Re: St. Vincent's Village Development Proposal and Silveira Property

Dear Mr. Zitney:

The Sierra Club Marin Group would like to request that the items below be addressed in the scope and discussion of the Draft EIR for the St. Vincent's Village Development Proposal and Silveira Property Land Use Evaluation.We believe the following have potential environmental effects and need to be included in the environmental analysis.

1. The Silveira family has submitted a conceptual proposal for their property. This proposal should be fully evaluated as an alternative in the EIR as well as the St. Vincent/Silveira Task Force's proposal. This would be fair to the property owner and give a full and cumulative perspective of the potential environmental impacts of both the St. Vincent and Silveira properties.

2. Discuss an EIR alternative where the Silveira property remains in agricultural use and with complementary zoning and the St. Vincent property has only limited additional new housing and no additional commercial use. This limited number should be no more then the lowest range of housing recommended by the St. Vincent/Silveira Task Force for the St. Vincent property. This alternative would reflect the recent proposal in the Independent Journal by one of the San Rafael City Councilmembers. 

3. Discuss the viability and impacts both on site and within Marin County of new office complexes on both or either property in light of Marin's current high office vacancy rate, very low unemployment rate, traffic congestion and traffic patterns.

4. Discuss impacts of potential new office and/or hospitality use in the area designated for commercial office space in St. Vincent's H complex.

5. Discuss impacts of including an Inn and/ or assisted living facility within, or near the H complex on the St. Vincent property along with other stated business uses. These additional uses near the H complex were not part of the St. Vincent/Silveira Task Force's recommendation. The mention of inclusion of an Inn or assisted living facility was stated in your Notice of Preparation .

6. Discuss the cumulative impacts of the proposed project with other nearby projects that are now under consideration, including the Oakview project west of the freeway (being processed by the County).

7. Discuss impacts on wildlife corridors from proposed new trail systems and their accompanying human intrusion.

8. The Equestrian Center is planned to be moved and expanded east of the railroad track. Various issues need to be discussed and evaluated.

1. Odors from the new Equestrian Center on the school for boys and nearby recreational areas.
2. Seismic related failure on the Equestrian Center and its related structures which are located in geologic areas with bay mud and subject to liquefaction.
3. Waste materials generated by Equestrian Center and its associated riding paths adjacent to and within wetland and bayland areas and the bay.
4. Relationship of Equestrian Center to City of San Rafael and County General Plan policies for preservation of Baylands Conservation Zone.
5. Impacts of Equestrian Center on the new Hamilton Wetlands Restoration project. Discuss noise, odor, water and air quality impacts to this restoration/preserve area.
6. Water supply and sewage requirements, and their impacts on the lands east of the railroad track for the Equestrian Center and its related structures and facilities. 

9. A new parallel drainage canal, "branch of Miller Creek", is proposed to be constructed on the St. Vincent property parallel to the existing Miller Creek. Discuss the impacts of this drainage canal on the natural water flow, water quality, and habitat of the existing Miller Creek west of the railroad tracks and to the Silveira property. Discuss the drainage canals impact on the flood plain surrounding Miller Creek and the groundwater on the Silveira property west of the railroad tracks.

10. Discuss the impacts to the riparian wetlands, woodlands and seasonal wetlands on the Silveira property and along Miller Creek west of the railroad track with the diversion of natural runoff from the St. Vincent property by the proposed "new branch" of Miller Creek. Also, how would this diversion of water affect the Silveira property if it remains in agricultural use?

11.  Discuss the current Federal, State and Insurance Industry policies and thinking regarding construction on flood plains, bay mud and areas subject to liquefaction.

12.  Environmental Checklist for the project scoping, page 15, # g is checked No Impact. This issue says, "Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?" We believe this should be checked Potentially Significant Impact. The emergency response or evacuation plan and its effectiveness for this project can not be determined prior to completion of an extensive traffic analysis of the various alternatives and the understanding of the cumulative impacts of this project. Without this information a determination of "No Impact" is not justified.

13. Environmental Checklist for the project scoping, page 16, # b, discusses ground water supply. We believe it should be checked Potentially Significant Impact and not Less Then Significant Impact. One of the alternatives to be analyzed is to have the Silveira property remain in agricultural use. If the Silveira property continues in agricultural use, what impacts will the St. Vincent project have on Silveira's ground water supply? This might be a Potentially Significant Impact.

14.  Environmental Checklist for project scoping, page 18, #a, Land Use and Planning lists, "Physically divide an established community." This is checked as No Impact. We believe this should be checked as Potentially Significant Impact. Currently the "open space" area of St. Vincent/Silveira provides a community separator between Novato and San Rafael. Discussion of the significant loss of this open space, view and buffer corridor by the proposed development should be included in the environmental evaluation.

15.  Discuss noise of the project on the habitat east of the railroad track and on the Silveira agricultural lands.

16. Discuss impact of air, noise, water quality and runoff on the Las Galinas Sanitary District operations and vice versa.

17. Discuss the noise impacts and safety issues of the proposed SMART rail system and railroad right-of-way on the new Equestrian Center, school for boys, elementary school and recreational facilities.

18. Discuss the grading, cut and fill proposals for all alternatives in relation to the City of San Rafael and County of Marin General Plan policies.

19.  Environmental Checklist for the project scoping, page 22, # c, (Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere) should be checked Potentially Significant Impact and not No Impact. Discuss the displacement of the existing school for boys, the school staff related to the school uses, the problems and impacts of this move and the potential impacts of its relocation to the area of bay mud and flood plain just west of the railroad tracks, as well as the move of the Equestrian Center and associated structures east of the railroad tracks.

20. Discuss economic impacts to the City of San Rafael for required new public services; police, fire, schools, park maintenance, water, roads, road maintenance, etc. Also, include an analysis of the cost to San Rafael's on-going budget for providing public services to this new community.

21. Discuss traffic and parking impacts of the new and restored recreational facilities in relation to both the project and Marin County.

22.  Discuss transportation/traffic delay time on US 101 due to increased traffic from the project. Measure the different delay times generated by the various project alternatives. Delay should be measured in roadway segments. This time delay should be compared to current time delay and to time delay at project buildout.

23. Discuss cost of new interchanges related to the St. Vincent and Silveira projects required to mitigate new traffic for all EIR project alternatives. State how these will be funded and who would pay for the needed improvements related to these interchanges, such as at Marinwood and Lucus Valley, as well as needed improvements to US 101.

24. Discuss long term costs associated with proposed local shuttle service, and its long term viability after looking at previous projects with shuttles within Marin.

25. Discuss the relationship and reliability of transit for this project by the Golden Gate Bridge District in light of its current budget constraints and reduction of service and routes.

26. Discuss methods to be used to retain "affordable" housing in this category.

27. Discuss the availability of water supply under all alternatives, including the impacts on the areas from which the water would be obtained.

Sincerely,

Martha Olson Jarocki , Co-ChairDotty LeMieux, Co-Chair

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