Fear, frustration and FAQs in Planning Commission hearing on S.E.I.R.


Planning Commissioners on Monday listened to and shared their own comments on a draft of the Countywide Plan’s supplemental environmental impact report, which focuses on potential cumulative impacts from development in the San Geronimo Valley on salmonids and streams. 

Homeowners and commissioners alike expressed concern about the document’s build-out scenario, since the hypothetical development of each of the valley’s lots serves as a baseline for evaluating cumulative impacts. 

“The S.E.I.R. should include evaluations of alternative development scenarios that represent the more probable and less extensive future development of the San Geronimo Valley,” said Ann Saramon, a member of the San Geronimo Valley Stewards. “If you’re familiar with the area, there has been very little major development within the last 10 years. French Ranch was the last big development.” 

The authors of the draft, a combination of environmental planners from the county and consultants from the environmental conservation firm Stillwater Sciences, developed the report around the projection that 358 additional units could be built in the valley. 

Commissioner Don Dickenson questioned the number. “One of the dilemmas in this whole process is trying to deal with cumulative impacts and what is realistic,” he said. “As you’ve indicated, you took the most conservative approach and assumed that every lot was developable, which, if you know San Geronimo Valley, with its septic restraints, clearly would never, ever happen. Why wasn’t it a more realistic assessment?” 

Rachel Reed, an environmental planning manager for the county, said “the California Environmental Quality Act requires you look at the worst case. At the very least, we’re considering what the most impactful scenario is. Another practical reason is the project is under litigation, so why not be more safe and conservative in your analysis.” 

The Salmon Protection and Watershed Network has sued the county repeatedly over the last decade over the Countywide Plan’s protections for coho salmon and steelhead trout in San Geronimo Valley streams. 

Andrew Ogden, a senior attorney for SPAWN’s parent group, the Turtle Island Restoration Network, said his organization will assist in finalizing a streamside conservation ordinance for the county. “We’re willing to meet with any stakeholder groups, work with the county and come up with the exact form of that ordinance,” he said. 

The ordinance designates development setbacks as the greater of 50 feet landward from the outer edge of woody riparian vegetation associated with a stream or 100 feet landward from the top of a streambank. 

Dennis Poggio, of Forest Knolls, criticized the “overreaching financial burden” of requiring property owners to hire a biologist to conduct a site assessment before development can take place. “The draft S.E.I.R. that is being proposed today is lacking fairness,” he said.

Toward the end of the hearing, Commissioner Christina Desser, who represents District 4, asked to what extent the fish in the valley are impacted by conditions elsewhere in their habitat, and whether the draft’s authors looked at those conditions. In other words, “do they die as soon as they leave this little watershed?” 

Anthony Keith, a senior aquatic ecologist for Stillwater Sciences, answered that such an analysis was outside the scope of the review. But, he said, “it is worth noting that the population of coho salmon that exist in the Lagunitas Creek watershed is doing better than most other coho salmon populations along the coast of California.”


A 45-day comment period ends June 15, following which the Community Development Agency will prepare a final S.E.I.R. to submit to the Board of Supervisors for certification.