-specific geotechnical and geological investigations and additional 

structural analysis and detailing are required. If the studies result in a significant redesign of 

the project, then recirculation of the EIR may be required. 



death due to slope instability, including landslides and slope creep. 


Slope instability, including landslides and slope creep, has the potential to undermine 

foundations, cause distortion and distress to overlying structures, and displace or destroy 

Project buildings and facilities. Creep is a common phenomenon that occurs to varying 

degrees on most hill slopes in Sonoma County. Such soil creep movements can impose 

BAO\082970001 3-91


lateral loads on foundations and contribute to differential settlement of slabs, walkways, 

roads, and other structures, and can result in tilting, lateral displacement, and/or more than 

normal cracking. 

A recent study by Giblin (2007) encountered evidence of landslides and slope instability of 

varying sizes and ages within the Project site. Additional technical analysis performed by 

Giblin concluded that conventional grading techniques could satisfactorily improve site 

stability and that the corrective measures would generally be feasible from a geotechnical 

standpoint (Giblin, 2008b). A review of the Giblin analysis by Kleinfelder concluded that the 

BAO\082970001 3-91


analysis was acceptable for a preliminary evaluation and for assessing overall geotechnical 

feasibility of landslide mitigation and project development (Kleinfelder, 2008b). 

Supplemental recommendations for site preparation, grading and foundation design criteria 

should be provided based on the results of additional site exploration and analysis of the 

conditions encountered (Giblin, 2008b). 

Mitigation Measure 3.6-3: Incorporate site-specific slope stability analysis into Project 

design. 

AdditionalThe site-specific investigations and analyses will be performed during final 

design by the Applicant. The investigations will include drilling soil borings and recovering 

soil samples within and outside the boundaries of the proposed development site. The 

investigation will also include identification and characterization of the horizontal and 

vertical (depth) extents of slope instability. The findings will be incorporated in the analyses 

that will evaluate slope stability, including landslides and soil creep, and various slope 

stability measures. Depending on the findings, slope stabilization measures may consist of 

regrading slopes, providing surface and subsurface drainages, and constructing slope 

strengthening elements such as toe buttresses and secant walls. analyses will be performed 

and the findings of the analyses The results of these studies may limit the proposed 

development design, and they will be incorporated into the design of Project components 

prior to approval of the Improvement Plan. If the studies result in a significant redesign of 

the Project, then recirculation of the EIR may be required. 



death due to liquefaction and other forms of seismic-induced ground failure, including 

seismic slope instability and ground cracking. 


Seismic-induced ground failure has the potential to distress, displace, and/or destroy 

Project buildings and facilities. Portions of the Project site that are susceptible to slope 

instability hazards may also be susceptible to slope failure as a result of strong seismic 

ground shaking. 

Mitigation Measure 3.6-4: Incorporate the results of geologic and geotechnical 

investigations and site-specific seismic analysis into Project design. 

As part of a design-level geologic and geotechnical investigations, site-specific seismic and 

geologic hazard analyses will be performed to collect data and to assess the potential for 

seismic-induced ground failure in soil and rock materials adjacent to and underlying Project 

components. The study will include assessments of seismic-induced geologic hazard 

potential at the Project site, such as liquefaction, slope failure during earthquakes, and loss 

of bearing capacity of foundation soils. If such potentially problematic soils and/or slopes 

are found, the effects of these seismic-induced geologic hazards to the performance of 

Project components will be evaluated and incorporated into the design. 

Mitigation measures may include excavation of potentially liquefiable soils during 

construction and replacement with engineered backfill, in-situ ground-treatment (such as 

compaction grouting, deep soil mixing, and jet grouting) to prevent occurrence of 

3-92 BAO\082970001


liquefaction and loss of soil bearing, construction of perimeter system to contain the 

problematic soils, and strengthening slopes using toe buttresses and secant walls. Potential 

slope failure within and outside the boundaries of the proposed development site that may 

impact Project components will be assessed. Portions of the Project site that are susceptible 

to slope instability hazards are likely to be susceptible to slope failure as a result of strong 

seismic ground shaking. 

The results of these studies may limit the proposed development design, and they will be 

incorporated into the design of Project components prior to approval of the Improvement 

Plan. If the studies result in a significant redesign of the Project, then recirculation of the EIR 

may be required. 


Impact 3.6-5: The Project may include development on soft, loose, expansive, and/or 

compressible soils that creates substantial risks to life or property. 


Soft or loose soils may affect support of structures and excavations. Shrink/swell, or 

expansive-soil, behavior is a condition in which soil reacts to changes in moisture content by 

expanding or contracting. Much of the existing fill identified within the Project site has high 

clay contents with moderate expansion potential. Expansive soils may cause differential and 

cyclical foundation movements that can cause damage and/or distress to overlying structures 

and equipment. Potential impacts from loose sands, soft clays, and other potentially 

compressible soils include excessive settlement and low foundation-bearing capacity for 

Project buildings and facilities. 

3-92 BAO\082970001


Mitigation Measure 3.6-5: Develop appropriate design features for locations where potential 

problems have been identified through design-level geotechnical investigations. 

Design-level geotechnical studies will be conducted to develop appropriate design features for 

locations where potential problems are known to exist. If potentially problematic soils are found, 

appropriate design measures may include excavation of potentially problematic such soils during 

construction and replacement with engineered backfill, ground-treatment processes, redirection of 

surface water and drainage away from foundation soils, and the use of deeper foundations. 

Covering If expansive soils are found, covering them with a moisture-conforming and protecting 

blanket of approved onsite or imported materials of low expansion potential can also reduce 

shrink/swell behavior. Implementation of these standard engineering methods would reduce 

potential impacts to a less-than-significant level. If the studies result in a significant redesign of the 

Project, then recirculation of the EIR may be required. 


Impact 3.6-6: The Project could result in exposure of construction workers or equipment to loss, 

injury, or death due to excavation instability. 


Destabilization of natural or constructed slopes could occur as a result of construction activities. 

Excavation, grading, and fill operations could alter existing slope profiles and could result in the 

excavation of slope-supporting material, steepening of the slope, or increased loading. Excavation 

operations during construction of the Project could result in unstable excavation slopes, caving, 

and displacement of the adjacent ground surface. However, as discussed below, appropriate 

design features and construction procedures would be implemented to maintain stable slopes and 

excavations during construction. 

Mitigation Measure 3.6-6: Evaluate subsurface conditions and analyze excavation and grading 

slopes for stability and incorporate recommendations into grading plans and construction 

operation activities. 

Temporary construction slopes and existing natural or constructed slopes impacted by 

construction operations will be evaluated for stability. In developing grading plans and 

construction procedures, the stability of both temporary and permanent cut, fill, and otherwise 

impacted slopes will be analyzed. Construction slopes and grading plans will be designed to limit 

the potential for slope instability, maintain adequate drainage of improved areas, and minimize 

the potential for erosion and flooding during construction. During construction, slopes affected by 

construction operations will be monitored and maintained in a stable condition. Construction 

activities likely to result in slope or excavation instability will be suspended during and 

immediately following periods of heavy precipitation when slopes are more susceptible to failure. 

Appropriate construction methods and procedures, in accordance with State and Federal health 

and safety codes, will be followed to protect the safety of workers and the public during trenching 

and excavation operations. A design-level geotechnical investigation will be performed to evaluate 

subsurface conditions, identify potential hazards, and provide information for development of 

excavation plans and procedures. If the studies result in a significant redesign of the Project, then 



BAO\082970001 3-93


3.6.4 References 

Abrahamson N., and Siva, W. 1997. Empirical response spectral attenuation relations for shallow crustal 

earthquakes. Seismological Research Letters, Vol. 68, No. 1, January. 

Blake, T.F Computer Services & Software. 2000. EQSEARCH. 

California Divisions of Mines & Geology (CDMG). 1976. Alquist-Priolo (AP) Special Studies Map. 

__________. 1992. Fault Rupture Hazard Zones in California, Alquist-Priolo Special Studies Zones Act of 

1972 with Index to Special Studies Zones Maps. California Division of Mines and Geology Special 

Publication 42, Revised 19921997. State of California, Department of Conservation. 

California Geological Survey (CGS). 2003. The Revised 2002 California Probabilistic Seismic Hazard 

Maps. Prepared by T. Cao, W.A. Bryant, B. Rowshandel, D. Branum, and C.J. Willis. 

California Geological Survey. June. 

Cotton, Shires and Associates. 2005. Preliminary Geologic Hazard Evaluation for the Aegis Senior 

Retirement Community. 

Giblin Associates. 2006a. Assessment of Geologic Hazards: The Oaks, Phases 4 and 5. March 28, revised 

October 4. 

__________. 2006b Geotechnical Investigation: The Oaks, Phases 4 and 5. March 31, revised October 4. 

__________. 2007. Investigation of Fault Surface Rupture Hazard, Fountaingrove Lodge, Santa Rosa, 

California, volumes 1 and 2. December 7. 

__________. 2008a. Response to January 7, 2008 Peer Review Letter Regarding Slope Instability and 

Landslide Comments, Investigation of Fault Surface Rupture Hazard, Fountaingrove Lodge. Letter 

to City of Santa Rosa. January 29. 

__________. 2008b. Preliminary Evaluation of Slope Stability, Fountaingrove Lodge, Santa Rosa, 

California. Letter report to Aegis Senior Living. March 26. 

Harding Lawson Associates. 1980. Geologic Evaluation in Support of an Environmental Impact Report 

for Development of the TMI Property at Fountaingrove Ranch. Prepared for Teachers 

Management Investment Corporation, May 12. 

Idriss, I.M. 1994. Procedures for selecting earthquake ground motions at rock sites. Report prepared for 

the National Institute of Standards and Technology, Gaithersburg, Maryland. 

Joyce Associates. 2006. Review of Engineering Geologic Concerns for the Oaks Senior Living Project. 

Letter to Aegis Senior Living. September 12. 

Kleinfelder. 2008a. Peer Review – Investigation of Fault Surface Rupture Hazard – Fountaingrove Lodge. 

Letter Report to City of Santa Rosa. January 7. 

3-94 BAO\082970001

3.8 HYDROLOGY AND WATER QUALITY 

Because the Project would increase impervious surfaces by more than 1 acre and result in 

development adjacent to a natural waterway, it would be required to follow the requirements 

outlined in the SUSMP. As required by the Santa Rosa Area SUSMP, the Project would include 

preparation of a Storm Water Mitigation Plan to mitigate post-construction water quality impacts. 

The new storm drain system would incorporate a hydrodynamic stormwater separator as an 

end-of-line BMP. Runoff would flow through the separator before being discharged to the City 

storm drain system. The separator would be capable of removing floatables, oils, and sediments 

from stormwater runoff. With incorporation of this and other post-construction BMPs, the Project 

would not result in a significant long-term water quality impact. 

Mitigation Measure 3.8-2: Comply with all applicable State and local regulations for stormwater 

management. 

As described above, compliance with the NPDES General Construction Permit, Santa Rosa’s 

municipal stormwater NPDES permit, the grading ordinance, the Santa Rosa Area SUSMP, and the 

Storm Water Mitigation Plan will minimize any water quality impacts. Informational signage will 

be added along Project pathways located near the creek that describe the sensitivity of the buffer 

area and establish appropriate restrictions. 


Impact 3.8-3: Implementation of the Project could affect groundwater recharge. 


As noted above, Project implementation will result in approximately 45.8 percent (4.51 acres) of the 

currently undeveloped site being converted to impervious surfaces. This could reduce the amount 

of water infiltrating into the ground and recharging groundwater. However, groundwater in the 

Project area is generally only within underlying fractured rock, and infiltration from the site does 

not contribute significantly to recharge of groundwater in this location. Effects on groundwater 

recharge from the Project would be minimal. 


Impact 3.8-4: Seiche or dam failure at Fountaingrove Lake could result in inundation at the 

Project site. 


A seiche is an earthquake-induced wave that can form within an enclosed body of water. In the 

unlikely event of dam failure or a seiche during a major earthquake, water from Fountaingrove 

Lake would flow into Piner Creek where it crosses the southern portion of the Project site and 

could potentially inundate this portion of the site. However, no buildings or facilities are proposed 

for the southern end of the site, which will be preserved as open space. For this reason, the impact 

of dam failure would not be significant. The Project will not modify or otherwise affect the 

Fountaingrove Lake dams. 


3-110 BAO\082970001

3.9 LAND USE AND PLANNING 

Pursuant to the FRPCD Policy Statement, development of up to 15 units per acre of single- and 

multi-family residential development is permissible on the Project parcels. The City’s General Plan 

designates the Project site as Low Density Residential, allowing for both single- and multi-family 

residential uses, up to 8 units per acre. General Plan Policy H-D-14 also allows for increased 

density regardless of land use designation as an incentive for senior and community care facility 

development. Although the calculated “density” of the Project is 15 units per acre and the Project 

would be consistent with the FRPCD Policy Statement, the Project is not subject to the land use 

density requirement. Community care facilities are not considered a residential land use and the 

land use density for the Project is not considered residential density. In addition, community care 

facilities are allowed in any land use designation and in any zoning district in the City through a 

Conditional Use Permit; therefore, the Project is consistent with the General Plan and the zoning 

code (City of Santa Rosa, 2002 and 2007). The Conditional Use Permit is required for community 

care facilities and for all development within the FRPCD to establish allowed uses, dimensional 

standards, landscape requirements, parking requirements, and other development standards. 

To prevent placing too many community care facilities in a given area, General Plan Policy 

LUL-E-3 requires the City to avoid the concentration of large community care facilities in any 

single residential neighborhood. In northeast Santa Rosa, existing continuing care facilities include 

Brighton Gardens, Varenna, and Vineyard Commons. The Project is interspersed with these 

facilities by other land uses and is consistent with the guidance provided in Policy LUL-E-3. 

Project consistency with other specific General Plan policies is reviewed in Appendix C. To further 

support Project compatibility with the General Plan, FRPCD policies, and with surrounding land 

uses, the Project would be subject to consideration by the Design Review Board. Design Review is 

intended to ensure that the Project incorporates superior site and architectural design. 

Additionally, because the Project site includes land with slopes of 10 percent or more, the Project is 

subject to the City’s Hillside Development Standards, and would require a Hillside Development 

Permit. The issuance of a Hillside Development Permit requires that the City’s Planning 

Commission make a finding that the Project will minimize the impacts of hillside development 

and will meet City Design Guidelines. The Project’s satisfaction of Permit conditions and 

adherence to the applicable Design Guidelines would further support the Project’s compatibility 

with surrounding residential and recreational uses. No hilltop or ridgeline development is 

proposed as part of the Project. 

Potential visual, noise, and traffic impacts from the Project are evaluated in Sections 3.1, 3.10, and 

3.13, respectively, of this Draft EIR, and would not interfere with adjacent land uses. 

In general, the Project is not expected to conflict with surrounding land uses, or to negatively affect 

the character of adjacent residential neighborhoods. The Project proposes a self-contained 

community care facility for seniors with varying medical needs and onsite employee housing to 

complement the facility. Progressive care needs of residents would be addressed by the proposed 

36-unit Care Facility by providing high- acuitysecurity assisted living and memory 

support/Alzheimer’s care. Other services, such as formal dining facilities, banking, and a fitness 

center, also would be available onsite to provide for residents’ recreational, social, and 

housekeeping needs. Additionally, transportation services would be 

3-120 BAO\082970001

3.13 TRAFFIC AND TRANSPORTATION 

Springs Road leads to Old Redwood Highway and to an interchange with U.S. 101. Only 15 

percent of Project traffic is projected to travel to or from north of the Project site on U.S. 101 and 

Old Redwood Highway combined (see Table 3.13-3). In addition, the routing using Fountaingrove 

Parkway to U.S. 101 and Old Redwood Highway is more direct than a Thomas Lake Harris 

Drive-Cross Creek Road-Mark West Springs Road routing (Crane Transportation Group, 2006). 

Therefore, only negligible levels of Project traffic would use Mark West Springs Road, and no 

measurable impact to operating conditions on Mark West Springs Road would occur. 

Mitigation Measure 3.13-1: Add a traffic signal on Thomas Lake Harris Drive. 

A three-legged signal shallwill be installed at Thomas Lake Harris (West) and Fountaingrove 

Parkway. This traffic signal would alleviate the need for a westbound right-turn deceleration lane 

and an eastbound left-turn acceleration lane on Thomas Lake Harris Drive. In addition to the 

traffic signal, there will be a need to increase the radius of the curb return on the northeast 

quadrant of the intersection to improve the flow of the westbound to northbound right turn. The 

traffic signal would be interconnected (timed) with the existing traffic signals at the intersection of 

Fountaingrove Parkway and Round Barn Boulevard, as well as the intersection of Fountaingrove 

Parkway and Altruria Drive. This would result in an improvement over the existing LOS. 

It is important to note that drivers using Thomas Lake Harris Drive also have the option of using 

the nearby Fir Ridge Drive intersection for signalized access to Fountaingrove Parkway. 


Impact 3.13-2: The Project would add traffic trips to U.S. 101, potentially resulting in a 

degradation of peak hour LOS below Sonoma County Congestion Management Authority LOS 

E. 


Based on the distribution patterns shown in Table 3.13-3, the Project would be expected to add 

traffic to U.S. 101 and its ramps, as shown in Table 3.13-6. The additional traffic is less than 0.2 

percent of the capacity of the six-lane segment of freeway in central Santa Rosa now under 

construction. This is a negligible impact and would not affect the LOS on U.S. 101. 


Impact 3.13-3: The Project could result in an increase in hazards due to a design feature (e.g., 

sharp curves or dangerous intersections) or incompatible uses. 


The posted speed limit on Thomas Lake Harris Drive near the Project site is 25 miles per hour. 

Based on criteria from the American Association of State Highways and Transportation Officials 

(Crane Transportation Group, 2006), the minimum required sight distance is 155 feet, which is 

lower than Fountaingrove Lodge’s driveway design (which ranges from 285 feet to 480 feet) on 

Thomas Lake Harris Drive. 

3-164 BAO\082970001

4.0 Mitigation Monitoring and Reporting 

Program 

This Mitigation Monitoring and Reporting Program (MMRP) has been prepared as part of 

the Environmental Impact Report (EIR). All EIR sections and impacts that have mitigation 

measures are listed in Table 4-1, along with specific implementation procedures to effect 

compliance. The MMRP describes monitoring actions, monitoring responsibilities, and 

monitoring schedules for each of the implementation procedures. 

BAO\082970001 4-1

4.0 MITIGATION MONITORING AND REPORTING PROGRAM 

TABLE 4-1 

Mitigation Monitoring and Reporting Program 

Documentation 

Additional Permit 

Enforcement 

Implementation 

Schedule 

Impacts Mitigation Measures Responsible 

Party 

3.1 Aesthetics and Visual Resources 

N/A Project Development Plan and 

Landscape Plan. 

Prior to Final 

Design Review 

City of Santa 

Rosa 

Department of 

Community 

Development 

Mitigation Measure 3.1-2: Revise and implement 

landscape plan to provide a natural-appearing 

landscape composition along the periphery of the 

site. 

Impact 3.1-2: Implementation of the Aegis Senior Living Continuing Care Retirement 

Community - Fountaingrove Lodge Project (Fountaingrove Lodge Project, or the Project) 

would degrade the existing visual character or quality of the Project site and its surroundings. 

To prevent the creation of the significant impacts related 

to the change in visual character of the views seen from 

KOP-1 and KOP-4, the Project landscape plan should be 

revised to change the plantings specified around the 

perimeter of the site. In all areas along the perimeter of 

the site the landscape plan should be revised to first 

retain as many of the existing trees as feasible. In 

addition, the plan should be revised to eliminate exotic 

tree and shrub species and areas of irrigated nonnative 

ground covers. Instead, the planting plan should specify 

plantings of valley oaks and other native trees planted in 

a naturalistic composition that will appear to be a 

continuation of nearby native tree groupings and that will 

grow tall to provide maximum screening of the Project 

facilities from the adjacent streets and nearby residential 

and recreational areas. Elimination of irrigated nonnative 

ground covers and use of suitable native plants where 

ground cover is required will help to maintain the natural 

appearance of the site’s perimeter. This mitigation 

measure should be developed in conjunction with 

Mitigation Measures 3.4-1a (Replace trees in accordance 

with City Code Chapter 17-24-Trees and 17-24.050(c)(1) 

and (3)) and 3.4-1b (Use tree preservation notes on all 

improvement, grading and building plans). 

Determination of the Project’s impacts and potential significance was determined through a 

systematic evaluation of the changes that the Project would bring about in the visual 

character and quality of the views toward the Project site from each of the Key Observation 

Points (KOP). Only evaluations from KOPs with potentially significant impacts are described 

below. 

KOP-1, View from Thomas Lake Harris Drive Looking Northeastward Toward the 

Project Site. Comparison of the existing view from KOP-1 with the simulation of this view as 

it would appear after completion of the Project indicates that, with Project development, much 

of the natural vegetation on this portion of the Project site would be removed and the focus of 

the view would be the three-story Flats Building. The sidewalk along the east side of Thomas 

Lake Harris Drive; the southern entrance onto the property; low stone retaining walls; and 

landscape grasses, shrubs, and trees would be visible in the foreground. A parking lot in front 

of the Flats Building would be screened by landscaping. The tree-covered ridgeline beyond 

the property would still be visible in the background. 

The character of this view would be substantially changed in that what is now an open view of 

the undeveloped Project site and the golf course beyond will be transformed into a view in 

which the buildings, retaining walls, and landscaping dominate the foreground zone of the 

view and block the view to the golf course. The transformation of this view from open space 

to development would be a substantial degradation of the character of this view. 

With development of the Project, the visual quality of this view will change from moderately 

high to moderate. The blockage of the view toward the open areas, tree groupings, and rock 

outcrops in the golf course will lower the vividness of the view to moderate. The presence of 

the visually dominant Project structures will intrude somewhat on the view, thereby lowering 

the view’s level of intactness to moderate. The view’s level of visual unity will remain the 

same. Although the composition of spaces now visible in the view would no longer be 

present, the complex that will dominate the view will have a consistent architectural design 

theme. Although there would be some change in the overall level of the visual quality of this 

view, this change would not be so great as to cause a substantial degradation of its visual 

quality. 

KOP-4, View from Lahinch Lane Looking South into the Project Site. Comparison of the 

existing view from KOP-1 with the simulation of this view as it would appear after completion 

of the Project (Figure 3.1-7) indicates that, with Project development, the Care Center and 

Main Building will be visible on the northern end of the Project site. The trees that are now 

visible in this area will be removed and will be replaced with buildings. However, because the 

roofline of the Main Building is lower than the tops of the trees in the background, a tree line 

will still be visible behind the building. In addition, trees planted along the northern edge of 

the site will partially screen the structures and integrate them into the view. The low Care 

Center building will create a scalar transition between the residential neighborhood and the 

Main Building, The visual character of this view will be substantially changed in that what is 

now a partially developed suburban view will become more substantially developed and the 

tree grove, an important visual element, will be removed. This transformation of this view 

would constitute a substantial adverse degradation of the character of this view. 

With development of the Project, the visual quality of this view will change from moderately 

high to moderate. The removal of the tree grove that is now a striking element of this view will 

lower the vividness of the view to moderate. Although the Project structures will be partially 

screened, they will intrude on the view to some degree, reducing its level of intactness. Given 

the massing of the buildings that creates a good scalar transition, the preservation of the view 

of the tree line in the background, and the partial screening, the view’s level of visual unity will 

not change substantially. Although there would be some change in the overall level of the 

visual quality of this view, this change would not be so great as to cause a substantial 

degradation of this view’s visual quality. 

ES092008001PHX\ BAO\082970001 4-3


TABLE 4-1 


Documentation 


Enforcement 


Schedule 


Party 

N/A Outdoor Lighting Plan. 

Prior to Final 

Design Review 




Community 

Development 

Mitigation Measure 3.1-3: Conform to the City of 

Santa Rosa’s Lighting Design Guidelines and the 

Principles of Low-impact Lighting Design. 

Impact 3.1-3: Implementation of the Project would result in new sources of light or glare. 

To minimize the potential impacts of the lighting 

associated with the Project, the Project’s outdoor lighting 

plan should be reviewed for strict conformance with the 

City of Santa Rosa’s (City) lighting design guidelines and 

the principles of low-impact lighting design. Outdoor 

lighting should be restricted to areas where it is essential 

for safety and security. The light levels specified should 

be no more than what is needed to meet safety and 

security requirements. Light fixtures that eliminate 

uplighting and that are shielded to prevent light spill 

should be used to direct lighting to only those areas 

where it is required. Automatic and/or manual switches 

should be installed to assure that lights are kept on only 

when required. 

The Project would add new sources of nighttime security lighting along driveways, in outdoor 

parking lots, and near building entrances. The presence of this lighting on a site that now 

does not contain any substantial sources of nighttime illumination has the potential to 

substantially affect nighttime views in the area. To some degree, the building massing and 

the trees retained and planted on the site will attenuate these effects, but if unshielded and 

poorly directed, the light fixtures could cause offsite light impacts. 

During the daytime, sunlight reflecting off windows and cars could produce glare, but these 

effects would be attenuated by the landscaping proposed for the site and would not 

substantially affect daytime views. 

3.3 Air Quality 

N/A Specifications. 

During 

construction 

Project Applicant 

Mitigation Measure 3.3-2: Implement Construction 

Control Measures for PM10. 

Impact 3.3-2: The Project could contribute to violation of an air quality standard. 

Construction Contract. 




Community 

Development 

These control measures are based on the BAAQMD 

CEQA Guidelines for reducing PM10 emissions during 

construction. 

The following discussion provides further explanation of the construction and operation 

emissions for the Project. 

Basic Control Measures. The following control 

measures shall be implemented at all construction sites: 

Short-term Construction Emissions (PM10). Construction and operation of the Project 

would result in emissions of PM10. During construction, PM10 emissions from construction 

activities would be mitigated using the control measures set forth in the Bay Area Air Quality 

Management District’s (BAAQMD) California Environmental Quality Act (CEQA) Guidelines 

as described in Mitigation Measure 3.3-2. 

• Water active construction areas at least twice daily. 

• Cover trucks hauling soil, sand, and other loose 

materials or require trucks to maintain at least 2 feet 

of free board. 

• Pave, apply water three times daily, or apply 

(nontoxic) soil stabilizers on unpaved access roads, 

parking areas, and staging areas at construction 

sites. 

• Sweep (with water sweepers) paved access roads, 

parking areas, and staging areas at construction 

sites daily. 

• Sweep streets daily (with water sweepers) if visible 

soil material is carried onto adjacent public streets. 

• Hydroseed or apply (nontoxic) soil stabilizers to 

inactive construction areas (previously graded areas 

inactive for 10 days or more). 

• Enclose, cover, water twice daily or apply (nontoxic) 

soil binders to exposed stockpiles (dirt, sand). 

• Limit traffic speeds on unpaved roads to 15 miles 

per hour (mph). 

• Install sandbags or other erosion control measures 

to prevent silt runoff to public roadways. 

• Replant vegetation in disturbed areas as quickly as 

possible. 

• Install wheel washers for existing trucks, or wash off 

the tires or tracks of trucks and equipment leaving 

the site. 

• Suspend excavation and grading activity when 

winds (instantaneous gusts) exceed 25 mph. 

Short-term Construction Emissions. The BAAQMD emphasizes implementation of 

effective control measures rather than detailed quantification of construction emissions 

(BAAQMD, 1999). Particulate matter (PM10) emissions during construction would result from 

activities such as soil disturbance, travel on unpaved roads, and mobile source exhaust 

emissions. During construction, PM10 emissions from construction activities would be 

mitigated using the control measures set forth in the BAAQMD CEQA Guidelines as 

described in Mitigation Measure 3.3-2. Exhaust emissions from construction equipment and 

heavy-duty diesel trucks used to construct the Project would result in short-term emissions of 

ozone precursors (nitrogen oxide [NOx] and reactive organic gas [ROG]).Construction 

equipment emissions (NOX and ROG) are included in the emissions inventory that is the 

basis for the regional air quality plans and are not expected to impede attainment or 

maintenance of the ozone standards in the Bay Area (BAAQMD, 1999). Therefore, with 

Mitigation Measure 3.3-2 to address PM10, short-term air quality impacts from construction of 

the Project would be less than significant. 

4-4 ES092008001PHX\ BAO\082970001


TABLE 4-1 


Documentation 


Enforcement 


Schedule 


Party 

3.4 Biological Resources 

N/A Tree Replacement Plan. 

Before issuance 

of a grading 

permit or 

approval of the 

Improvement 

Plan. 




Community 

Development 

Mitigation Measure 3.4-1a: Replace trees in 

accordance with City Code Chapter 17-24-Trees and 

17-24.050(c)(1) and (3). 

Impact 3.4-1: Implementation of the Project would result in the loss of protected and heritage 

valley oaks and other native trees. 




Recreation and 

Parks 

Trees impacted by the Project would be replaced in 

accordance with City Code Chapter 17-24 – Trees (City of 

Santa Rosa, 2007b), which requires replacement of two 

15-gallon trees for each 6 inches, or fraction thereof, of 

trunk diameter of a tree to be removed. This replacement 

ratio is subject to approval by the City, where the ratio 

may be modified to require a greater number of smaller 

trees or, conversely, fewer numbers of a larger size (City 

Code Chapter 17-24.050(c)(1)). Based on this 

replacement ratio, 2,107 mitigation replacement trees 

would be anticipated for replacement onsite. For existing 

trees over 4 inches in girth to be removed, two 15-gallon 

minimum-size trees shall be planted for 6 inches, or 

fraction thereof, of existing tree girth. Fruit trees to be 

removed do not require mitigation. Native trees shall be 

replaced with native tree species. Nonnative trees may be 

replaced by either native or nonnative tree species. Trees 

shall be replaced onsite where feasible, offsite when 

approved by the Department of Recreation and Parks, or 

by payment of cash in-lieu of tree replacement, as 

allowed by City Code Chapter 17-24. 

Of the 513 trees located in the Study Area, approximately 338 trees (66 percent) are 

proposed to be removed during construction of the Project, and approximately 175 

(34 percent) would be preserved. The trees to be removed include 78 valley oaks, 138 coast 

live oaks, 24 blue oaks, 75 black oaks, 11 California bays, and one madrone under protection 

by the City, including approximately 120 native heritage trees (Landesign Group, 2006), as 

defined by the City’s Municipal Code Title 17. In addition, 11 nonnative trees will be removed. 

Loss of valley oaks and other native trees is a potentially significant impact, although the 

project will be designed to minimize tree loss. However, with implementation of mitigation 

described below, potential impacts to oak trees and other native trees would be less than 

significant. 

Before the issuance of a grading permit, a tree 

replacement plan shall be submitted to and approved by 

the Santa Rosa Department of Community Development. 

The plan shall indicate the number of trees to be 

removed, the number of required replacement trees by 

native or nonnative species, and the onsite location of the 

replacement trees or payment of cash in lieu of tree 

replacement as allowed by City Code Chapter 17-24. It 

will also include success criteria for replacement tree 

survival and the triggers for replanting. 

N/A Improvement Plans. 

Grading Plans. 

Prior to issuance 


permit, approval 

of the 

Improvement 

Plan, and 

issuance of 

Building Permits. 




Community 

Development 

Mitigation Measure 3.4-1b: Use tree preservation 

notes on all improvement, grading and building 

plans. 

Building Plans. 

To protect trees that will not be removed as part of the 

Project, the following tree preservation notes shall be on 

all improvement plans, grading plans, and building plans: 

“Obtain a copy of and follow the guidelines contained in 

the General Tree Preservation Guidelines by Horticultural 

Associates. Contact Horticultural Associates at (707) 

935-3911 or Department of Community Development at 

(707) 543-3258 for a copy of the Guidelines.” All Trees to 

be preserved and trees to be removed shall be shown on 

improvement plans, grading plans, and building plans. 

N/A Project plans and specifications. 

Mitigation Measure 3.4-1c: Require application of 

Best Management Practices during construction. 

Construction drawings, which will 

accurately locate areas to be avoided 

such as tree trunks and root protection 

zones. 



permit, approval 


Improvement 

Plan, and 




Community 

Development. 



The City will require the application of Best Management 

Practices (BMPs) during construction to reduce impacts 

to valley oaks. The trees that shall be avoided and 

protected during construction include any isolated oak 

ES092008001PHX\ BAO\082970001 4-5


TABLE 4-1 


Documentation 


Enforcement 


Schedule 

Building Permits. 


Party 

MMRP signoff on the fencing off of 

sensitive trees’ root-protection zone. 

Rosa Public 

Works 

Department 

tree that has a diameter of 6 inches or greater, as 

measured 4.5 feet above the ground. 

Project plans designating construction 

staging areas and prohibition of 

parking, loading, and grading during 

construction activities within root zones 

of trees. 

Prior to 

commencement 

of any onsite or 

offsite 

construction 

activities. 

BMPs shall be included in the plans and specifications for 

the Project. These shall be reviewed in pre-construction 

meetings with City staff, the City’s contractor, and 

qualified biologists and shall, at a minimum, include the 

following provisions: 

Meeting Minutes from 

City/biologist/contractor meeting to 

review BMPs. 

MMRP sign-off on routing drainage 

swales and underground work outside 

the dripline where possible. 

MMRP sign-off on the placement of a 

4-inch layer of chipped bark mulch over 

the soil surface within the fenced 

dripline. 

MMRP sign-off on pruning to clean and 

raise canopy per International Society 

of Arboriculture pruning standards, if 

necessary. 

Root protection zone maps, 

accompanied by documentation of 

other specific measures. 

• Construction drawings shall accurately locate areas 

to be avoided such as tree trunks and root 

protection zones. 

• Before construction, the root-protection zone 

(1.5 times the canopy area) of sensitive trees shall 

be fenced using wire mesh fencing. 

• Construction staging areas shall be designated on 

plans and prohibit parking, loading, and grading 

during construction activities within root zones of 

trees. 

• A pre-construction meeting conference shall be held 

with contractors to review BMPs and require 

bonding and fines to secure the replacement of 

inadvertently damaged trees. 

• Existing grade shall be maintained within the fenced 

portion of the dripline. Drainage swales and 

underground work shall be routed outside the 

dripline where possible. 

• A 4-inch layer of chipped bark mulch shall be placed 

over the soil surface within the fenced dripline prior 

to installing temporary fencing. Suitable mulch must 

contain bark “fines.” This layer of mulch shall be 

maintained throughout construction. 

• If pruning is necessary, pruning shall be done to 

clean and raise canopy per International Society of 

Arboriculture pruning standards. 

• A tree specialist shall be consulted during design to 

accurately locate root protection zones and identify 

other specific measures that would limit potential 

indirect impacts on trees that may be encroached 

upon. 

• A drainage plan shall be designed that will avoid oak 

trees to be preserved. 

Project drainage plan. 

Construction schedule. 

California Fish and Game 

Code. 




Community 

Development 

Mitigation Measure 3.4-3: Provide protection of 

nesting raptors, migratory birds, and nesting 

non-special-status birds. 

Impact 3.4-3: The Project would result in the loss of raptor and migratory bird nesting habitat 

and could result in impacts to nesting non-special-status birds. 

Avian Species Survey Report. 

Prior to 

commencement 

of any onsite 

construction 

activities. 

Several measures would be implemented to minimize 

impacts to nesting raptors, migratory birds, and nesting 

non-special-status birds: 

Qualified 

Biologist 

• To avoid impacts to nesting avian species, Project 

activity shall be avoided to the degree feasible 

during the breeding season (generally, March 1 

through September 15). 

• If avoidance of Project activity during the nesting 

season is not feasible, pre-construction surveys for 

avian species shall be conducted by a qualified 

biologist to identify active nests within or adjacent to 

the project site. To the extent feasible, avoidance or 

mitigation guidelines from U. S. Fish and Wildlife 

Service (USFWS), California Department of Fish 

4-6 ES092008001PHX\ BAO\082970001 

The Project would result in the loss of individual trees potentially used for nesting by raptors 

and migratory birds. In addition, suitable nesting habitat for many other non-special-status 

bird species is present, and construction activities in the Project site may affect these 

species. Disturbance of nest sites could result in abandonment of eggs or young or actual 

destruction of nests. These impacts are potentially significant. However, most birds such as 

observed on the Project site have large home ranges, and existing adjacent habitat could 

provide alternative habitat during Project construction.


TABLE 4-1 


Documentation 


Enforcement 


Schedule 


Party 

and Game (CDFG), and the qualified biologist will 

provide timing, methodology, and species-specific 

protocols to be followed. 

• If no nesting raptors or migratory birds are found in 

the survey area, no further mitigation is necessary. 

• If active nests are found, impacts shall be avoided 

by establishment of appropriate buffers, determined 

through coordination with CDFG or USFWS, as 

appropriate. No Project activity shall commence 

within the buffer area until a qualified biologist 

confirms that there is no longer active nesting 

activity or other mitigation and avoidance measures 

are authorized by USFWS or CDFG. Buffers may be 

adjusted if it is determined by a qualified biologist (in 

coordination with USFWS and/or CDFG) that it 

would not be likely to adversely affect the nest. 

Monitoring of the nest by a qualified biologist may be 

required if the activity could adversely affect the site. 

• To minimize the potential for birds to nest in the 

construction area, nest searches may be conducted, 

and tree removal and other vegetation removal may 

be performed without special regulatory approval 

between September 1 and February 1. This shall be 

noted on improvement plans, grading plans, and 

building plans. 

N/A Construction schedule. 

Mitigation 3.4-4: Provide protection for roosting and 

maternity colonies for special-status bat species. 

Impact 3.4-4: Project construction activities could result in impacts to roosting and maternity 

colonies of special-status bat species. 

Pre-construction survey report, 

including habitat assessment. 

Prior to 

commencement 

of any on-site 

construction 

activities. 




Community 

Development. 

Revised construction specifications. 

Qualified 

Biologist 

To avoid impacts to bat species, tree removal should be 

performed at appropriate times of the year. If trees must 

be removed outside of this time, a pre-construction survey 

shall be conducted by a qualified biologist to identify all 

roosts. A 50-foot buffer zone shall be established around 

each snag or tree until the roosting period is over. 

Resident and migratory bat species may be located near the Project site during construction. 

These species are protected under the California Fish and Game Code. Disturbance of roost 

trees could result in significant disturbance or destruction of roosts or maternity colonies. This 

would be a potentially significant impact. However, existing adjacent habitat could provide 

alternate habitat during Project construction. Implementation of mitigation measures 

described below would further reduce this impact. 

A habitat assessment of each tree slated for removal shall 

be conducted to determine its potential for use by bats. If 

potential habitat exists in a tree, specific 

recommendations shall be made for that tree (such as 

selective removal of limbs or seasonal timing). 

Recommendations shall be incorporated into construction 

specifications. 

N/A Western pond turtle pre-construction 

survey report. 

Mitigation Measure 3.4-5a: Provide protection for 

western and northwestern pond turtle during 

construction. 

Impact 3.4-5: Project construction activities could result in impacts to western or 

northwestern pond turtle. 

MMRP signoff that construction zone 

limits, have been visibly established 

along the Project boundary near Piner 

Creek. 

Prior to 

commencement 

of any onsite 

construction 

activities. 




Community 

Development 

Qualified 

Biologist 

Design plans and specifications revised 

to establish protocol if turtles are found 

in construction zone. 

During all onand 


construction 

activities. 

Pre-construction surveys for the western pond turtle 

(including northwestern pond turtle) shall be implemented. 

Individual western pond turtles found within the Project 

site during pre-construction surveys shall be relocated by 

a qualified biologist. Construction zone limits along the 

Project boundary near Piner Creek channel banks shall 

be set up using silt fencing that is keyed into the ground 

by burying the bottom of the fence. The fencing will 

restrict access by turtles, keeping them out of the 

construction area and indicating the construction area 

boundaries to construction workers. Signage shall also be 

placed indicating that the Piner Creek channel area is 

protected and not accessible for construction equipment 

and materials. Any turtle found in the construction area 

Although habitat for western pond turtle (including northwestern pond turtle) is limited to the 

southern portion of the Study Area along Piner Creek and no direct impacts to the creek 

would occur as a result of Project construction, impacts to western pond turtle during 

construction could occur from sediments and construction debris indirectly entering Piner 

Creek should the western pond turtle be present. In addition, the western pond turtle could 

potentially migrate to the Project site during construction and be inadvertently affected. These 

impacts could be potentially significant. However, with implementation of mitigation described 

below, potential impacts would be less than significant. 

ES092008001PHX\ BAO\082970001 4-7


TABLE 4-1 


Documentation 


Enforcement 


Schedule 


Party 

during construction shall be relocated by a qualified 

biologist outside the construction zone limits. This 

mitigation requirement shall be noted on improvement 

plans, grading plans, and building plans. 

N/A Project plans to include biological 

monitor provision. 

During 

development of 

design plans. 

Mitigation Measure 3.4-5b: Perform onsite monitoring 

during construction. 

Daily logs and monthly compliance 

reports. 




Community 

Development 

During 

construction to 

the satisfaction 



Community 

Development. 

Qualified 

Biologist 

Biological monitors shall be employed to monitor and/or 

implement construction mitigation measures and to report 

on compliance with mitigation measures by contractors. 

Biological monitors shall be qualified to conduct the 

mitigation activities described herein as well as additional 

mitigation that may be required in project permits. Reports 

on noncompliance with environmental requirements may 

result in temporary halting of construction activity to 

examine the noncompliance and prevent further resource 

damage. Biological monitors shall: 

• Provide worker environmental awareness training 

for all construction personnel that identifies sensitive 

biological resources that may occur in or adjacent to 

construction areas and that addresses measures 

required to minimize Project impacts during 

construction and operation. 

• Designate a setback from the creek in the Project 

plans. This setback will be identified by orange 

construction fencing installed before construction 

activities onsite. A biological monitor will monitor the 

installation of the construction fencing. 

• Be present onsite during initial construction activities 

to identify sensitive resources. 

• Monitor mitigation construction near sensitive 

habitats and resources. 

• Prohibit ground disturbance until sensitive areas are 

cleared. 

• Be present during open trench work construction 

activities that require special attention in sensitive 

areas. 

Prepare construction monitoring and compliance reports 

that analyze the effectiveness of the mitigation measures. 

3.5 Cultural Resources 

Project plans and specifications revised 

to include provisions for archaeological 

remains discovery. 

California Public 

Resources Code 

Sections 5024.1, 7050.5, 

and 5097.94. 

During 


plans and 

specification. 

Mitigation Measure 3.5-1a: Protect historic or 

archaeological resources discovered during 

construction. 

Impact 3.5-1: Construction of the Project could cause a substantial adverse change in the 

significance of an unknown historic or archaeological resource or disturb human remains. 

Daily logs and monthly compliance 

reports. 




Community 

Development 

During 

construction. 

Archaeological 

Monitor 

If archaeological remains are uncovered during 

construction activities, work onsite shall be halted 

immediately until a qualified archaeologist can evaluate 

the finds. Project personnel shall not alter any of the 

uncovered materials or their context. If resources are 

encountered, the Project applicant, in consultation with a 

qualified archaeologist, shall prepare a resource 

inventory, declaration, and mitigation plan and shall 

submit it to the City for review and approval prior to the 

continuation of construction activities. Prehistoric 

archaeological site indicators include obsidian and chert 

flakes and chipped stone tools, grinding and mashing 

Because a high potential exists for cultural resources to occur given the site conditions, 

potential impacts could occur to unknown subsurface cultural resources during construction. 

With implementation of Mitigation Measures 3.5-1a and 3.5-1b, potential impacts to cultural 

resources would be less than significant. 

implements (e.g., slabs and handstones, mortars and 

4-8 ES092008001PHX\ BAO\082970001


TABLE 4-1 


Documentation 


Enforcement 


Schedule 


Party 

pestles), and locally darkened midden soil. Midden soil 

may contain a combination of any of the previously listed 

items, with the possible addition of bone and shell 

remains and fire-affected stones. Historic period site 

indicators generally include fragments of glass, ceramic 

and metal objects, milled and split lumber, and structure 

and feature remains such as building foundations and 

discrete trash deposits (e.g., wells, privy pits, dumps). 

N/A Finding Notification. 

During 

construction. 




Community 

Development 

Mitigation Measure 3.5-1b: Protect human remains 

discovered during construction. 

Construction 

Contractor 

If human remains are encountered during Project 

construction, excavation or disturbance of the location 

shall be halted immediately, and the county coroner will 

be contacted. If the coroner determines the remains are 

Native American, the coroner will contact the Native 

American Heritage Commission (NAHC). The NAHC will 

identify the person or persons believed to be most likely 

descended from the deceased Native American, and the 

most likely descendent shall make recommendations 

regarding the treatment of the remains. 

3.6 Geology, Soils, and Seismicity 

N/A Seismic Analysis Report. 

During the 


plans and 





Community 

Development 

Mitigation Measure 3.6-2: Incorporate site-specific 

seismic analysis into Project design. 


death due to strong ground shaking from local and regional seismic sources. 

Revised plans and specifications. 

Prior tothe 


Improvement 

Plan. 


The site-specific seismic analyses shall be performed to 

evaluate seismic ground motions, including peak ground 

acceleration, that can be expected to occur at the Project 

site. These findings will be incorporated into the design of 

Project components prior to approval of the Improvement 

Plan. The project components will be designed in 

accordance with the applicable building codes (2007 

California Building Code) and will satisfy the seismic 

performance criteria of their intended uses. Code 

requirements for structures located very near faults are 

more complex than the requirements for structures 

located outside this region. For structures located within 

the Project region, additional measures such as sitespecific 

geotechnical and geological investigations and 

additional structural analysis and detailing are required. If 

the studies result in a significant redesign of the project, 

then recirculation of the EIR may be required. 

Based on the activities of major regional seismic sources, it is likely that the Project will be 

exposed to at least one moderate or greater earthquake located close enough to produce 

strong ground shaking at the Project site. The greatest potential for strong seismic ground 

shaking within the Project site comes from the Healdsburg-Rodgers Creek Fault due to its 

close distance to the site. 


of building 

permits. 

In the event of a maximum credible event on the Healdsburg-Rodgers Creek Fault, the 

average estimated horizontal peak ground acceleration on a rock or shallow soil site within 

the Project vicinity range from approximately 0.4 to 0.9 g-force (g), estimated using the 

Abrahamson and Silva (1997) and Idriss (1994) attenuation relationships. Because seismic 

waves attenuate with distance from their source, estimated bedrock accelerations are highest 

for portions of the Project vicinity nearest to the fault zone and decrease with distance from 

the fault. Local soil conditions may amplify or dampen seismic waves as they travel from 

underlying bedrock to the ground surface. 

In addition to the Healdsburg-Rodgers Creek fault, the Maacama, Hayward, and San 

Andreas Faults also present significant potential for strong ground shaking within the region. 

Impact 3.6-3: The Project could result in exposure of people or structures to loss, injury, or Mitigation Measure 3.6-3: Incorporate site-specific City of Santa During 

N/A Slope Stability Analysis Report. 

death due to slope instability, including landslides and slope creep. 

slope stability analysis into Project design. 



Department of plans and 


Slope instability, including landslides and slope creep, has the potential to undermine 

Additional site-specific investigations and analyses will be Community specifications. 

foundations, cause distortion and distress to overlying structures, and displace or destroy performed during final design by the Applicant. The Development 

Project buildings and facilities. Creep is a common phenomenon that occurs to varying investigations will include drilling soil borings and 

Prior to the 

degrees on most hill slopes in Sonoma County. Such soil creep movements can impose recovering soil samples within and outside the boundaries Project Applicant approval of the 

lateral loads on foundations and contribute to differential settlement of slabs, walkways, of the proposed development site. The investigation will 

Improvement 

roads, and other structures, and can result in tilting, lateral displacement, and/or more than also include identification and characterization of the 

Plan. 

normal cracking. 

horizontal and vertical (depth) extents of slope instability. 

The findings will be incorporated in the analyses that will 


A recent study by Giblin encountered evidence of landslides and slope instability of varying evaluate slope stability, including landslides and soil 


sizes and ages within the Project site. Additional technical analysis performed by Giblin creep, and various slope stability measures. Depending 

permits. 

concluded that conventional grading techniques could satisfactorily improve site stability and on the findings, slope stabilization measures may consist 

that the corrective measures would generally be feasible from a geotechnical standpoint. A 

ES092008001PHX\ BAO\082970001 4-9


TABLE 4-1 


Documentation 


Enforcement 


Schedule 


Party 

of regrading slopes, providing surface and subsurface 

drainages, and constructing slope strengthening elements 

such as toe buttresses and secant walls. The results of 

these studies may limit the proposed development 

design, and they will be incorporated into the design of 

Project components prior to approval of the Improvement 

Plan. If the studies result in a significant redesign of the 


review of the Giblin analysis by Kleinfelder concluded that the analysis was acceptable for a 

preliminary evaluation and for assessing overall geotechnical feasibility of landslide mitigation 

and project development. Supplemental recommendations for site preparation, grading and 

foundation design criteria should be provided based on the results of additional site 

exploration and analysis of the conditions encountered. 

N/A Design-level Geologic and Geotechnical 

Investigation Report. 

During 


plans and 





Community 

Development 

Mitigation Measure 3.6-4: Incorporate the results of 

geologic and geotechnical investigations and 

site-specific seismic analysis into Project design. 


death due to liquefaction and other forms of seismic-induced ground failure, including seismic 

slope instability and ground cracking. 


Prior to approval 


Improvement 

Plan. 

As part of a design-level geologic and geotechnical 

investigations, site-specific seismic and geologic hazard 

analyses will be performed to collect data and to assess 

the potential for seismic-induced ground failure in soil and 

rock materials adjacent to and underlying Project 

components. The study will include assessments of 

seismic-induced geologic hazard potential at the project 

site, such as liquefaction, slope failure during 

earthquakes, and loss of bearing capacity of foundation 

soils. If such potentially problematic soils and/or slopes 

are found, the effects of these seismic-induced geologic 

hazards to the performance of Project components will be 

evaluated and incorporated into the design. 

Seismic-induced ground failure has the potential to distress, displace, and/or destroy Project 

buildings and facilities. Portions of the Project site that are susceptible to slope instability 

hazards may also be susceptible to slope failure as a result of strong seismic ground shaking. 



permits. 

Mitigation measures may include excavation of potentially 

liquefiable soils during construction and replacement with 

engineered backfill, in situ ground treatment (such as 

compaction grouting, deep soil mixing, and jet grouting) to 

prevent occurrence of liquefaction and loss of soil 

bearing, construction of perimeter system to contain the 

problematic soils, and strengthening slopes using toe 

buttresses and secant walls. Potential slope failure within 

and outside the boundaries of the proposed development 

site that may impact Project components will be 

assessed. Portions of the Project site that are susceptible 

to slope instability hazards are likely to be susceptible to 

slope failure as a result of strong seismic ground shaking. 

The results of these studies may limit the proposed 

development design, and they will be incorporated into 

the design of Project components prior to approval of the 

Improvement Plan. If the studies result in a significant 

redesign of the Project, then recirculation of the EIR may 

be required. 

Impact 3.6-5: The Project may include development on soft, loose, expansive, and/or Mitigation Measure 3.6-5: Develop appropriate design City of Santa During 

N/A Design-level Geologic and Geotechnical 

compressible soils that creates substantial risks to life or property. 

features for locations where potential problems have Rosa 



been identified through design-level geotechnical Department of plans and 

Soft or loose soils may affect support of structures and excavations. Shrink/swell, or 

investigations. 

Community specifications 


expansive-soil, behavior is a condition in which soil reacts to changes in moisture content by 

Development 

expanding or contracting. Much of the existing fill identified within the Project site has high Design-level geotechnical studies will be conducted to 

Before thePrior 

clay contents with moderate expansion potential. Expansive soils may cause differential and develop appropriate design features for locations where Project Applicant to approval of 

cyclical foundation movements that can cause damage and/or distress to overlying structures potential problems are known to exist. If potentially 

the Improvement 

and equipment. Potential impacts from loose sands, soft clays, and other potentially 

problematic soils are found, appropriate design measures 

Plan. 

compressible soils include excessive settlement and low foundation-bearing capacity for may include excavation of such soils during construction 

Project buildings and facilities. 

and replacement with engineered backfill, ground 



4-10 ES092008001PHX\ BAO\082970001


TABLE 4-1 


Documentation 


Enforcement 


Schedule 


Party 

permits. 

treatment processes, redirection of surface water and 

drainage away from foundation soils, and the use of 

deeper foundations. If expansive soils are found, covering 

them with a moisture-conforming and protecting blanket 

of approved onsite or imported materials of low expansion 

potential can reduce shrink/swell behavior. 

Implementation of these standard engineering methods 

would reduce potential impacts to a less-than-significant 

level. If the studies result in a significant redesign of the 


N/A Slope Stability Analysis Report. 

Impact 3.6-6: The Project could result in exposure of construction workers or equipment to 

loss, injury, or death due to excavation instability. 

Design-level Geologic and Geotechnical 


During 


plans and 





Community 

Development 

Mitigation Measure 3.6-6: Evaluate subsurface 

conditions and analyze excavation and grading 

slopes for stability and incorporate recommendations 

into grading plans and construction operation 

activities. 

Revised grading plans and 



Regular construction monitoring logs, 

monthly summary report. 

Prior to the 


Improvement 

Plan. 

Construction Site 

Monitor 

Temporary construction slopes and existing natural or 

constructed slopes impacted by construction operations 

will be evaluated for stability. In developing grading plans 

and construction procedures, the stability of both 

temporary and permanent cut, fill, and otherwise 

impacted slopes will be analyzed. Construction slopes 

and grading plans will be designed to limit the potential for 

slope instability, maintain adequate drainage of improved 

areas, and minimize the potential for erosion and flooding 

during construction. During construction, slopes affected 

by construction operations will be monitored and 

maintained in a stable condition. Construction activities 

likely to result in slope or excavation instability will be 

suspended during and immediately following periods of 

heavy precipitation when slopes are more susceptible to 

failure. 

Destabilization of natural or constructed slopes could occur as a result of construction 

activities. Excavation, grading, and fill operations could alter existing slope profiles and could 

result in the excavation of slope-supporting material, steepening of the slope, or increased 

loading. Excavation operations during construction of the Project could result in unstable 

excavation slopes, caving, and displacement of the adjacent ground surface. However, as 

discussed below, appropriate design features and construction procedures would be 

implemented to maintain stable slopes and excavations during construction. 

During 

Construction. 

Appropriate construction methods and procedures, in 

accordance with state and federal health and safety 

codes, will be followed to protect the safety of workers 

and the public during trenching and excavation 

operations. A design-level geotechnical investigation will 

be performed to evaluate subsurface conditions, identify 

potential hazards, and provide information for 

development of excavation plans and procedures. If the 

studies result in a significant redesign of the Project, then 


3.7 Hazards and Hazardous Materials 

Site Health and Safety Plan. 

California Occupational 

Safety and Health 

Administration, California 


Transportation, and the 

Sonoma County 

Hazardous Materials and 

Waste Management Plan 

requirements. 

Before 


plans and 





Community 

Development 

Mitigation Measure 3.7-1: Comply with all applicable 

State and local regulations for hazardous materials 

and waste management. 

Impact 3.7-1: Construction and operation of the Project would require the use and transport 

of some hazardous materials. 

Project 

Applicant 

Hazardous materials impacts from construction and 

operation of the site would not be significant with 

regulatory compliance. 

The construction of the facility would require the transport, temporary storage, and use of 

asphalt, fuels, paints, and solvents, which could potentially be released and result in 

exposure to these chemicals. Operation of the facility could also involve the use of household 

and janitorial cleaning products, pesticides, herbicides, and solvents. 

The use and handling of materials associated with the construction and operation of the 

proposed Fountaingrove Lodge facility would follow all applicable federal, state, and local 

regulations, including California Occupational Safety and Health Administration, California 

Department of Transportation, and the Sonoma County Hazardous Materials and Waste 

Management Plan requirements. Waste would be disposed through the municipal waste 

water or solid waste services. 

ES092008001PHX\ BAO\082970001 4-11


TABLE 4-1 


Documentation 


Enforcement 


Schedule 


Party 

Site Health and Safety Plan. 

Community Care 

Licensing Division 

requirements and 

Sonoma County Waste 

Management Agency 

policies. 

Before 


plans and 





Community 

Development. 


state and local regulations, including Community 

Care state licensing requirements, for handling of 

medical wastes and other hazardous materials. 

Impact 3.7-2: Operation of the Project would require the storage, use, and transport of 

hazardous or biomedical materials. 

During 

construction. 

Project 

Applicant. 

Compliance with these regulations would reduce impacts 

to a less than significant level. 

Postconstruction. 

The purpose of the Project’s Care Center is to provide services specifically for patients with 

Alzheimer’s disease or other types of dementia. The Care Center operates as a residential 

care/assisted living facility and is not licensed to provide skilled nursing services, such as 

giving injections, maintaining catheters, or doing colostomy care for residents. Residents 

needing medical attention would be treated at the nearby hospital or, if they require skilled 

nursing care, would be transferred to an appropriate facility. 

State of 

California 

(Community 

Care Licensing). 

The operation of the care facility would not require the storage, use, and transport of 

biomedical materials. The Proposed Care Center would not be generating medical waste as 

defined by the California Medical Waste Act including, for example, used needles or blood or 

tissue samples. The facility would meet all licensing and permitting requirements set forth by 

the Community Care Licensing Division of the California Department of Social Services 

(State Licensing). 

Expired or leftover pharmaceuticals would be disposed of in an appropriate fashion according 

to Sonoma County Waste Management Agency policies. There would be no liquid oxygen 

used onsite; however, nonliquid oxygen may be used if prescribed by a physician for a 

respiratory condition. Nonliquid oxygen would be used in such cases under the preapproval 

of state licensing with notification to the local fire authority. Emergency generators would not 

be used onsite. Safety equipment would be on battery backup per Uniform Building Codes, 

which is accepted by state licensing. Minimum quantities of customary pool, laundry, 

housekeeping, and kitchen maintenance cleaning supplies would be stored in locked 

cabinets or rooms onsite. Fencing, required signage, and secured storage for cleaning 

materials would be provided. Vehicle maintenance would not be performed onsite. 

Vegetation Management Plan. 


of grading permit. 

Impact 3.7-3: The Project would expose people or structures to a significant risk of loss, 

injury, or death involving wildland fires. 

Project plans and specifications. 

Wildland-Urban Interface 

Fire Area in accordance 

with Public Resources 

Code, Section 4201 

through 4204, and 

Government Code, 

Sections 51175 through 

51189 


Rosa Fire 

Department 


State and local regulations, including Santa Rosa Fire 

Department requirements, for fire safety. 

Prior to approval 


Improvement 

Plan. 

The Project applicant will submit a Vegetation 

Management Plan to the Santa Rosa Fire Department for 

approval before obtaining a grading permit. The plan will 

specifically address proposed buffer zones and fire breaks 

within the property and shall comply with Uniform Fire 

Code and state requirements for vegetation management. 

In addition, all units shall have approved fire sprinkler 

systems. 

The City has building code and fire code regulations relating to construction and fire 

protective measures in areas identified as Very High Fire Severity Zone, which applies to the 

Project site, which is in the Montecity Heights Very High Fire Severity Zone. In addition, 

Chapter 7A of the California Building Code includes requirements for those areas considered 

to be within the Wildland-Urban Interface Fire Area in accordance with Public Resources 

Code, Section 4201 through 4204, and Government Code, Sections 51175 through 51189. 

Much of the area is developed with urban uses and adjacent structures are constructed using 

fire resistant materials. To further minimize fire risk, proposed structures onsite would be 

designed in accordance with applicable laws and regulations. For example, site buildings 

would be equipped with fire suppression sprinklers in accordance with state licensing 

requirements. Building design would be required to include smoke barriers and 2-hour 

separation walls and doors. The Project site would include buffers and firebreaks. 

N/A Pool plans and specifications. 

Before issuance 


permit. 

County of 

Sonoma 

Environmental 

Health Division. 

Mitigation Measure 3.7-5: Submit plans and 

specifications to the Environmental Health Division 

for review and approval. 

Impact 3.7-5: Operation of the Project could subject its residents to hazards inherent in 

facility design. 

Review by the Environmental Health Division will promote 

incorporation of appropriate safety provisions in the 

Project. 

Before the issuance of any building permits and the start of any construction, plans and 

specifications for any proposed swimming pool or spa would be submitted to the 

Environmental Health Division of the Health Services Department for approval. Review of the 

permit application by this agency would include safety provisions—if not already included in 

the design—for the pool or spa, restrooms, showers, equipment rooms, cleaning supply 

rooms, and fences. 

3.8 Hydrology and Water Quality 

SWPPP. 

NPDES General 

Construction Permit 

(SWRCB Order 

Prior to and 

during all onand 






State and local regulations for stormwater 

management. 

Impact 3.8-2: Construction and operation of the Project could increase pollutants in 

stormwater runoff, potentially violating water quality standards. 

Sampling and Analysis Program Plan. 

4-12 ES092008001PHX\ BAO\082970001


TABLE 4-1 


Documentation 


Enforcement 


Schedule 


Party 

Storm Water Mitigation Plan. 

99-08-DWQ). 

construction 

activities. 

Community 

Development 

Written Certification of BMP installation. 

Santa Rosa Santa Rosa 

Area Standard Urban 

Stormwater Mitigation 

Plan (SUSMP). 

Construction 

Contractor 

As described above, compliance with the NPDES General 

Construction Permit, Santa Rosa’s municipal stormwater 

NPDES permit, the grading ordinance, the Santa Rosa 

Area SUSMP, and the Storm Water Mitigation Plan will 

minimize any water quality impacts. Informational signage 

will be added along Project pathways located near the 

creek that describe the sensitivity of the buffer area and 

establish appropriate restrictions. 

During grading and construction activities, there would be the potential for surface water 

runoff to carry sediment and other pollutants into the stormwater system and Piner Creek, 

thereby potentially degrading water quality. As noted above, Piner Creek is a tributary to 

Santa Rosa Creek, which is listed as a 303(d) impaired waterway for sediments. Construction 

activities are required to comply with the National Pollutant Discharge Elimination System 

(NPDES) General Construction Permit, which requires preparation of a Stormwater Pollution 

Prevention Plan (SWPPP) outlining BMPs to be used during construction. The SWPPP would 

include BMPs for erosion control, sediment control, tracking control, wind erosion, and 

nonstormwater discharges. 

In addition, the Project would result in disturbance of more than 1 acre of soil; therefore, the 

Project will require coverage under the Statewide General Construction Permit. The General 

Construction Permit requires permittees to implement specific sampling and analytical 

procedures to determine whether implemented BMPs are preventing sediment-impaired 

waters from further impairment by direct discharge of sediments in stormwater. As such, the 

Project would be required to implement a sampling and analysis program to monitor 

stormwater discharges during construction. With incorporation of the General Construction 

Permit requirements, the Project would not result in a significant short-term water quality 

impact. 

After construction is complete and the Project is in operation, stormwater could transport 

contaminants—such as accumulated particulate matter, residuals from automobile use, and 

organic matter from access roadways, landscaped areas, and other exposed surfaces—into 

the storm drain system. 

Because the Project would increase impervious surfaces by more than 1 acre and result in 

development adjacent to a natural waterway, it would be required to follow the requirements 

outlined in the SUSMP. As required by the SUSMP, the Project would include preparation of 

a Storm Water Mitigation Plan to mitigate post-construction water quality impacts. The new 

storm drain system would incorporate a hydrodynamic stormwater separator as an 

end-of-line BMP. Runoff would flow through the separator before being discharged to the City 

storm drain system. The separator would be capable of removing floatables, oils, and 

sediments from stormwater runoff. With incorporation of this and other post-construction 

BMPs, the Project would not result in a significant long-term water quality impact. 

3.10 Noise 

N/A Noise Analysis. 

Mitigation Measure 3.10-2: Implement noise reducing 

measures for mechanical equipment. 

Impact 3.10-2: Operation of building equipment could result in noise impacts on adjacent 

properties. 

Revised project plans and 

specifications, if applicable. 

After 


draft plans and 





Community 

Development 

Prior to 


building permits. 

Qualified 

Acoustical 

Consultant 

Construction 

Contractor 

Once specific pieces of equipment and their locations are 

chosen, a detailed noise analysis shall be conducted by a 

qualified acoustical consultant to assess the need for 

noise reduction measures. If the study shows that, after 

implementation of the Project, noise levels as measured 

at the property line would exceed either the ambient noise 

levels by 5 decibels A scale (dBA) or applicable noise 

criteria, some or all of the following noise insulation 

features will be incorporated into the Project design, as 

necessary and appropriate: 

The Project would place the Community Care Center building south of Gullane Drive opposite 

the existing residences on the north side of the roadway; the Main Building would be directly 

south of the Care Center. These uses are expected to generate noise caused by parking lot 

use, maintenance activities, and the operation of building mechanical equipment. Based on 

the site plan, the service yard will be located opposite the Care Center from the existing 

residences. This is likely the location for service-related items such as trash enclosures and 

may be where the major mechanical equipment for the building is located. However, no 

mechanical equipment plans or equipment specifications have been developed for the 

Project, so mechanical equipment may be located on the Care Center rooftop. The location of 

equipment on the rooftop, while unlikely to increase noise levels above the existing Ldn in the 

neighborhood north of the Project site, could be noticeable to the adjacent neighborhood, 

depending on the placement and type of equipment used. Thus, without mitigation, the 

operation and use of the Project may result in a significant noise impact on the adjacent 

neighbors. 

• Specify all rooftop mechanical equipment with the 

manufacturer’s ‘low noise’ option, if available. 

• Locate rooftop mechanical equipment in the center 

or southern portion of the roof to maximize the 

distance from the equipment to the residences to the 

north of the Project site. 

• Incorporate a parapet wall around the periphery of 

the building rooftop, with a height equal to or greater 

than the height of the piece of rooftop equipment. To 

ensure this parapet wall acts as a noise barrier, it 

should be built without cracks or gaps in the face or 

ES092008001PHX\ BAO\082970001 4-13


TABLE 4-1 


Documentation 


Enforcement 


Schedule 


Party 

larger or continuous gaps at the base and have a 

minimum surface weight of 3.0 pounds per square 

foot (lb/ft 2 ). 

• Screw-type compressors should not be specified at 

the Project, due to the tonal nature of the noise 

emitted. However, if screw-type compressors cannot 

be avoided, the following measures may be 

necessary to attenuate tonal noise emissions: 

− Wrap all compressors with 1–inch-thick fiberglass 

or closed cell foam insulation. The wrap needs to 

completely enclose the compressors and all 

refrigerant piping. 

− Wrap this insulation with a noise barrier jacket, 

preferably metal (mass-loaded vinyl is also 

acoustically acceptable but may not weather well). 

This barrier jacket material should be selected for 

a nominal face weight of 0.5-1 lb/ft 2 . The noise 

barrier jacket should have a minimal size and 

number of openings. 

− Make the noise barrier jacket serviceable with 

provisions in the jacket fabrication for access to 

the service valves (suction and discharge) and 

other normal access ports. The jacket should also 

be made so that it may be removed and replaced 

without destruction of the insulation. 

− Insert silencers (pulse diffusers) in the compressor 

discharges to attenuate compressor discharge 

noise. 

Install a bank of acoustical louvers at the air intakes with 

an insertion loss of greater than or equal to 12 decibels at 

500 hertz to control intake noise. 

Impact 3.10-3: The Project could result in an increase in noise from construction activities. Mitigation Measure 3.10-3: Implement BMPs during City of Santa During 

N/A Written Certification of BMP installation. 

construction. 



Construction of the Project would increase noise levels in the vicinity of the Project site and 

Department of plans and 

Project Plans and specification to adopt 

along transportation corridors used by construction equipment and workers during the 

• Construction Scheduling. The following measures 

Community specifications. 

noise-reducing BMPs. 

construction period. Equipment generating noise during construction includes jackhammers, will be implemented to limit construction related 

Development 

backhoes, trucks, and grading and paving equipment. The Noise Study in Appendix O of this activities to the portion of the day when the number 

Draft Environmental Impact Report (EIR) provides information on typical noise levels at 

of persons in the adjacent residential uses is lowest: Construction 

construction sites. Noise produced by construction activities would be audible and exceed 

− Limit construction hours between 7:00 AM and Contractor 

existing noise levels in the vicinity of the Project site during the construction period, 

7:00 PM, Monday through Saturday 

designated Noise 

constituting a significant but temporary noise impact. 

− Do not allow machinery to be cleaned past Disturbance 

6:00 PM or serviced past 6:45 PM Monday Coordinator 

through Friday 

− Limit the allowable hours for delivery trucks to 

8:30 AM—5:00 PM, Monday through Friday 

• Construction Equipment Mufflers and Maintenance. 

Properly muffle and maintain equipment powered by 

internal combustion engines. 

• Idling Prohibitions. Prohibit unnecessary idling of 

internal combustion engines. Equipment should be 

turned off when not in use. 

• Equipment Location and Shielding. Locate stationary 

noise-generating construction equipment such as air 

compressors as far as practical from nearby 

residences and other noise-sensitive land areas. If 

equipment cannot be located away from residences, 

temporary noise barriers, such as mass-loaded 

construction blankets, should be installed around the 

equipment during its use. 

4-14 ES092008001PHX\ BAO\082970001


TABLE 4-1 


Documentation 


Enforcement 


Schedule 


Party 

• Quiet Equipment Selection. Select quiet construction 

equipment, particularly air compressors, when 

possible. 

• Noise Disturbance Coordinator. Designate a ‘noise 

disturbance coordinator’ who would be responsible 

for responding to local complaints about construction 

noise. This person would most likely be the 

contractor or contractor’s representative. He or she 

would determine the cause of the noise complaint 

and would require that reasonable measures 

warranted to correct the problem be implemented. 

3.11 Public Services 

N/A Community Facilities District record of 

establishment. 

During 


plans and 





Community 

Development. 

Mitigation Measure 3.11-2a: Participate in a 

Community Facilities District and comply with all City 

Fire Department Regulations and Policies. 

Impact 3.11-2: The Project would increase demand for fire and emergency services. 

Written approval of project plans and 


Prior to 


building permits 

and/or issuance 

of certificate of 

occupancy to 


of the Fire 

Chief. 



Department 

The Project shall participate in a Community Facilities 

District to provide the ongoing resources needed to serve 

the development and address cumulative development 

impacts to response times. To reduce the potential for fire 

service response to an emergency at the Project, all units 

shall have approved fire sprinkler systems. The 

installation of fire sprinkler protection throughout the 

Project would provide for immediate fire and life safety 

protection and assist in mitigating for the lengthening 

response times for fire and emergency apparatus and 

personnel. 

The Project would place further demands on fire and emergency services, particularly for 

medical emergencies. The Fire Department and Sonoma Life Support provide first responder 

and first responder paramedic services. Sonoma Life Support would transfer injured persons 

to the nearest hospital, either Santa Rosa Memorial Hospital or Kaiser Permanente Medical 

Center. Many elderly people have limited mobility, making it necessary to have additional fire 

resources on scene more quickly for rescue and rapid fire suppression. In addition, there is 

an increased need for emergency response to medical emergencies. Paramedic staffed 

engine companies provide a higher level of care for people with cardiac problems, trauma, 

and strokes. 

N/A Project plans and specifications. 

Written proof of onsite EMT 

employment. 

Prior to 


certificate of 

occupancy to 


of the Fire 

Chief. 



Department. 

Mitigation Measure 3.11-2b: Provide onsite 

Emergency Medical Technician qualified or equivalent 

personnel 24 hours per day, to the satisfaction of the 

Fire Chief. 

Fountaingrove Lodge will provide Emergency Medical 

Technician qualified or equivalent personnel 24 hours per 

day in the main “assisted living” building and Care Center. 

This would reduce the Fire Department’s need to respond 

to non-medical emergency calls in community care 

facilities, thereby allowing them to respond more quickly 

to other emergencies in the area. Care Center staff would 

have the ability to call 9-1-1 and medically assess 

residents to determine if the request is a medical 

emergency or a routine care assistance issue. 

3.13 Transportation and Traffic 

Impact 3.13-1: Project traffic would increase delays at the Fountaingrove Parkway 

Mitigation Measure 3.13-1: Add a traffic signal on City of Santa Installation prior N/A Plans for three-legged signal at Thomas 

intersections with Thomas Lake Harris Drive East and West. 

Thomas Lake Harris Drive. 

Rosa Public to certificate of 

Lake Harris and Fountaingrove 

At the intersection of Fountaingrove Parkway and Thomas Lake Harris Drive West, traffic is 

A three-legged signal will be installed at Thomas Lake 

Works 

occupancy. 

Parkway (West). 

projected to increase by 1.2 percent during the AM peak hour and by 1.7 percent during the 

Harris and Fountaingrove Parkway (West). This traffic 

Department. 

Installation of signal.. 

PM peak hour, adding further congestion to already existing LOS F conditions. Vehicle 

signal would alleviate the need for a westbound right-turn 


queues within the left turn lanes on all approaches to the Thomas Lake Harris Drive east and 

deceleration lane and an eastbound left-turn acceleration 

Rosa Community Provide 

west intersections with Fountaingrove Parkway are all less than available storage distances 

lane on Thomas Lake Harris Drive. In addition to the 

Development acceptable 

(i.e., turning traffic queue backs up onto the road and precludes through traffic from passing, 

traffic signal, there will be a need to increase the radius of 

Department. design prior to 

contributing to additional intersection congestion). The Project would add an additional 

the curb return on the northeast quadrant of the 


average delay for left turns to Fountaingrove Parkway by 20 seconds during the AM peak 

intersection to improve the flow of the westbound to 

Improvement 

hour and 29 seconds during the PM peak hour. These additions in traffic are substantial in 

northbound right turn. The traffic signal would be 

Plan. 

relation to the existing traffic load. Since there is a substantial increase in traffic volumes, 

interconnected (timed) with the existing traffic signals at 

ES092008001PHX\ BAO\082970001 4-15


TABLE 4-1 


Documentation 


Enforcement 


Schedule 


Party 

the intersection of Fountaingrove Parkway and Round 

Barn Boulevard, as well as the intersection of 

Fountaingrove Parkway and Altruria Drive. 

significant delay impacts to traffic on Fountaingrove Parkway and Thomas Lake Harris Drive 

would occur with the construction of the Project. 

At the intersection of Fountaingrove Parkway and Thomas Lake Harris Drive East, delays are 

increased by approximately one second per vehicle (40 vehicles in the AM peak hour and 30 

vehicles in the PM peak hour) where no additional traffic will be added. The current (base 

case, No Project Alternative) stop sign-controlled left turn from Thomas Lake Harris Drive 

(east) onto Fountaingrove Parkway operates at LOS F conditions during both peak hours. 

The Project would not be expected to add any traffic to the Thomas Lake Harris Drive 

intersection approach, and the added Project traffic on Fountaingrove Parkway would 

increase delay for stop sign-controlled left turns from Thomas Lake Harris Drive by less than 

five seconds. Although these left turns would have a base case LOS F operation, Project 

impact is considered less than significant. 

4-16 ES092008001PHX\ BAO\082970001

5.0 References 

California Board of Equalization (BOE). 2007. Annual California Transportation Fuel Use 

Consumption 2007-2008. 

California Energy Commission. 2007. California’s Residential Electricity Consumption, Prices, 

and Bills, 1908-2005. September 2007. Web site accessed October 20, 2008, 

http://www.energy.ca.gov/2007publications/CEC-200-2007-018/CEC-200-2007-018.PDF 

City of Santa Rosa. 1992. Policy Statement—Fountaingrove Ranch Planned Community District, 

Santa Rosa, California. Amended per Ordinance No. 2955, May 26, 1992. Originally adopted per 

Ordinance No. 2196, September 1981. 

City of Santa Rosa. 2002a. Santa Rosa 2020: General Plan. Department of Community 

Development. Prepared by EIP Associates. June 18. 

City of Santa Rosa. 2002b. Santa Rosa 2020: General Plan Final Environmental Impact Report. City of 

Santa Rosa Department of Community Development. Prepared by EIP Associates. June. 

Landesign, 2008. Landesign Group. Fountaingrove Lodge Tree Replacement Mitigation 

Summary, Revised July 15. 

ES092008001PHX\ BAO\082970001 5-1

Fountaingrove Environmental Impact Report - City of Santa Rosa ...

Create successful ePaper yourself

Delete template?

Save as template?