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 a member of Sonoma Overlook Trail Stewards, as well as Sonoma Valley Housing Group and Transition Sonoma Valley.


First step toward assisted-living facility on First Street East

Posted on June 25, 2019 by Fred Allebach

The proposed First Street East project, at the old Peterson property adjacent to Vintage House, is a proposed 80-bed assisted living facility, along with 27 residential units.

Previous projects (which included a hotel/restaurant, and vacation rentals) at this site garnered much neighborhood opposition, and led to acrimonious relations with former Planning Commissions and with the city. You could even say that the dynamics resulting from previous proposed projects at this site, and accusations of bias against commissioners, are what led to the shake-up of the then current Planning Commission, and to the new city commission selection process, and also to the dirty politics of the last election, and ongoing efforts to anonymously smear current council members.  

CEQA cart before the merits horse

The recent hearing and presentation was short on Project details and long on CEQA process boilerplate comments. An assumption was made that everyone in the public had read all about the Project, and that it was OK to get right to EIR stuff before the merits of the proposal had been vetted.   

This order of operations issue was noted by Planning Commissioners and the public. Contract staff said, “we can’t help this, this is the hand we were dealt, please just stay on CEQA environmental impacts; we are not programmed to go outside of city protocols at this time.” And, apparently, the developer was advised to not do a project description because this was to be a CEQA hearing only. Even though everyone knows you can’t stop the public from leaking out whatever merits issues they want to talk about in their three minutes.

Project alternatives 

The CEQA slide show presentation given by the contract staff did have a project alternatives section, where options for less senior living and more affordable housing were given. Project alternatives are given to provide options to reduce possible significant impacts of the initial project design.

Discovering what is significant etc. becomes like reading a board game’s rules inside the box cover, and arguing about exactly what they mean. Any area of ambiguity can be used by any player to try and justify their moves. Staff, consultant and developer will try and justify the initial design, the public and commissioners may look to the alternatives.   

Housing Opportunity Site

Given that the Project site is one of the few remaining city Housing Opportunity Sites (HOS), and an 80-bed assisted living unit is a commercial enterprise, and does not qualify under any existing city Housing Element category as “housing”, of any type, it seemed the city and developer wanted to sidestep all that and maybe get this project through with exceptions and minimum qualifications. 

Sonoma as Carmel

I see recent Sonoma housing development as a parade of market rate projects that just keep on getting proposed, and where a 20% inclusionary requirement (that is 120% AMI only) suffices for about the sum total of social equity in housing. Every market rate project over five units tips the Sonoma demographic 80% more to the 10% and the 1% of national wealth, since no one from the area median income (AMI) spectrum can afford anything near market rate prices here. 

If the city’s default inclusion of area median income people, who are easily 50% plus of the regional population, is 20%, and a typical percent for deed restricted Affordable Housing in a community is between 10 and 15%, and Sonoma currently has only 250 deed restricted units out of 6000 housing units total, this leads to a demographic, mathematics conclusion. Sonoma is behind the social equity curve and needs to catch up. Sonoma is already woefully lacking housing for the lower AMI spectrum, and for each market rate project that provides 20% of inclusionary units, at 120% AMI only, and none extra, the AMI population displacement rate is 30% to 40%. This assuming that the regional AMI population is 50% to 60% of the overall population. In reality, it is probably more.

This is a built-in equity draining situation, Sonoma is just like Marin, Carmel, Woodstock, VT, and Aspen etc. The wealthy flock there and all prices go through the roof; the demographic gets stilted to elderly wealthy white, schools suffer, low density housing predominates, NIMBYs fight inclusion, workers get displaced.  

A city-defined housing roadmap?

Some have said in the past that the city needs an economic development plan, and a housing development plan and blueprint that lays out what the city wants. That the city and not developers should define the quality of growth, and the target demographic. The city should use its own upgraded, self-defined planning code and General Plan, and maybe some Specific Plans, to show developers what is wanted. 

As things stand now, the city’s cart is hitched to the whim of the wild horses of the market. The best the city can do is go along for the ride and try and get some money and benefits out of it. In a way, the whole pattern is similar to heroin addiction: a compulsion to do the wrong thing and arrive at a lesser good is incentivized, and mitigations amount to simply taking a little less metaphorical heroin. This is the kind of social good the market brings. 

A 20% inclusion at 120% AMI satisfies all equity parameters? 

The Project site is a HOS and there could be 53 housing units, 27 are proposed. The Project would have five inclusionary units, which would mean the applicant could then somehow go around the Housing Accountability Act, and also get some kind of density bonus concession based only in a required minimum of the five AMI affordable units. An inclusionary affordable unit need only be 120% AMI, $123,000 for a family of four, that’s what stands for “affordable” for Sonoma inclusions. 

These are the kind of things the council might direct the Planning Commission and/or a Blue Ribbon citizen committee to address, because zoning and code are exactly where to insert inclusive values and to structurally address social inequities. Inclusion is already a stated value in the General Plan. 

I think the Planning Commission should use whatever discretion they have legitimately available, according to the current Sacred City Texts, to insist that this project adhere proportionally to its designation as a HOS. And that the Project meets the current housing needs of the city. 

Social environment? 

The EIR has a land use and planning, population and housing section. I had imagined in my public comment, that the social environment is as much a part of “the environment” as any, and that helping create a monoculture, wealthy environment would be something of a significant impact, and that this project seemed to add to an environment of social inequity. This thread was picked up later in a discussion of “highest and best use.” 

What could be the highest and best use? Affordable Housing, commercial? Does the 20% inclusion at 120% AMI-only really check all the boxes for affordability and then anything else goes? Not according to the third city Housing Action Plan meeting, where the public present overwhelmingly called for more AMI-level affordable housing, 50% deed restricted Affordable Housing for all new units in the next 10 years at that! 

Blight is a CEQA impact, what about elite? 

Commissioner McDonald asked staff, is the social environment part of CEQA? No, city attorney Veronica Nebb said, but if a project would lead to physical, environmental changes, like blight…, then that would be a legit CEQA social environment, social costs angle to take. 

If blight is an extreme social cost that qualifies as a CEQA impact, what would be its opposite? Elite would. Elite is as extreme an environmental effect as blight. With elite, anyone making AMI can’t afford to buy anything, they are excluded, segregated, and eventually displaced. In this way, by allowing a progressive tipping to more and more elite units, Sonoma’s social equity responsibilities are avoided and externalized to other communities. Business as usual has the skids greased for this exclusivity in the Housing Element and code, etc. This situation can be changed.

The opposite of blight and extreme poverty is ultra-market rate extreme wealth like we see in Sonoma now. Sonoma is out of balance on the high end, and a 20% inclusion as the major equity strategy in place, with no big new affordable projects besides SAHA, leaves Sonoma tipping more and more to the 10%. That 10% needs cleaner fish to be able to come and work for them, or to come rescue them in an emergency, to take care of their yards and kids and houses, and all is better if workers and clients all live in the same community, be neighbors, have kids go to the same school, and are all in it together. Integration is better than segregation.

Project Draft EIR comment

This is a DEIR comment for staff: if blight is a CEQA environmental effects category, why is elite not measured by the same level of extremity in its effect along a scale of social costs? Extreme wealth is having a negative effect on the AMI cohort even being able to live here. Having workers be able to live here is a General Plan goal. What about systemic, exclusionary policies that lead to and protect low density zoning pockets and segregation? 

Existing discretionary hierarchy for AMI housing? 

There was some talk about how to decide what alternatives take precedence, given the current code. Kristina Tierney, city Planning staff said, the “General Plan trumps the code.” Interesting! The General Plan would then lead to defining a hierarchy of importance, from the Housing Element, and then to Housing Opportunity sites. What trumps what for housing values? The hierarchy will lead decision makers to adhere to a currently valid code and General Plan roadmap, one that can foster and require more social equity, as the Housing Action Plan has shown people in the city want.  

The developer speaks

Maybe there is an existing hierarchy that makes a HOS of greater import than commercial use. This wide-ranging hearing covered all the above kind of stuff, but then the developer, who had been told not to give a project description because this was a CEQA presentation only, got steamed by hearing all the merits and values talk, and he yelled out from the crowd to speak. Chair Felder graciously re-opened the hearing to let him speak. Mr. Reyes felt his project had been unfairly attacked and misrepresented and he was pissed. He said he was a good guy, with people’s normal interests in mind, and that he was intent on doing good, that he never kicked people out because of lack of money, and that this was his family business he grew up in, and that the rent in the 80-unit assisted living facility would only be $3,100 a month for a studio. 

Where’s the beef? 

In my following comment, I mentioned that applicants can say anything at a hearing, and everyone can say how great they are, but the public and commission needs to see the specifics spelled out and quantified adequately. Of the 80 units, how many studios? How many square feet? What costs are included or excluded? Extras? Food, exercise, haircut? Let’s see some numbers for the full monthly bill for each assisted living unit proposed.  

If the land costs are $9 million, and construction may be $30 to $40 million, and Sonoma is known as a top unaffordable place to live, how can this money be recouped with affordable units at $3,100 a month, from tenants who have area median income savings? Who is the project really going to serve? The land and construction costs don’t seem to add up to below market assisted living rents… If the target group to be served is just “the elderly in town”, who are they demographically and savings-wise compared to others? Doesn’t Sonoma already have three or more assisted living facilities? What is the demand? What will really serve local seniors? The price points and sizes for all 80 units and the associated costs will tell it all. I have a hard time imagining that the assisted living project here is not designed to serve top-end clients only, and I’d like to see objective proof that it is not.

A quick look at the developer’s portfolio of assisted living projects features the word “luxury” frequently. And studios are 280 square feet. We can kind of see what Sonoma would get, and wonder why in a luxury market like Sonoma, investors would not seek to maximize their rents? 


A veiled, Wizard of Oz-like aspect to the project here is that the core investors are people who were implicated for ethically questionable campaign practices in the last election, one of whom who is suing the city over not being able to break city code to make mansions on the hillside just up First Street East, and the other who has used gratuitous lawsuits to intimidate public officials. These are guys who openly espouse speculative profit seeking, to get the highest returns possible. So, it is a bit of a stretch for social equity people here in town to buy into an assertion that the current project really constitutes a greater public good, and would have actual AMI affordable prices. That just seems out of character for who is behind it all. 

A greater good and highest and best use is glossed totally differently by different universes of alternative facts here.  

Post-script in the lobby

I had a chance to chat with the developer afterwards in the lobby and I said, “it’s not just you, anything in the Plaza area gets high community scrutiny, because it is the heart of town, and people feel a sense of ownership”, and I said, “just let this one roll off, and come back fresh, hang in there.”  Mr. Reyes was still steamed, and said he was shocked and disgusted by the hearing and was going to talk to his lawyer. 

Then it was on to polish off the perfectly room temperature Brie cheese while hobnobbing with the likes of Marilyn Goode and a few Planning Commissioners who had to recuse. 

In retrospect I thought, even if there was a great AMI, HOS project there at this FSE site, the same sort of parking and traffic, sight lines, and character issues would all come up again, and this just hasn’t got there yet, because social equity never pencils out, and if a real affordable project does get there, the fight could then be AMI affordable housing versus neighborhood character. 

Given the Housing Action Plan turnouts, there will be plenty of people to advocate for AMI housing, if and when that time comes.

One thought on “First step toward assisted-living facility on First Street East

  1. If Sonoma has a clue they would have built a small hotel on this site that would bring in much needed tot taxes so we can have better police patrol, improved streets and money for other failing infrastructure. Not the location for affordable housing. There is no such thing anyways. The cost to build anything half way nice would never. E affordable. There are lots of other affordable parts of ca to live in.

Leave a Reply

Your email address will not be published. Required fields are marked *


Do NOT follow this link or you will be banned from the site!