A number of serious environmental effects have been identified. To mention only a few of the most significant, the project will require the disturbance of a half million cubic yards of soil and rock, much of it asbestos-laden serpentine.
Nearly a hundred acres of oak woodlands will be destroyed, with no mitigation beyond the planting of saplings that cannot even begin to resemble the lost habitat for generations.
Since appropriate preliminary surveys have not yet been conducted for either biological or cultural resources, the potential loss of rare plants and hitherto undiscovered archaeological sites is impossible to estimate.
The intense darkness of the night skies and equally intense silence of this rural neighborhood will be lost forever. Increased traffic will burden adjacent streets, and add to the load in downtown Lakeport and elsewhere in a manner that has not been analyzed. 600 acre-feet of Clear Lake water – nearly a quarter of the entire Community Service Area 21 allocation – will be used to irrigate a golf course.
Possible sedimentation impacts on Scotts Creek and Lyons Creek, and by extension on Clear Lake itself, have not yet been fully investigated.
Worst of all, the growth pattern for the whole north Lakeport region will be distorted: rather than expanding in the orderly manner prescribed by sound planning principles and defined by a community growth boundary, development will leapfrog out into open countryside adjacent to ongoing agricultural operations. Cristallago is a poster child for sprawl, and the antithesis of modern smart growth principles.
Nor does the analysis provided by the environmental impact report (EIR) offer the Board of Supervisors a sound basis for reaching a decision. Many of its defects stem from an inherent structural confusion between a “project” and a “programmatic” EIR, which has resulted in analysis of many highly significant impacts being deferred under the pretext of being programmatic, with others evaluated on a project level, while the distinction between the two is never made clear.
Several specific inadequacies are particularly glaring:
Water supply. Neither possible conflicts with the obligation to supply water to the Geysers nor effects of using Clear Lake water for golf course irrigation are evaluated.
Traffic. Both cumulative impact analysis and proposed impact fees are inadequate.
Air Quality. The EIR unreasonably finds cumulative contributions to greenhouse gases to be insignificant, contrary to State of California standards, and it disregards comments from the Air Quality Management District warning that cumulative impacts from this project could result in the loss of attainment status for the air basin as a whole, meaning among other consequences a requirement for annual smog inspections.
Cultural and biological resources. Both preliminary investigations and proposed mitigations are inadequate.
Alternatives analysis. Essential information about land use conflicts is not provided, even though these impacts have been identified as significant and unavoidable.
General Plan inconsistencies. The EIR unreasonably fails to admit many policy inconsistencies that were identified by planning staff and members of the public.
Some of these environmental impacts are still subject to debate – and if the Board of Supervisors does not reject the project outright it should allow that debate to continue by decertifying the EIR, substantively addressing the many questions that have been raised, and recirculating it for public review – but unquestionably “significant and unavoidable” impacts have been identified to scenic views, to woodland habitat, and to surrounding land uses. A finding of “overriding considerations” will thus be a necessary pre-condition to project approval, and such a finding cannot reasonably be supported.
It has been repeatedly asserted that Cristallago would provide an economic engine not only for the Lakeport area but also for the whole of Lake County. This assertion, dubious even during the unprecedented housing bubble that prevailed at the time of the original application, has become absurd.
Nationwide, golf clubs are closing and the resorts and residential developments tied to them falling into bankruptcy – even before recent scandals involving Tiger Woods that are predicted to result in a 50 percent decline in the audience for televised golf.
The economic evaluation of Cristallago’s resort component was based on the assumption that dedicated marina facilities would be provided to resort guests and home owners, but now the lakeshore property intended for those amenities has gone into foreclosure.
The overwhelming majority of jobs created by the project would be in the service sector, with low pay and few if any benefits, and their number will be greatly reduced if the resort component fails to meet the improbably rosy projections that have been offered.
The shaky financial condition of the developers raises the specter of a project that has been begun but which cannot be completed. This scenario has been repeated far too often in Lake County already, with a previous example on this very project site. We cannot afford another paper subdivision, especially not on this massive scale.
Leaving the worst for last, Cristallago conflicts grossly with the Lake County General Plan. The most obvious defect – residential densities forbidden outside Community Growth Boundaries – is only one among dozens of acknowledged inconsistencies. For a list, see the Sierra Club comment letter posted on line at http://www.lakelive.info/cristallago/pdffiles/SCBOS1.20.10.pdf .
State Planning and Zoning law explicitly forbids approval of a project which conflicts with general plan policies or which renders the general plan internally inconsistent. No exception can be made to this requirement, nor do any “overriding considerations” apply.
Amending the general plan for the sake of the project is not an option. This is commonly done with designations on particular parcels, but these conflicts stem from fundamental policies that are the very backbone of the document.
It is inconceivable that for any reasons the Board of Supervisors would choose to dismantle an excellent general plan that was recently adopted after years of effort and the expenditure of millions of dollars, and certainly not in order to facilitate a tenuous project that offers so little in the way of tangible benefits to the community.
In short, approval of this application would eviscerate our general plan, set devastating precedents for the rest of Lake County, distort growth patterns in the Lakeport region, and create environmental havoc, all without a viable expectation of realizing the compensatory benefits that have been promised.
Please call or write your supervisors and urge them to reject this application.
Victoria Brandon is chair of the Sierra Club Lake Group.
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