Connecting the Dots ~ Fred Allebach

Fred Allebach Fred Allebach is a member of the City of Sonoma’s Community Services and Environmental Commission, and an Advisory Committee member of the Sonoma Valley Groundwater Sustainability Agency. Fred is maintenance chair of the Sonoma Overlook Trail Stewards and an active member of the Sonoma Valley Housing Group and Transition Sonoma Valley. As well, Fred has a KSVY radio show on Sunday nights at 8:PM, participates in the Sonoma Valley Action Coalition for immigration issues, and with the Sonoma Climate Coalition.


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To Planning Commission: don’t ignore hotel’s greenhouse gas impact

Posted on April 10, 2017 by Fred Allebach

In this comment, I will request an alternative analysis, and/or peer review, of the Project transportation greenhouse gas (GHG) section of the EIR by the Union of Concerned Scientists, or a similar agency. This request is made asking that the following items be covered, with due diligence done to ensure substantial evidence has been gathered, to:

-Ensure that up-to-date, 2017 climate information has been considered.

-Ensure a true cost accounting of Project transportation GHG emissions, through the undertaking of a Project cross-border, consumption-based transportation GHG inventory.

-That Project-derived air travel has been properly defined and accounted for.

-That Project-based, employee and hotel guest automobile transportation GHG emissions have been properly accounted for and quantified.

-That true cost accounting of mass transit and bicycle mitigations will be quantified in light of Project employee’s and hotel guest’s actual transportation GHG emissions,

-That Project client’s wealth has been properly accounted for in a consumption-based, per capita Project GHG inventory.

And, I will assert that lead agency’s reasoning as to consistency with the county Climate Action is deficient, and that the Project is inconsistent with the recent city council’s passing of the RCPA’s 22 local climate protection actions, specifically Measure 4-L1 mixed use development in city centers and along transit corridors.

And finally, it would be prudent for the GHG section of the EIR, for the city and Planning Commission, to take into account the Climate Action 2020 EIR lawsuit by California River Watch, that is based on many of the same questions brought forth above, as far as lack of true cost accounting of regional and county transportation GHG impacts.

Alternative Analysis and/or Peer Review of Project Transportation GHG Emissions

I suggest an alternative analysis and/or peer review by the Union of Concerned Scientists (UCS), or another environmental consulting agency of similar repute, specifically of the transportation greenhouse gas (GHG) emissions section of EIR. This will be to examine if there is substantial evidence to the contrary regarding the adequacy of 2011 Bay Area Air Quality Management District (BAAQMD) GHG transportation thresholds. The BAAQMD 2011 thresholds are the ones used by the lead agency (the city).

What level of climate protections do the BAAQMD bright-line thresholds shoot for in terms of climate change and level of global warming increase? 1.5 Celsius, 2.0C, 3.0C? Given the current state of climate science, the public needs to know the BAAQMD targets and what chance they actually have for reversing catastrophic warming.

Union of Concerned Scientists,

West Coast Office
500 12th Street, Suite 340
Oakland, CA 94607-4087
Phone: (510) 843-1872
Fax: (510) 843-3785

The UCS has reviewed aspects of the state Sustainable Groundwater Management Act, in particular, rules concerning the creation of Groundwater Sustainability Plans; and the UCS has produced a Blueprint for a Clean Energy Economy.

To have an actual alternative analysis, it will be important to engage an agency capable of challenging business-as-usual EIR assumptions. If the current EIR represents the city’s and the developer’s interests, an alternative analysis will represent the public and environmental interests, and make the process fair.

One thing is certain, the public does not have the chops to stand on equal ground to the EIR consultant, and because the public cannot martial arguments of a certain type, their points are dismissed as invalid and insignificant. Only through the representation of an alternative analysis for Project transportation GHG impacts, can points be formulated on equal ground to that of the EIR consultant, and thus, the public’s voice be heard


True Cost Accounting and Consumption-Based GHG Inventory is Necessary

Additionally, the BAAQMD, in association with UC Berkeley Cool Climate Network (1) has worked on a Bay Area consumption-based GHG emissions inventory that come in @ 35% higher than activity-based inventories. This consumption-based inventory sees large inequalities for household GHG footprint, and these are tied to wealth, vehicle ownership, and for recreational travel, i.e. tourism. Actual, true cost accounting of Project transportation GHG emissions (i.e. tourist-based GHG emissions) are likely to be higher than cited in the EIR, and a UCS or similar alternative analysis/ peer review of Project transportation GHG emissions would possibly show the GHG emissions to be significant and therefore in need of further review and mitigation.

The CRW EIR lawsuit against the Climate Action 2020 transportation GHG forecast impacts, is proceeding along exact these same lines.

The BAAQMD bright-line threshold used for the EIR, from 2011, one, may no longer be accurate, and two, may simply be a sophisticated systemic regulatory means to shoehorn in more business as usual growth and development. An alternative analysis that looks at Project transportation GHG from a sustainability/carrying capacity frame, would, in my estimation, be likely to conclude that the @ 825 MTCO2e produced by the project on an annual basis, is significant because it is 825 more than would have existed without the project. Because the bright line threshold is @ 1,100 MTCO2e, that means 825 has only a “nominal” (FEIR answer to question BO4-07) impact on climate change?  C’mon. An 825-metric ton equivalent of carbon per year from the project is only “nominal”, and therefore not significant?

It seems we have in one hand regulatory policy from the state of CA that is designed to reduce GHG emissions, and then we have a regional, city, and CEQA EIR process that finds ways to finesse the creation of more GHG emissions. Something is not right here.

The GHG section of this Project EIR goes to great lengths to “prove” that Project transportation GHG impacts will not be significant, which flies in the face of a commonsense conclusion that even one ton of transportation GHG emissions is significant.


FEIR Questions Inadequately Answered

One essential criticism of the Project’s EIR in terms of transportation GHG impacts, is that an artificial line (activity-based inventory) has been drawn that restricts those impacts to activities only within the city, the county, or the Bay Area region. The FEIR answer to question B04-02 was inadequate because it did not address the question of how a true cost accounting of Project transportation GHG emissions would alter the Project GHG transportation inventory in terms of significance. The FEIR answer to the above question relies on state-level mitigations, not Project-specific mitigations. The answer concludes by stating, “… actions taken in CA would be unlikely to reverse global warming on their own.” Yet, a failure to address incremental Project GHG transportation emissions, and the like, is exactly what has led to the global climate crisis in the first place.


CAPCOA Evaluation of Significant Impacts

As per the following CAPCOA (California Air Pollution Control Officer’s Association) citation, I question if the lead agency adopted any GHG threshold ordinance, resolution, rule or regulation through a public review process, and what substantial evidence the lead agency is using to assert that the aggregate transportation GHG emissions of this Project will not significantly contribute to human-caused climate change? I assert here that the lead agency’s call that Project transportation GHG emissions are less than significant do not constitute an “irrebuttable presumption that impacts below the regulatory standard are less than significant.”


CAPCOA White Paper: CEQA and Climate Change

p. 11 “Additionally, Guidelines §15064.7(b) requires that if thresholds of significance are adopted for general use as part of the lead agency’s environmental review process they must be adopted by ordinance, resolution, rule or regulation, and developed through a public review process and be supported by substantial evidence.

“While many public agencies adopt regulatory standards as thresholds, the standards do not substitute for a public agency’s use of careful judgment in determining significance. They also do not replace the legal standard for significance (i.e., if there is a fair argument, based on substantial evidence in light of the whole record that the project may have a significant effect, the effect should be considered significant) (Guidelines §15064(f)(1). Also see Communities for a Better Environment v. California Resource Agency 103 Cal. App. 4th 98 (2002)). In other words, the adoption of a regulatory standard does not create an irrebuttable presumption that impacts below the regulatory standard are less than significant.”


2011 BAAQMD Thresholds are Currently Adequate?

A lot has changed in five or six years since 2011 climate-wise. A Project transportation GHG alternative analysis and/or peer review by the UCS or similar agency/ consulting firm, would give the public confidence that the GHG component is accurate and representative of primary assumptions concerning planning for sustainability and carrying capacity in development projects. The whole thrust of climate action plans is to address how to dial down business as usual (BAU) practices, not to figure out ways to justify more of the same growth inertia that has led to the climate crisis in the first place. Confidence should be given from the ER process that actual climate problems are being addressed and not that business as usual (BAU) is simply being shoe-horned in.

Transportation and building energy are the two greatest sources of CA state GHG emissions. Transportation accounts for 36.8% of CA GHG emissions. On-road transportation will be a large percentage (40% range) of Project-generated GHG emissions. Transportation is a Project area deemed to be a significant impact in need of mitigation. As I proceed with this comment, I will demonstrate how proposed Project transportation GHG mitigations are inadequate.

My comment, and argument here is centered on how to properly account for Sonoma tourist destination GHG emissions, and specifically the proposed Napa Street West hotel. If the impact is framed as less to start, the mitigations will be less as well.


Accounting for Project-Related Air Travel

Air travel is a type of transportation likely to be used by national and international wealthy tourists targeted by the Sonoma Tourism Improvement District (TID), and by publications such as Sonoma Magazine, (owned by the developer). Air travel has the worst impact for all transportation GHG emissions. However, that there would be any Project-related air travel is discounted offhand in the EIR. On answer to question BO4-03, the consultant says, “It is not anticipated that the Project would generate aircraft trips.” There has been no demonstrated effort by the consultant to account for Project destination travel. The consultant states that the Project itself will not likely be the only reason for air travel air travel. So, who then accounts for air travel if no one is responsible? It is reasonable to assume that some Project transportation GHG will be from air travel. This needs to be actually accounted for and not passed off as irrelevant.

According to the NYT, “one round-trip flight from New York to San Francisco creates a warming effect equivalent to 2 or 3 tons of carbon dioxide per person. The average American generates about 19 tons of carbon dioxide a year.” In the following link, David Suzuki says why air travel is so significant

How many tourists are coming to Sonoma by large airline? Why can’t this be quantified? The FEIR dismisses air travel as having any Project GHG impact, but produces no substantial evidence to support that claim. All hotel users are coming in regionally? I don’t think so; it is likely that some percent of tourists fly into the Bay Area with Sonoma, Sonoma County, and “wine country”, and specific hotels as a destination. This is exactly what the TID is promoting. With the marketing of a large luxury hotel, wealthy people can and will fly to Sonoma from around the country and the world. Sonoma, and this hotel project reasonably have, and will have, an air travel GHG footprint and this needs to be quantified to assess the transportation GHG impacts of this project. A failure to quantify this footprint is evasion of a legitimate impact.

Absence of evidence is not evidence of absence. An alternative analysis/ peer review of Project transportation GHG emissions could find and cite air travel statistics relative to Sonoma hospitality venues, and assign a percentage to a 62-room hotel over a year.

The EIR process puts each hotel and tourist development project as a separate entity, draws a line around project’s GHG impacts and says they are less than significant. In this manner, more aggregate use gets shoe-horned in under the guise of artificially limited and proscribed mitigations. This is exactly how we have arrived at the climate crisis in the first place, by sanctioning more growth rather than shooting for a sustainable carrying capacity overall. This is exactly why an alternative analysis is called for, and why measures that appear to sanction business as usual should be called into question by the Planning Commission.


Wealth, Air Travel and High GHG Transportation Impacts are Linked                         Higher wealth, which is what will be required to travel to and stay at a $500 per night room in the proposed hotel Project, is definitively linked with higher per capita GHG emissions. This is demonstrable:  Luxury tourism takes a high degree of wealth to participate in. Sonoma is known as one of the wealthiest towns in the country. Sonoma = higher wealth = luxury tourism = higher GHG impacts. This is a restatement of the IPAT equation.

An alternative analysis and/or peer review by the UCS or similar agency would have the will to quantify the Project per capita GHG impacts of wealth, air travel, and regional/ employee single vehicle travel, and not pass off the need to for such quantification as irrelevant or “less than significant”, by inadequate measures. From where I stand, the EIR as a whole takes every possible angle to justify the Project and absolutely zero effort to find anything wrong. If this is not biased, what is? An alternative analysis is clearly called for.


CA River Watch CAP Lawsuit was made on Basis of Similar GHG Transportation Deficiencies as in this EIR

Lack of full, or true cost accounting, i.e. accounting for cross-border wine-hospitality-tourism-generated transportation GHG emissions, is the basis for the California River Watch CEQA lawsuit on the county climate action plan (CAP). A critical assumption of this full cost accounting is that GHG emissions are measured within a life-cycle, consumption-based framework, not an activity-based frame solely within county borders as is done by the county Regional Climate Protection Authority (RCPA). The following links show examples of systemic accounting for GHG emissions, of the type my public comments alluded to.

If CEQA is a California Act, who is responsible in CA for the GHG emissions of wine country and Sonoma tourism transportation GHG emissions? Where are these GHG emissions counted? How is a nexus made for the draw that causes the demand for such tourist destination transportation? Do airline flights exist in a vacuum? These are relevant questions aimed squarely at accounting for such Project transportation GHG impacts.

A full cost accounting of ALL transportation GHG impacts would enlarge the scope to beyond a within-county frame of reference. However, since the scope of the GHG impacts seem to be restricted to the county and/or North Bay only, it then becomes acceptable for staff to say: “These (EIR) projections encompass ALL vehicle trips generated by the project, including employees, hotel guests, restaurant patrons, and deliveries”, even though full cost accounting is not being used, and ALL of transportation footprint is not being accounted for.


Local Transportation GHG impacts of the Project

The EIR says that to mitigate local transportation GHG emissions, employees could take the bus to work. This is obfuscation; this is not a refutable argument; that employees can ride the bus does not mean they will. Nobody thinks potential hotel employees will take the bus.

Hotel work is service industry work and pays low wages. People who earn these wages cannot afford to live in Sonoma. It is known that a large percentage of Sonoma workers commute here with a more than ½ hour commute one-way. Therefore, the cumulative impact of some 60 or more employees who cannot afford to live here would amount to a certain amount of GHG emissions that the EIR consultant has declined to measure.

If employees were to take the bus, they will have to hope they don’t get off work late. The last bus to Santa Rosa is at 9:30 PM; the previous bus on the same route is at 7:30 PM. So, if you get off at 7:35 PM, you will have to wait two hours to catch your bus. The last bus to Petaluma is 5:45 PM. The last intra-valley bus is 4:40 PM. Bus service is inadequate to meet employee transportation needs.

In question BO7-08 of the FEIR, the commenter addresses Project employee Vehicle Miles Traveled (VMT), given known scarcity of housing and mass transit. The consultant, admits to not assuming extensive transit use. Is mass transit going to be assumed to be a Project transportation GHG mitigation in one place (consistent with county CAP) but then seen as an inadequate mitigation in another? You can’t have this both ways

It is highly unlikely that any of the 60 or possibly more employees of the hotel will be taking the bus to work, period. The EIR consultant should be asked by the Planning Commission to quantify the GHG emissions impacts of actual Project-based employee transportation. The following give some evidence of what employee transportation would actually look like.

Transportation is 38.9% of all Bay Area GHG emissions. Light duty vehicles (cars) are 63.3% of Bay Area transportation GHG emissions.

As per a 2003 county study on Sonoma County employee commutes: no public transportation was used at all by commuters. 88%-99% drove alone. Sonoma had the second highest commute in GHG emissions in county, after Petaluma. (Sonoma County Climate Protection Campaign GHG Inventory Project; Sonoma County, California September 2003
John David Erickson, Intern)

In the FEIR, the consultant does not answer question BO7-03, about how the Project will facilitate tourist mass transit use. The assumption seems to be that all tourists will be driving cars to the hotel. Thus, no mass transit will be used to deliver patrons to the hotel? The question is not answered. Available stats from the county 2015 Annual Tourism Report, about tourist transportation behavior are not cited. This adds to a perception of bias, if no evidence is cited to the contrary, and all points are stacked (or hidden) in the Project’s favor, this hardly seems like an objective, scientific method of fact finding. What it does seem like is an effort to appear objective while only quantifying points that support the Project.


The City has no VMT Standards or Thresholds

Regarding vehicle trips generated by the Project, the City of Sonoma has not itself, nor has the EIR, established thresholds of significance for evaluating Vehicle Miles Traveled (VMT), in accordance with Cal Trans State goals, nor has the city developed or adopted a Transportation Demand Management (TDM) plan to reduce regional Project VMT.

Proposed transportation mitigations in the EIR do not fully account for nor address how to significantly reduce VMT. The assertions that employees and hotel guest will ride bikes, and ride the bus are not quantified in any way. These are hypothetical suppositions that then are supposed to stand for mitigation of Project transportation GHG emissions.

A reasonable, and quantified addressing of the full value of Project employee transportation GHG will have to address: incentives for mass transit use, employer-provided shuttle and vanpool, ride-sharing, staggered work hours and flex-scheduling synced to the actual bus schedule, off-peak commute hours, carpool designated parking, guaranteed ride home and most importantly, affordable housing on-site (which supports not waiving the residential component).

A study of how many Sonoma hotel workers ride the bus or bikes to and from work should be undertaken. As well, a study of how many hotel guests take mass transit to Sonoma tourist destinations. The we can begin to quantify the Project transportation GHG impacts from actual data.

It can be reasonably demonstrated by prevailing Sonoma hotel hospitality wages and housing costs, that Project employees will not be able to afford to buy a home nor rent in Sonoma. No Project annual wage scale or wages per hour have been provided by the developer, other than an unsubstantiated promise to allow union labor. It is reasonable to assume then, that the number of employees biking to work will about zero. That Project patrons will bike and walk rather than drive is presented as a supposition; it is equally likely patrons will drive to other developer-owned venues, or other county event centers or local restaurants.

In light of the above discussion, the FEIR answer to question B4-03 is inadequate to address the actual vehicle trips generated by the Project.


Idling and Dumb Traffic Light at Second West and Napa

The street signal at 2nd Street West and Napa Street West is not a smart light. Any pedestrian-activated crossing signals interrupts traffic, and causes an intersection fully loaded with cars to sit idling in front of simultaneous red lights on all streets. This light, as currently configured, with possibly hundreds of more people per day in the area as a result of the hotel, has the potential to back traffic up and increase idling GHG emissions substantially. A smart light will need to be installed.


Bicycles, Walking, Tourist Impact on the Plaza

The EIR also promotes bicycle measures as an effort to satisfy BAAQMD TCM’s or transportation control measures. This however appears to be a gratuitous effort similar to the assertion that employees will take the bus. What other high-end hotel is relying on bikes to offset guest and employee transit and GHG emissions? Are rich, high-end tourists going to actually ride bikes anywhere when they can afford to rent a Maserati?

Only area median income people come to Sonoma, rent bikes, and ride out to Gundlach Bundschu or Buena Vista wineries.

Furthermore, once here, since the Plaza is nearby, it is assumed Project patrons will walk to their tourism destinations. This runs counter to a city council trend to question, and point out the high amount of impact tourists are having on the Plaza. Should the Project EIR and use permit be appealed to the council, this policy conflict should be noted. Is the city trying to make the Plaza more resident friendly, or more tourist friendly? Where is the balance? If it is OK for the EIR consultant assume hotel tourists will walk, why is it not OK for public EIR commenters to assume anything, and then have the consultant say there is no specific question?

The FEIR consultant addresses public comment as invalid and non-specific, and therefore “no response is required.” The consultant can’t then answer with vague, subjective answers of their own. This is not a systemically coherent method of addressing public comment; it amounts to a “do as I say, not as I do” double bind that rejects the merits of “non-specific” public comment, but then answers with the same non-specificity as proof. This can’t stand as a logical rebuttal.

The consultant has failed to make a good faith effort to answer public EIR questions, and to make any coherent summary of the issues at stake.

Question BO7-05 in the FEIR does not provide any quantification to answer questions about employee and hotel guest bicycle use, in the same manner the EIR consultant dismisses as inadequate from the public. Subjective assertions such as “it’s possible”, “more likely”, and “reasonable to anticipate”, about bicycle use cannot stand as an adequate response: where do Sonoma hotel employees live? How many in Sonoma? How many ride bikes to work? With the whole county advertising wine event centers and rural tasting facilities, hotel guests will not drive cars to events or to the coast?  Do not wealthy tourist have luxury cars that are known to get lower MPG and have higher GHG impacts? Higher wealth correlates with higher GHG impact, and a luxury hotel can be reasonably seen to be a magnet for higher transportation GHG impacts overall.

In the answer to question BO7-07, the consultant says Project transportation GHG emissions could “reasonably be expected” to be reduced because patrons will walk to the Plaza rather than drive their cars. Patrons would walk, “compared to conditions that might normally exist for a hotel that is not in walking distance of such.” Again, why can’t I question that it is reasonable to expect that the Project has an air traffic GHG footprint, and that this might be significant? No, with this EIR consultant we have a double bind discourse method being foisted on the public here that is not fair and obfuscatory.

Could it be “reasonably expected” that the hotel, working in conjunction with developer-owned Cornerstone, Wing and Barrel Ranch, Ramekins and The General’s Daughter, would have events and conferences there? These types of conferences are certainly planned as they were mentioned as part of the original hotel aspirations. Will hotel guests walk over there? Not likely at all. The Anderson-owned Wing and Barrel Ranch has a proposal for a substantial new club house to be built, and thus, plans to ramp up the tourism transportation GHG footprint associated with the hotel are clear to see.

Riding the bus and bikes as TCMs are a facile ploy to show some mitigation when existing surveys (Sonoma County Climate Protection Campaign GHG Inventory Project; Sonoma County, California September 2003
John David Erickson, Intern), and common sense lead to other conclusions. This is similar to the Montini EIR where off-leash dog’s impact on rare plants were supposed to be mitigated by a few signs and a low rock wall. Really? This Montini mitigation in the face of plenty of contrary evidence and reports showing compliance troubles with off-leash dogs in signed, public land areas.

What for Montini was signs and low rock walls, is bikes, bus, and curb pop-outs for the transportation and traffic aspects of this hotel Project. The whole traffic mitigation process hinges on two or three critical mitigations, mitigations that can be shown by alternative evidence and analysis to be inadequate. The only question is: who can bring the will and resources to bear to produce such alternative analysis? This is what I am requesting of the Planning Commission for this Project. An alternative Project transportation GHG analysis and/or peer review by an agency that will. Or, Planning Commissioners themselves call out the inadequacy.


Master Response cited but Not Indexed

In response to questions BO9, the consultant refers the reader to master responses 1 and 2, yet such master responses are not indexed in the FEIR. As such, the FEIR is poorly organized. How can the reader get a clear understanding of consultant answers to public comments, if the master responses cannot even be found in the index? If the Executive Summary is supposed to be the master response, there is none for GHG emissions, and the traffic and transportation section merely says that a curb pop-out and striping will mitigate everything.


Transportation/ Traffic Mitigations as Proposed are Inadequate

The information given in the original distributions of the FEIR responses to public comment included answers that sought to justify proposed hotel employee and guest transportation as being mitigated by mass transit and bicycle transportation. This assertion by the consultant, has now been explicitly denied by staff.  Staff now says that ALL transit GHG impacts have been accounted for in the EIR.

So what is it? What the consultant said before, or what staff says now?  When so many things get said over 1000s of pages of documents, who can keep track of what is true anymore? In law, this is known as “papering” the opposition. The opposing side is given so much material to look at, it becomes impossible to make sense of it all. Thereby a case gets made, not by compelling  arguments but by overwhelming with incomprehensible amounts of detail, which is then asserted to be true and right.

After a half hour of looking for the master responses, for pedestrian, bicycle, and traffic operation impacts, FEIR p. 5-3, I finally found it. And what does the master response say?  All the studies, graphs and objective quantification dismisses all public comments, points and concerns, and postulates that bicycles, mass transit and curb pop-outs will fix everything. That’s how Project transportation GHG impacts will be mitigated in a nutshell.

Does that not strike the Planning Commission as inadequate?

Given that the public simply does not buy the transportation GHG reduction rationales provided in the EIR, for good enough reasons, it is reasonable to ask for an alternative analysis so as to demonstrate to the public that every reasonable and full-evidence, true cost accounting alternative has been considered. If the EIR is going to make “facts” out of Project transportation GHG as being less than significant, and this will then be the basis of a possible developer lawsuit if the city does not approve the full project objectives as desired, I submit it is incumbent on the Planning Commission to seek and alternative study to satisfy the reasonable doubts raised by the public.


Alternative Analysis Necessary to Represent Public Interests

The public simply does not have the chops and expertise to take on this EIR. What the public needs is to be represented by an alternative expert. Then, let the Planning Commission decide whose arguments are more compelling.

The EIR and FEIR answers to almost all questions fail to connect the dots and address the gist of commenter’s points. The whole question and answer format reduces discourse to a kind of fake logic and stilted lawyer-type talk, that assigns factual value to partial, and biased evidence, and then challenges the public to have to provide its own study to refute it all. An alternative analysis would be the study to represent the public’s interests vis-à-vis this Project.


Consistency with County Climate Action Plan

The EIR claims the Project is consistent with county Climate Action Plan (CAP), specifically through the CAP’s Solution #9, Transportation and Land Use.  p. 43.

This claim of consistency is cited in the DEIR Appendices, under Environmental Impacts category #7, GHG, p. 32 of 60 or p.47 of 630, table 2

“CAP Solution #9: Transportation and Land Use

Strengthen city centered, transit oriented development. Continue to emphasize urban revitalization and infill, mixed use, and transit oriented development along major transportation and transit corridors.”

“Consistent with CAP:

The Project is an infill project that would be pedestrian oriented by encouraging hotel guests to walk or bike in and around the Sonoma Plaza. The Project is also proximate to Sonoma County Transit bus routes on Highway 12 and West Second Street.”


The EIR claims the Project is consistent with the county Climate Action Plan (CAP), specifically by being a “transit oriented development”. But this is not the case. Mass transit in Sonoma is currently inadequate to meet the needs of hotel guests, employees, and the public. Sonoma does not have the numbers to justify more frequent service. The bus schedule is plain not frequent enough, or of long enough duration, to be adequate. It is not logical to call the Project a “mass transit oriented development.” The current Sonoma workforce commutes almost entirely by single vehicle, single occupancy commutes of 30 minutes or more. This creates high GHG emissions, which is not consistent with CAP transportation guidelines.

The Project is not mixed-use because the developer and staff want to waive the residential component. And, simply encouraging hotel guests to walk and ride a bike does not mean that they will. The current trend is for more tourist individual transportation, to drive to rural locations for wine, food and events. Tourist transportation patterns are cited below under the heading 2015 Annual Tourism Report.

This citation of supposed consistency is an example of deficient reasoning in the EIR, citing a weak example that simply does not prove the point. If this is the case here, what other EIR citations suffer from similar factual inflation?

One would have to conclude then, that the Project is not consistent with CAP Solution #9.


Inconsistency with Recent City Council Adoption of 22 Local Climate Protection Measures

The recently city-adopted Measure 4-L1, Mixed-Use Development in City Centers and Along Transit Corridors, p. 3-43 of county Climate Action 2020 textbook, is consistent with the CA2020 goal of reducing travel demand through focused growth. The annual GHG reduction potential is high, 3,494 metric tons of CO2 equivalent. This is now a specific city goal and planning parameter.

Just as it is seen as OK in this EIR/ planning process, to wait for a yet-to-be-implemented inclusionary housing impact fee policy to come into place, it should also be OK to start looking for Project planning to be consistent with Measure 4-L1.

The CA2020 text for Measure 4-L1 states: “The jurisdictions would focus new residential and commercial development in their city centers and along existing and planned transit corridors. Mixed-use development (such as residential use above commercial uses) in such locations would improve the diversity of nearby land uses and facilitate easier access to retail and commercial destinations. Improving the jobs/ housing balance would also facilitate access to work destinations. Development adjacent to transit centers and along active transit corridors (commonly called transit-oriented development or TOD) would increase the amount of trips that could be completed via transit instead of personal vehicles.”

Many community co-benefits are listed by the RCPA, and these dovetail with many stated Project Objectives as well. As I noted before, 99% of stated Project Objectives are consistent with many types of project. The weighing of costs and benefits here, as far as what type of Project the Planning Commission may choose, gets down to whether TOT tax and hospitality tourism is seen as a greater community benefit than resident-friendly mixed-use development?

Measure 4-L1 goes on to say under Implementation: “The jurisdictions will develop appropriate tools for cities and urbanized unincorporated areas to encourage mixed-use, infill, TOD, and economic development intended to serve local residents…  The communities would promote and apply existing policies and incentives to further encourage mixed-use, infill, and TOD.”

So, here we have the potential to turn the tide of downtown Sonoma to a more resident-friendly infill area and foster the use of more mass transit. More residents will mean more demand for the nearby mass transit hub on the Plaza, and more demand for central businesses that serve residents, vs. businesses that exclusively serve tourist hospitality. The hotel Project obviously serves tourist hospitality interests (and investor returns interests) above residents, and the Project’s primary community benefit, in terms of the number one stated Objective, a 62-room hotel with an 80-seat restaurant, is defined in terms of TOT tax money to the city, rather than through downtown livability and mixed-use.

The hotel Project as proposed would meet none of the Measure 4-L1 objectives. A prime opportunity for mixed-use development would be lost by waiving the residential component, and by having another restaurant when more diverse, resident-serving downtown, infill retail is called for by 4-L1. That the city council has just adopted Measure 4-L1 along with 21 other local climate protection measures, is a powerful rationale to modify the Project to meet these transportation and central planning specifications.

These mixed-use, centralized planning specs are squarely in place to address climate change and transportation GHG impacts.

Mixed-use means housing and commercial together. Measure 4-L1 means building housing near a transit hub, i.e. the Plaza. By adopting measure 4-L1, Sonoma has committed to having 50% of its growth to result in this type of mixed-use development. By not waiving the residential component, and taking the No Restaurant alternative, the city will be consistent with Measure 4-L1. By approving the Project as proposed, the city will be missing a prime, central-city mixed-use development opportunity that is not likely to come again soon.

Finally, the General Plan states that, the purpose of the Commercial designation is to “… provide areas for retail, hotel, service, medical, and office development, in association with apartments and mixed-use developments and necessary public improvements.” Given that there is not that much space downtown, a project that combines hotel use with residential is one that meets multiple city planning objectives at one time. Multiple objective projects are better than single objective ones because more public policy goals can be met at once.


The Sonoma County, 2015 Annual Tourism Report, Inconsistent with CAP

The 2015 Annual Tourism Report, from the Sonoma County Economic Development Board was produced by Moody’s Analytics. “Moody’s Analytics is a leader in economic research and provides key quantitative and qualitative analysis on Sonoma County’s tourism industry. Key findings from Moody’s Analytics Tourism Analysis include:

“Sonoma County’s tourism industry is maintaining a strong expansion. (emphasis mine) This marks the continuation of four years of growth in which tourism has outpaced the rest of the economy.

“The long-term outlook for Sonoma County tourism remains strong. The region continues to grow in recognition as a premier tourist destination, and its proximity to Bay Area attractions and airports is driving its expansion.” (emphasis mine, proximity to airports eh?) According to Moody’s, 60% of tourism jobs are service jobs which pay well below county area median income (AMI) in yearly earnings. What this means is that tourists will increasingly travel by air and car to Sonoma, and potential Project employees will be commuting to Sonoma for somewhere else, all generating transportation GHG emissions. This conclusion runs counter to the EIR thesis of a “nominal’ Project transportation GHG impact.

The Moody’s Tourism Report is all about how much money is to be made by who, and nothing at all is said about tourism transportation GHG impacts, nor about reaching any carrying capacity level to reduce tourism-generated GHG transportation emissions. The whole premise of tourism is that wealthy people travel somewhere, to be entertained in some form. Tourism has a high GHG footprint, and the more of it you have, the higher your GHG footprint.

The EIR is supposed to address the Project transportation GHG emissions impacts, but as you can see from the above examples, employees and tourists will continue to expand their driving and other transit-based GHG emissions, and in aggregate, this could not be less consistent with the CAP, and the call to reduce transportation-based GHG emissions overall, which is the largest state and regional sector of GHG emissions by far.



To conclude, an alternative analysis and/or peer review of the Project’s transportation GHG emissions by the UCS or similar would give the public confidence that the EIR was not simply a BAU, growth-justifying document, and that actual sustainability and carrying capacity transportation climate change objectives were being met.

Should an alternative analysis and/or peer review be called for by the Planning Commission, it will be very important that the agency or firm not be chosen by city staff or Kenwood Investments. The whole point is to not get another firm whose job it is to incrementally justify BAU growth, but to engage an agency that will look at this EIR from an actual alternate frame, one that represents legitimate, science-based public comment regarding climate change and Project transportation GHG emissions.

The Union of Concerned Scientists is such an alternative frame.

Basically, what we have here with this Project and its EIR, is a BAU, growth-is-necessary/ private property rights trumps environmental policy paradigm, with experts to justify it, up against a public who is advocating a change to BAU towards a carrying capacity, sustainability future that calls for less consumption, and its associated tourism transportation GHG impacts, not more. What the developer and city are framing as benefits, a public concerned with sustainability (triple bottom line, full cost accounting) sees as costs.

What the public needs in this process is an alternative analysis that does an actual, scientific cost/ benefit analysis of Project transportation GHG emissions impacts. If the UCS said the Project transportation GHG impacts were acceptable, there would be nothing left for me to say.


(1) Consumption-Based Greenhouse Gas Inventories


“This study develops a consumption-based greenhouse gas inventory of all San Francisco Bay Area census block groups, cities and counties. It is the first study to explore household carbon footprints at such fine geospatial resolution for any region. The methodology incorporates local consumption and emissions data wherever possible. In other cases, consumption is approximated using econometric analysis of national and statewide transportation and household consumption survey responses by S.F. Bay Area residents. The consumption-based method results in about 35% higher GHG emissions than the traditional territorial approach for the region, largely due to higher emissions from imported food and goods. Transportation is the largest source of emissions (33%), followed by food (19%), goods (18%), services (18%) heating fuels (5%), home construction (3%), electricity (2%) and 1% waste. Within the region there are large differences in the size of average household carbon footprints (HCF) between cities (>2.5x) and larger differences between neighborhoods within populous cities (~5x). These differences suggest large inequalities in climate responsibility within a single metropolitan area. The composition of household carbon footprints also varies considerably between different locations, with vehicle ownership, income, household size and home size contributing the most to differences. The study concludes with recommendations to prioritize policies and programs for different locations.

Learn about the Air District’s Consumption-Based Greenhouse Gas Emissions Inventory.

The Air District collaborated with the Cool Climate Network at UC Berkeley to develop a consumption-based inventory of greenhouse gas emissions for the San Francisco Bay Area, based on the six greenhouse gases identified in the Kyoto Protocol: CO2, methane, N2O, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. The consumption-based inventory estimates the amount of greenhouse gases emitted in the production of goods and services from all over the world that are consumed by Bay Area residents.

The consumption-based inventory is intended to supplement and complement the Air District’s production-based inventory of greenhouse gases that are emitted within the geographic boundaries of the Air District.

The consumption-based inventory is based on a full life-cycle analysis of the emissions generated by the production, shipping, use, and disposal of each product consumed in the Bay Area, regardless of where the GHG emissions were released to the atmosphere. The inventory estimates emissions for several hundred categories of products within the five basic areas of transportation, housing, food, goods, and services.

Because our modern economy is highly integrated and global in scale, a significant portion of the goods and services consumed by Bay Area residents are produced in other states or nations. A consumption-based inventory is especially relevant for the purpose of analyzing the GHG footprint of people in affluent regions, such as the San Francisco Bay Area, where the high level of income enjoyed by many households leads to increased consumption of goods and services, as well as more spending on leisure activities such as vacation travel.

In combination, the Air District’s traditional GHG inventory and the consumption-based inventory provide a more complete analysis of how the region contributes to global climate change.

The consumption-based emissions inventory will be used to:

  • help inform development of the Air District’s Regional Climate Protection Strategy
  • identify potential GHG emission reduction policies or measures
  • assist climate planning efforts by cities and counties in the Bay Area
  • help educate Bay Area residents about the size and composition of their GHG footprint and how they can take action to reduce their GHG emissions











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