Permit Sonoma Response

A resident of Donald Street, using reasonable diligence, would have had difficulty finding out that their neighborhood was part of a large rezoning planning process. Permit Sonoma wholly or partially disagrees with this finding. Permit Sonoma’s community outreach and engagement efforts for the Springs Specific Plan process have significantly exceeded what is legally required. Maps of the proposed Springs Specific Plan boundary were distributed at four community meetings in 2016 and 2017; at a meeting of the Sonoma Valley Citizens Advisory Committee in August 2018; at Community Advisory Team meetings in 2016, 2017, and 2018; at the EIR scoping meeting on July 10, 2018; and on the project website. Maps were also posted at the Springs Specific Plan information table at the Springs Festival on September 10, 2016, and at the Cinco de Mayo celebration on May 6, 2016.

The boundaries of the SSP area, intended by MTC and ABAG to be within a street or two of a rural transportation corridor – Highway 12 in this case ̶̶does not logically encompass a neighborhood as far removed as the Donald Street area. Permit Sonoma wholly or partially disagrees with this finding. There is no evidence to indicate that the Metropolitan Transportation Commission (MTC) and the Association of Bay Area Governments (ABAG) intended the Springs Specific Plan boundary to be located entirely within a street or two of Highway 12. In fact, all County applications related to the Springs planning area—for designations as a Rural Community Investment Area and as a Priority Development Area, and for grant funds for costs associated with development of a Specific Plan for the Springs area—have included maps clearly showing the inclusion of the Donald Street area in the Springs planning boundary. One of those maps showing the inclusion of Donald Street was incorporated into the staff report for ABAG Executive Board Resolution No. 11-12, which adopted and designated Rural Community Investment Areas and Employment Investment Areas, including the Springs planning area, into the Sustainable Communities Strategy for the Bay Area.

Planners should have recognized that the Donald Street neighborhood was not represented in any of the public meetings. The groups tasked to work on the SSP, such as the Community Advisory Team (CAT), Municipal Advisory Committee (MAC), the Sonoma Alliance, and others also failed in this regard. Permit Sonoma partially disagrees with this finding. While Permit Sonoma concurs that its staff should have recognized an apparent lack of participation by Donald Street residents early in the planning process, Permit Sonoma does not agree that this lack of recognition amounts to a failure. As outlined in Attachment A (Community Outreach for the Springs Specific Plan), Permit Sonoma did extensive public outreach, using a variety of community outreach and engagement tools, to maximize public participation and feedback in the early stages of plan development. Moreover, planning staff were aware that there would be broader public notice provided to residents of the proposed Springs Specific Plan area at key points later in the process, when the draft EIR and hearing draft of the Specific Plan are published and public hearings begin. Permit Sonoma further disagrees that “groups tasked to work on the SSP, such as the Community Advisory Team (CAT), Municipal Advisory Committee (MAC), the Sonoma Alliance, and others also failed in this regard.” The CAT was formed to provide input on development of the Specific Plan and to assist with public outreach, but it was not tasked with monitoring the success of outreach efforts. The MAC was not created by the Board of Supervisors until December 2018. Finally, we assume that the reference to “Sonoma Alliance” in this finding is to the Sonoma County Alliance, a business group which is mentioned in the full report. The Sonoma County Alliance had no role in the Springs Specific Plan process other than as a potentially interested community organization. If the intent was to refer to the Springs Community Alliance, while it and its members have been actively involved in the planning process and Permit Sonoma staff made presentations to Springs Community Alliance meetings in 2016 and 2018, the group was engaged as an interested community organization and has no responsibility for the process or outcome of the plan.

Because the Donald Street residents reasonably assumed they were not part of “The Springs,” and notifications did not mention Donald Street’s involvement in the SSP, their distress and surprise upon learning of the rezoning of parcels in the neighborhood is understandable. Permit Sonoma disagrees with this finding. As stated at the outset of this response to the Grand Jury report, it appears that there is some confusion regarding the status of the Springs Specific Plan. Finding F4 refers to the reaction of Donald Street residents to learning of the rezoning of parcels in their neighborhood. It is important for those residents to understand that those parcels are at this time merely proposed for redesignation and rezoning. Only the Board of Supervisors has authority to approve rezoning, after public review of a draft EIR and Specific Plan, after public hearing before the Planning Commission, and after a public hearing before the Board. None of those preliminary events has occurred; the draft EIR has not been published, and no public hearings are firmly scheduled. Under the current timeline, the first Planning Commission hearing is projected for February 4, 2021, and the earliest date the Springs Specific Plan will be scheduled for public hearing before the Board is July 2021. Permit Sonoma respectfully does not agree that it was reasonable for Donald Street residents to assume that they were not part of the Springs Specific Plan area simply because they did not consider themselves to be part of “The Springs.” As discussed above, Permit Sonoma conducted extensive public outreach. Maps of the proposed Springs Specific Plan area were distributed at workshops and community meetings, including a meeting of the Sonoma Valley Citizens Advisory Commission (a joint advisory body not limited in scope to The Springs area, with representatives from both the City of Sonoma and the unincorporated area in Sonoma Valley), whenever Permit Sonoma staff presented on the Specific Plan process. The Specific Plan area map was posted on Permit Sonoma’s website. Permit Sonoma also engaged in extensive media outreach that led to coverage of the Specific Plan process by local media.

Citizens’ trust in their government was tested at many points in the handling of the SSP, leaving the Donald Street residents feeling marginalized and unheard by their County government. Permit Sonoma partially disagrees with this finding. To date, Permit Sonoma has far exceeded the minimum legal requirements for public notice during the Springs Specific Plan process. There are is still substantial opportunity for Donald Street residents to engage in the planning process going forward. While Permit Sonoma is not in a position to know the feelings of Donald Street residents about the Springs Specific Plan process, we regret that residents of Donald Street did not feel included in our early planning efforts, and as discussed in responses to recommendations below are incorporating lessons learned into procedures for future planning efforts.

The Donald Street residents were caught off guard in the requested meeting on March 6, 2019; they felt they were misled by a County official as to its purpose. Permit Sonoma partially disagrees with this finding. While Permit Sonoma is not in a position to know how Donald Street residents felt about the March 6, 2019 meeting, we do not agree that any County official misled the residents about the purpose of the meeting. To the extent that Permit Sonoma staff initially hoped to mediate an understanding between Donald Street residents and affordable housing advocates, staff were doing the important work of building community consensus. Although it was too late by March 2019 for Permit Sonoma to consider modifying the proposed Specific Plan boundary, it was an ideal time to begin participating in the public process. Permit Sonoma staff have met with Donald Street residents frequently and more than any other group involved the SSP process. According to department records, in 2019 alone Permit Sonoma staff met with Donald Street residents on February 26, March 6, March 27, June 18, and July 26. Donald Street residents were also given time on the Planning Commission’s published meeting agenda in December 2019 to present their arguments to the Commission and staff.

By not proactively engaging with the Donald Street neighborhood, the County did not live up to its best practices as explicitly set out in MTC Resolution No. 4035. Permit Sonoma disagrees with this finding. As discussed above, Permit Sonoma has engaged in robust public outreach throughout the Specific Plan process, and will continue to do so. As outlined in Attachment A, Permit Sonoma engaged in robust public outreach throughout the process. Responses to Recommendations