Santa Rosa City Council
September 24, 2024

Roseland Creek
Community Park
Correspondence
Attachment 3
State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director Bay Delta Region
2825 Cordelia Road, Suite 100
Fairfield, CA 94534
(707) 428-2002
www.wildlife.ca.gov
June 10, 2024
Jen Santos, Deputy Director – Parks
City of Santa Rosa
55 Stony Point Road
Santa Rosa, CA 95401
[email protected]
Subject: Roseland Creek Community Park Master Plan, Environmental Impact Report, SCH No. 2022080148, Sonoma County
Dear Ms. Santos:

The California Department of Fish and Wildlife (CDFW) received a Notice of Intent to Adopt an Environmental Impact Report (EIR) from the City of Santa Rosa (City) for the Roseland Creek Community Park Master Plan (project) pursuant the California Environmental Quality Act (CEQA) and CEQA Guidelines.1 CDFW previously submitted a letter dated September 7, 2022 in response to the EIR Notice to Preparation (NOP) for the project.

CDFW is submitting comments on the EIR to inform the City, as the Lead Agency, of our concerns regarding potentially significant impacts to biological resources associated with the project.

CDFW ROLE
CDFW is a Trustee Agency with responsibility under CEQA (Pub. Resources Code, § 21000 et seq.) pursuant to CEQA Guidelines section 15386 for commenting on projects that could impact fish, plant, and wildlife resources. CDFW is also considered a Responsible Agency if a project would require discretionary approval, such as permits issued under the California Endangered Species Act (CESA), Lake and Streambed Alteration (LSA) Program, or other provisions of the Fish and Game Code that afford protection to the state’s fish and wildlife trust resources.

PROJECT DESCRIPTION SUMMARY
Proponent: City of Santa Rosa
Objective: The project proposes to construct a new community park to serve the Roseland neighborhood. Trails, interpretive signs, and upland habitat restoration in 1 CEQA is codified in the California Public Resources Code in section 21000 et seq. The “CEQA Guidelines” are found in Title 14 of the California Code of Regulations, commencing with section 15000.

DocuSign Envelope ID: 100AA621-EC8D-4DB5-A207-90E654CB80C2 Jen Santos
City of Santa Rosa
June 10, 2024

existing grasslands are proposed for the northern section of the park. The central portion of the project site contains the oak (Quercus sp.) woodland habitat, which would be left intact and would also contain trails and interpretive signs. A nature center and restroom building would be constructed near the parking lot on the west side of the park, north of Roseland Creek. A picnic area and outdoor classroom or community garden would be located along the northern side of the riparian corridor along Roseland Creek at the edge of the oak woodland. On the south side of the riparian corridor, there would be a restroom near the parking lot, picnic areas (including single-use BBQs), a nature-themed play area, a lawn area, and sports court. A trail surrounding the lawn and play areas would include fitness stations. The existing purple needlegrass (Stipa pulchra) grassland area near the southeast corner of the site would be preserved, with trails encircling it. The site currently consists of primarily undeveloped land. Habitat on- site consists of annual grasslands, oak and riparian woodlands, and Roseland Creek.

Location: The 19.49-acre project site is located at 1027 McMinn Avenue, and 1360, 1370 and 1400 Burbank Avenue (Assessor’s Parcel Numbers 125-331-001, 125-252- 003, 125-252-002, and 125-252-004) in the City of Santa Rosa and in Section 27, Township 7 North, Range 8 West of the Mount Diablo Meridian U.S. Geological Survey

7.5’ quadrangle map, at approximately Latitude 38.423440°N, Longitude 122.733154°W.

REGULATORY REQUIREMENTS
California Endangered Species Act
Please be advised that a CESA Incidental Take Permit (ITP) must be obtained if the project has the potential to result in “take” of plants or animals listed under CESA, either during construction or over the life of the project. As indicated in CDFW’s NOP response letter and further described below, the project has the potential to result in take of California tiger salamander (Ambystoma californiense), which is CESA listed as threatened species, and Sonoma sunshine (Blennosperma bakeri), Sebastopol meadowfoam (Limanthes vinculans), and Burke’s goldfields (Lasthenia burkei), which are CESA listed as endangered species. Issuance of a CESA ITP is subject to CEQA documentation; the CEQA document must specify impacts, mitigation measures, and a mitigation monitoring and reporting program. If the project will impact CESA listed species, early consultation is encouraged, as significant modification to the project and mitigation measures may be required in order to obtain a CESA ITP.

CEQA requires a Mandatory Finding of Significance if a project is likely to substantially restrict the range or reduce the population of a threatened or endangered species. (Pub.

Resources Code, §§ 21001, subd. (c) & 21083; CEQA Guidelines, §§ 15380, 15064, & 15065). Impacts must be avoided or mitigated to less-than-significant levels unless the DocuSign Envelope ID: 100AA621-EC8D-4DB5-A207-90E654CB80C2 Jen Santos
City of Santa Rosa
June 10, 2024

CEQA Lead Agency makes and supports Findings of Overriding Consideration (FOC).

The CEQA Lead Agency’s FOC does not eliminate the project proponent’s obligation to comply with CESA.

Lake and Streambed Alteration
An LSA Notification, pursuant to Fish and Game Code section 1600 et seq., is required for project activities affecting lakes or streams and associated riparian habitat.

Notification is required for any activity that may substantially divert or obstruct the natural flow; change or use material from the bed, channel, or bank including associated riparian or wetland resources; or deposit or dispose of material where it may pass into a river, lake or stream. Work within ephemeral streams, washes, watercourses with a subsurface flow, and floodplains are subject to notification requirements. CDFW will consider the CEQA document for the project and may issue an LSA Agreement. CDFW may not execute the final LSA Agreement (or ITP) until it has complied with CEQA as a Responsible Agency. Thank you for including the requirement of an LSA Agreement as a mitigation measure in the EIR.

COMMENTS AND RECOMMENDATIONS
CDFW offers the comments and recommendations below to assist the City in adequately identifying and/or mitigating the project’s significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources. Attachment 1 includes a Draft Mitigation Monitoring and Reporting Program for CDFW’s recommended mitigation measures.

I. Mandatory Findings of Significance: Does the project have the potential to substantially reduce the number or restrict the range of a rare or endangered plant or animal?
COMMENT 1: Page 42-43, Environmental Setting and Related Impact Shortcoming Issue: The EIR indicates that wetlands are present within the project site. Wetlands in the Santa Rosa Plain may support Sonoma sunshine, Sebastopol meadowfoam, and Burke’s goldfields. Sebastopol meadowfoam has been documented one mile southwest of the project site (California Natural Diversity Database [CNDDB] Occurrence Number 1).

As noted in CDFW’s NOP response letter, the Santa Rosa Plain Conservation Strategy, Appendix D: Guidelines for Conducting and Reporting Botanical Inventories for Federally Listed Plants on the Santa Rosa Plain (https://www.fws.gov/library/collections/santa-rosa-plain-conservation-strategy) and CDFW’s 2018 Protocols for Surveying and Evaluating Impacts to Special-Status Native Plant Populations and Sensitive Natural Communities DocuSign Envelope ID: 100AA621-EC8D-4DB5-A207-90E654CB80C2 Jen Santos
City of Santa Rosa
June 10, 2024

(https://wildlife.ca.gov/Conservation/Survey-Protocols#377281280-plants) provide guidelines for acceptable survey documentation for protocol-level surveys for CESA and federally listed plants on the Santa Rosa Plain. According to the EIR, protocol- level surveys were conducted in March, April, and May 2018, and one follow-up site visit in May 2022, with negative results. However, the above Santa Rosa Plain Conservation Strategy (Strategy) protocols require two years of surveys with a minimum of three visits during the growing season per year to be considered valid.

Only one site visit was made during 2022, therefore this survey may not be considered valid. In addition, survey reports were not included with the EIR so it is unclear if all elements of the survey were completed in conformance with the above protocols.

Specific impacts and why they may occur and be significant: Sonoma sunshine, Sebastopol meadowfoam, and Burke’s goldfields are CESA and federally listed as endangered species. These species may be directly or indirectly impacted by the project, and due to inadequate surveys, they may be present on-site but remain undetected resulting in mortality of individuals or indirect impacts from degradation of habitat adjacent to ground disturbance due to altering hydrological conditions or other factors. Sonoma sunshine, Sebastopol meadowfoam, and Burke’s goldfields are considered endangered under CEQA pursuant to CEQA Guidelines section 15380. Therefore, if these species are present on or adjacent to the project site where they would be directly or indirectly impacted, the project may substantially reduce the number or restrict the range of these species, which would be a mandatory finding of significance pursuant to CEQA Guidelines section 15065, subdivision (a)(1).

Recommended Mitigation Measure: For an adequate environmental setting, to comply with CESA and the federal Endangered Species Act (ESA), and to reduce impacts to Sonoma sunshine, Sebastopol meadowfoam, and Burke’s goldfields to less-than-significant, CDFW recommends including the following mitigation measure in the EIR.

MM-BIO-1. The project shall submit to CDFW two years of completed botanical survey results and obtain CDFW’s written approval of the results prior to project construction. The botanical survey results shall follow CDFW’s 2018 Protocols for Surveying and Evaluating Impacts to Special-Status Native Plant Populations and Sensitive Natural Communities (https://wildlife.ca.gov/Conservation/Survey- Protocols#377281280-plants) and the Santa Rosa Plain Conservation Strategy, Appendix D: Guidelines for Conducting and Reporting Botanical Inventories for Federally Listed Plants on the Santa Rosa Plain
(https://www.fws.gov/library/collections/santa-rosa-plain-conservation-strategy). If CDFW is unable to accept the survey results, the project shall conduct additional surveys prior to initiation of project activities or may assume presence of Sonoma DocuSign Envelope ID: 100AA621-EC8D-4DB5-A207-90E654CB80C2 Jen Santos
City of Santa Rosa
June 10, 2024

sunshine, Burke’s goldfields, and Sebastopol meadowfoam. Please be advised that for CDFW to accept the results, they should be completed in conformance with CDFW’s 2018 Protocols for Surveying and Evaluating Impacts to Special- Status Native Plant Populations and Sensitive Natural Communities (https://wildlife.ca.gov/Conservation/Survey-Protocols#377281280-plants) and the Santa Rosa Plain Conservation Strategy, Appendix D: Guidelines for Conducting and Reporting Botanical Inventories for Federally Listed Plants on the Santa Rosa Plain (https://www.fws.gov/library/collections/santa-rosa-plain-conservation- strategy), including, but not limited to, conducting surveys during appropriate conditions, utilizing appropriate reference sites, and evaluating all direct and indirect impacts such as altering off-site hydrological conditions where the above species may be present. Surveys conducted during drought conditions may not be acceptable. If the botanical surveys result in the detection of the above CESA listed plants that may be impacted by the project, or the presence of these species is assumed, the project shall obtain a CESA ITP from CDFW prior to construction and comply with all requirements of the ITP. In addition, the project shall consult with the U.S. Fish and Wildlife Service (USFWS) for any impacts to suitable habitat for plants listed under the federal ESA.

COMMENT 2: Page 44-45, Environmental Setting, Mitigation Measure, and Related Impact Shortcoming
Issue: The EIR states that California tiger salamander are unlikely to occur in the annual grasslands and oak woodlands within the project limits. However, several other projects in the immediate vicinity of the project site obtained ITPs for California tiger salamander as described in CDFW’s NOP response letter. In addition, three occurrences of California tiger salamander have been documented within 0.75 mile of the project (CNDDB Occurrence Numbers 11, 62, and 72) and California tiger salamander dispersal to the project site may be possible through the surrounding low-density development.

In addition, the EIR includes MM-BIOc.1-1, which states, “Prior to the commencement of ground disturbing activities, the site shall be inspected for burrows or other refugia that could support CTS. If none are detected, work can proceed without further measures. If burrows or other refugia with potential to support CTS are detected and cannot be avoided, the project shall consult with CDFW to determine if any additional measures, including an incidental take permit, may be required.” The project description is unlikely to feasibly avoid burrows and other upland refugia, especially south of Roseland Creek. In addition, any California tiger salamander may be effectively isolated from breeding and upland habitat by construction of the project, resulting in impacts to the species. Additionally, regardless of the current presence of California tiger salamander, the project would still result in permanent loss and likely temporary loss of suitable California tiger DocuSign Envelope ID: 100AA621-EC8D-4DB5-A207-90E654CB80C2 Jen Santos
City of Santa Rosa
June 10, 2024

salamander habitat, further degrading any potential recovery of this threatened and imperiled species.

Specific impacts and why they may occur and be significant: California tiger salamander may be directly or indirectly impacted by the project resulting in mortality of individuals from direct impacts or indirect impacts from degradation of habitat adjacent to ground disturbance and other factors. Additionally, the project would result in the permanent and likely temporary loss of California tiger salamander habitat. California tiger salamander are considered threatened under CEQA pursuant to CEQA Guidelines section 15380. Therefore, if California tiger salamander are present on or adjacent to the project site where they may be directly or indirectly impacted, or habitat loss occurs, the project may substantially reduce the number or restrict the range of these species, which would be a mandatory finding of significance pursuant to CEQA Guidelines section 15065, subdivision (a)(1).

Recommended Mitigation Measure: For an adequate environmental setting and to reduce impacts to California tiger salamander to less-than-significant and to comply with CESA and federal ESA, CDFW recommends including the following mitigation measure in the EIR.

MM BIO-2. Prior to commencing project construction, the project shall obtain a CESA ITP from CDFW for impacts to California tiger salamander and comply with the ITP. The project shall also obtain authorization from the USFWS for impacts to California tiger salamander and comply with the authorization. The project shall provide habitat compensation for California tiger salamander in accordance with the Strategy, CESA ITP, and USFWS authorization. Please note that the CESA ITP habitat compensation requirements are often consistent with the Strategy but may differ based on current information and site-specific conditions. CDFW staff are available to assist with the ITP process.

ENVIRONMENTAL DATA
CEQA requires that information developed in EIRs and negative declarations be incorporated into a database which may be used to make subsequent or supplemental environmental determinations. (Pub. Resources Code, § 21003, subd. (e).) Accordingly, please report any special-status species and natural communities detected during project surveys to CNDDB. The CNDDB field survey form can be filled out and submitted online at the following link: https://wildlife.ca.gov/Data/CNDDB/Submitting- Data. The types of information reported to CNDDB can be found at the following link:
https://www.wildlife.ca.gov/Data/CNDDB/Plants-and-Animals.

DocuSign Envelope ID: 100AA621-EC8D-4DB5-A207-90E654CB80C2 Jen Santos
City of Santa Rosa
June 10, 2024

ENVIRONMENTAL DOCUMENT FILING FEES
The project, as proposed, would have an impact on fish and/or wildlife, and assessment of environmental document filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the environmental document filing fee is required in order for the underlying project approval to be operative, vested, and final. (See: Cal. Code Regs, tit. 14, § 753.5; Fish & G. Code, § 711.4; Pub. Resources Code, § 21089.).

CONCLUSION
CDFW appreciates the opportunity to comment on the EIR to assist the City in identifying and mitigating project impacts on biological resources.

Questions regarding this letter or further coordination should be directed to Nick Wagner, Senior Environmental Scientist (Specialist) at (707) 428-2075 or [email protected]; or Melanie Day, Senior Environmental Scientist (Supervisory) at (707) 210-4415 or [email protected].

Sincerely,
Erin Chappell
Regional Manager
Bay Delta Region
Attachment 1: Draft Mitigation Monitoring and Reporting Program ec: Office of Planning and Research, State Clearinghouse (SCH No. 2022080148) Vincent Griego, USFWS - [email protected]
DocuSign Envelope ID: 100AA621-EC8D-4DB5-A207-90E654CB80C2

Jen Santos
City of Santa Rosa
June 10, 2024

ATTACHMENT 1
Draft Mitigation Monitoring and Reporting Program
Biological Resources (BIO)
Mitigation Measure (MM) Description Implementation
Schedule
Responsible
Party
MM-BIO-1. The project shall submit to CDFW two years of completed botanical survey results and obtain CDFW’s written approval of the results prior to project construction. The botanical survey results shall follow CDFW’s 2018 Protocols for Surveying and Evaluating Impacts to Special-Status Native Plant Populations and Sensitive Natural Communities
(https://wildlife.ca.gov/Conservation/Survey-
Protocols#377281280-plants) and the Santa Rosa Plain
Conservation Strategy, Appendix D: Guidelines for Conducting and Reporting Botanical Inventories for Federally Listed Plants on the Santa Rosa Plain
(https://www.fws.gov/library/collections/santa-rosa-plain- conservation-strategy). If CDFW is unable to accept the survey results, the project shall conduct additional surveys prior to initiation of project activities or may assume presence of Sonoma sunshine, Burke’s goldfields, and Sebastopol
meadowfoam. Please be advised that for CDFW to accept the results, they should be completed in conformance with CDFW’s 2018 Protocols for Surveying and Evaluating Impacts to
Special-Status Native Plant Populations and Sensitive Natural Communities (https://wildlife.ca.gov/Conservation/Survey- Protocols#377281280-plants) and the Santa Rosa Plain
Conservation Strategy, Appendix D: Guidelines for Conducting and Reporting Botanical Inventories for Federally Listed Plants on the Santa Rosa Plain
(https://www.fws.gov/library/collections/santa-rosa-plain- conservation-strategy), including, but not limited to, conducting surveys during appropriate conditions, utilizing appropriate reference sites, and evaluating all direct and indirect impacts such as altering off-site hydrological conditions where the above species may be present. Surveys conducted during
drought conditions may not be acceptable. If the botanical surveys result in the detection of the above CESA listed plants that may be impacted by the project, or the presence of these species is assumed, the project shall obtain a CESA ITP from CDFW prior to construction and comply with all requirements of the ITP. In addition, the project shall consult with the USFWS for any impacts to suitable habitat for plants listed under the federal ESA.

Prior to ground
disturbance
Project
Applicant
DocuSign Envelope ID: 100AA621-EC8D-4DB5-A207-90E654CB80C2 Jen Santos
City of Santa Rosa
June 10, 2024

MM BIO-2. Prior to commencing project construction, the project shall obtain a CESA ITP from CDFW for impacts to California tiger salamander and comply with the ITP. The project shall also obtain authorization from the USFWS for impacts to California tiger salamander and comply with the authorization. The project shall also provide habitat
compensation for California tiger salamander in accordance with the Strategy, CESA ITP, and USFWS authorization.

Please note that the CESA ITP habitat compensation
requirements are often consistent with the Strategy but may differ based on current information and site-specific conditions.

CDFW staff are available to assist with the ITP process.

Prior to ground
disturbance
Project
Applicant
DocuSign Envelope ID: 100AA621-EC8D-4DB5-A207-90E654CB80C2 From: Brenda L. Tomaras <[email protected]>
Sent: Thursday, May 23, 2024 9:06 AM
To: Santos, Jen <[email protected]>
Subject: [EXTERNAL] RE: Roseland Creek Community Park DEIR G
ood Morning Jen,
F
irst, Lytton would like to thank the City for accepting its suggested revisions to the mitigation measures. I think it points to the good working relationship between the Tribe and the City. The only concern Lytton has is regard to the discussion portion to indicates that there will be collection and evaluation of any finds on site. Many tribes, including Lytton, do not want testing done on artifacts and in fact, would prefer that the items be reburied on the site. This is especially true for items that are conserved sacred or ceremonial. The onsite monitors are there to provide such crucial cultural information.

T
hank you.

Brenda L. Tomaras
Tomaras & Ogas, LLP
10755-F Scripps Poway Parkway #281
San Diego, CA 92131
(858) 554-0 550
(858) 583-3 482 Mobile
(858) 777-5 765 Facsimile
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it is confidential and may be legally privileged. If you are not the intended recipient or authorized agent for the intended recipient, you have received this message and attachments in error, and any review, dissemination, or reproduction is strictly prohibited. If you are not the intended recipient, please immediately notify us by reply e-mail or by telephone at (858) 554-0550, and destroy the original transmission and its attachments without reading them or saving them. Failure to follow this process may be unlawful.

From: Ana Munoz
Sent: M onday, June 10, 2024 10:42 PM
To: Santos, Jen <[email protected]>
Subject: [EXTERNAL] Environmental impact report for Roseland Creek Park Greetings Ms. Santos.

My name is Ana Munoz, I live near the Park being discussed and I have a few comments.

I have owned my house since 2011 and since I moved into the area there has been a constant desire first by the county of Sonoma and now the City of Santa Rosa to develop the park beyond what it is today. No doubt that the City will benefit financially by developing the park fully with restrooms, parking lots, paved walks, BBQ pits and playground, we know that when a grant is received, a good portion of the funds are destined for the City's use.

The City is not going to stop trying to push the development of the park until they get it, I have atended multiple meetings and every time there are meetings, public input, and manipulation of the desire of the people who are impacted by the development. I understand that my comments will fall in deaf ears because there is a conflict of interest.

However, the city will make a great mistake by destroying the existing park. Every time we have had meetings there is overwhelming desire to keep the park in its natural state. All it needs is a small budget to have quarterly paths' maintenance and grass mowing. Perhaps adding more native trees and shrubs and cleaning the creek to prevent mosquitoes.

Children play in the park and enjoy it as is. If we want playgrounds we have several within a mile radius. Rather than destroying the natural state of the park perhaps improving traffic flow from the 5 or more elementary schools in the immediate vicinity will make us happier since we don't have to have gridlock from parents driving children to and from school and making it impossible for the general public to conduct business.

Building sanitation facilities will bring vagrants and criminal activity to an area that is relatively calm and introducing vices to our young children.

For the past 12 years I have said to maintain the park as a nature park without infrastructure.

We have several parks withing walking distance with what you want to add to this park. Save the money and improve and maintain what we have, make them child and families friendly.

We want our children to have parks that are safe free of criminal activity.

This park is unique in its natural state with the creek habitat and native trees and fauna. improve what is there do not create another concrete disaster.

Thanks,
Ana Munoz

California Wildlife Foundation/California Oaks, 201 University Avenue, H-43 Berkeley, CA 94710, (510) 763-0282 May 30, 2024
Jen Santos, Deputy Director, Parks
Recreation and Parks Department
100 Santa Rosa Avenue
Santa Rosa, CA 95404
Transmitted via e-mail: [email protected]
Re: Roseland Creek Community Park Master Plan Draft Environmental Impact Report, SCH No. 2022080148
Dear Ms. Santos:

The California Oaks program of the California Wildlife Foundation works to conserve oak ecosystems because of their critical role in sequestering carbon, maintaining healthy watersheds, providing plant and wildlife habitat, and sustaining cultural values. California Wildlife Foundation/California Oaks (CWF/CO) is writing about deficiencies of and problems with the Roseland Creek Community Park Master Plan Draft Environmental Impact Report (DEIR). This letter was prepared at the request of the Milo Baker Chapter of California Native Plant Society.

California Native Plant Society is a member of California Oaks Coalition, which brings together 80 international, national, Tribal, state, regional, and local organizations to conserve and perpetuate the state’s primary old-growth resource.

The park’s design should protect the beauty, shade, habitat, flood protection, and carbon sequestration and cultural values of the land’s oaks. These trees enhance the livability of surrounding communities by lowering air and soil temperatures, providing cooling shade, improving air and water quality, and providing a restorative natural environment in an area of Santa Rosa where natural areas are deficient.

Improvements to lands protected by a conservation easement should be protective of oaks.

Appendix C of the DEIR, Section 3.3, Tree Impact Assessment, discusses the Oak Protection Area that is part of the conservation easement for 1400 Burbank Avenue, and the easement’s provisions for low-intensity recreational and educational uses. The proposed removal of heritage valley oaks for trail alignment and paving would degrade the beauty, shade, habitat, flood protection, and cultural and carbon sequestration values that should be protected by the easement. Heritage oaks also provide seedlings for future oaks in this area, which if removed, would materially impair or interfere with the conservation values that are to be protected under the conservation easement. All trails should be designed to keep heritage trees standing. The DEIR is deficient in addressing this violation of the conservation easement. The conservation easement 3.0 (b) Statement of Purpose states, “Protect and preserve the natural resources of the property, including its riparian corridor and oak savanna” The conservation easement also “prohibits and prevents any use of the property that will materially impair or interfere with the conservation values of the property.” All trails should be developed to go around heritage trees and to protect their root systems. 2 Significant trimming of valley oak tree #106, which is growing in the site’s valley oak woodland, should not be carried out. Significant trimming is harmful to oak trees. (CWF/CO refers you to page four of Care of California’s Native Oaks, which has a section on oak pruning.) The proposed action would damage the ecological importance and sensitivity of valley oak woodland. As a State Ranked 3 community, valley oak woodland is classified as vulnerable due to a restricted range, relatively few populations, recent and widespread declines, or other factors making it vulnerable to extirpation. The proposed significant trimming of tree #106 should not occur.

The proposed removal of four heritage trees and construction impacts on an additional 18 heritage trees are also in violation of the Department of Parks and Recreation’s mission. The discussion, in Section 5.0, Summary and Recommendations, of the potential removal of four heritage trees and potential impacts on an additional 18 heritage trees from trail alignment and paving also runs counter to the mission of the Department of Parks and Recreation. Specifically, the destruction of the site’s mature and protected trees is a dereliction of the department’s duty to uphold the mission of “protecting environmental resources and promoting health and wellness.” An art museum would not destroy its most important artworks as part of its “improvements.” Similarly, Roseland Creek Community Park should not destroy its heritage oaks.

Section D (6) of Section 17-24.050 of the City of Santa Rosa’s Tree Protection Ordinance states that “No compaction of the soil within the root zone of protected trees shall occur.” The root protection area, which is half again as large as the area from the trunk to the dripline of an oak, is critical to oak tree health. More detail can be found in the above-referenced Care of California’s Native Oaks, which includes sections on paving and other construction activities.

Mitigation for oak impacts is inadequate. The project should protect the oaks and the City of Santa Rosa should amend oak protections and mitigation requirements to reflect the tree’s cultural values and importance in combatting the heat island effect, sequestering carbon, supporting biodiversity, protecting the watershed, and providing access to nature in the city. Trees that are impacted by the project should be replaced at a level that will offset the lost biomass and canopy of the removed trees and the substantial temporal loss of growth habitat structure and diversity.

The project, as currently conceived, should not be advanced. Thank you for your consideration of our comments.

Sincerely,
Janet Cobb Angela Moskow
Executive Officer, California Wildlife Foundation California Oaks Program Director [email protected] [email protected] cc: Milo Baker Chapter of California Native Plant Society The Honorable members of the Santa Rosa City Council, c/o Dina Manis, City Clerk, [email protected]

1 Roseland Creek Community Park
CNPS Milo Baker Chapter Comments 5/31/2024
Jen Santos, Deputy Director – Parks
[email protected]
RE: Roseland Community Park Draft Environmental Impact Report (DEIR) The Milo Baker Chapter of the California Native Plant Society (CNPS) is providing the City of Santa Rosa with these comments on the proposed April 2024 Roseland Neighborhood Park Draft Environmental Impact Report (DEIR). The Milo Baker Chapter is the Sonoma County representative of the California Native Plant Society, and our mission is to “Conserve California native plants and their natural habitats, and increase understanding, appreciation, and horticultural use of native plants.” Our members have been involved in the park planning process by attending the public meetings, providing written feedback, and visiting the site to educate local schools about the plants, habitats, and overall ecology that is present on this proposed park property.

This property has many different habitats that are in the process of natural regeneration but require some restoration actions to return the natural ecosystem functions. We greatly appreciate that the City will preserve many of the natural areas including the rare purple needlegrass grassland, the northern meadow, the oak woodland, and the habitat adjacent to Roseland Creek. We also appreciate the nature center and interpretive signs because these park elements are in alignment with the Native Plant Society’s mission and would support the community’s understanding and appreciation of the natural features present in this proposed park.

The following comments, both general in nature and specific to DEIR, are in aid to ensure restoration, enhancement and education within this jewel of a City park.

The EIR did not reflect the need for the restoration of Roseland Creek and the need to remove the approximately 400 linear feet of channelized and, in some areas, concrete in the creek and to make the creek more climate change resistant.

As we wrote previously in 2020, restoration of Roseland Creek should be addressed as part of the park plan. While the City has a Citywide Creek Masterplan (CCMP) that envisions restoration of this creek and the community has presented a more detailed vision of creek restoration, nothing was written in the DEIR addressing this issue. Roseland Creek’s headwaters are located at the Railroad tracks near West Barham Avenue where the creek passes through private parcels in Roseland for three blocks before passing under McMinn Avenue entering proposed park property. This is the most natural upstream area of the creek and restoration, and preservation of the creek would create excellent native plant and wildlife habitat. Downstream of the park, the creek passes through open space and protected habitats and a creek trail is partially built and planned to connect near the confluence of Roseland Creek and the Laguna de Santa Rosa just west of Llano Road. Creeks can serve as a habitat corridor that would connect the open space of the Laguna with the residents in Roseland. Habitat corridors are defined as natural areas that allow animals to move throughout areas and get much-needed habitat. Intact riparian habitat supports many bird and wildlife species that enrich our lives. A restoration plan should be included in the DEIR as part of the planning process.

The EIR did not cite the 2014 CCMP Appendix C Roseland Creek Restoration Plan and state how the park Master Plan will incorporate the Restoration needs of Roseland Creek.

The CCMP identifies the following: “Construct a self-maintaining channel with adequate bank-full dimensions to transport sediment, contain healthy riparian vegetation and convey the 100 -year flood.”

2 Roseland Creek Community Park
CNPS Milo Baker Chapter Comments 5/31/2024
This should be addressed before construction of any Creekside amenities. The Roseland Creek Master plan cites the following Santa Rosa General Plan Policies:

OSC-D-7 Rehabilitate existing channelized waterways, as feasible, to remove concrete linings and allow for a connection between the stream channel and the natural water table. Avoid creating additional channelized waterways, unless no other alternative is available to protect human health, safety, and welfare.

OSC-D-8 Restore channelized waterways to a more natural condition which allows for more natural hydraulic functioning, including development of meanders, pools, rifles, and other stream features. Restoration should also allow for growth of riparian vegetation which effectively stabilizes banks, screens pollutants from runoff entering the channel, enhances fisheries, and provides other opportunities for natural habitat restoration There is no discussion in the DEIR that these policies will be implemented for this park. One of the logical areas for the creek restoration is where the community garden area is proposed. The drawing incorrectly depicts riparian habitat along the northside of the creek where there currently is no riparian habitat.

The DEIR did not address invasive species removal.

The Roseland Creek Master Plan identified many moderate to highly invasive species that need to be removed prior to creation of park amenities. These species include Himalayan blackberry (Rubus armeniacus), cherry plum (Prunus cerasifera), hawthorn (Crataegus monogyna), woolly cotoneaster (Cotoneaster pannosus), harding grass (Phalaris aquatica), Mediterranen barley (Hordeum marinum ssp. gussoneanum), reed fescue (Festuca arundinacea), ripgut brome (Bromus diandrus), slim oat (Avena barbata), French broom (Genista monsessulana), Indian teasel (Dipsacus sativus), hairy cat’s ear (Hypochaeris radicata), Italian thistle (Carduus pycnocephalus ssp. pynocephalus), periwinkle (Vinca major), fennel (Foeniculum vulgare), poison hemlock (Conium maculatum). A discussion of invasive species removal should be presented as part of the park plan.

The DEIR does not show a crosswalk on Burbank Avenue for the bike trail on the southside of Roseland Creek.

There is only one crossing of Burbank Avenue and it is shown to be in the northern portion of the park. If the southern trail is to be part of the Santa Rosa Bicycle and Pedestrian Master Plan, then a crosswalk is needed in this portion of the park to connect to the west side of Burbank Avenue and downstream on Roseland Creek. There are no crosswalks on the east side of Burbank Avenue. Page 10 states, “…fencing that will function as a natural barrier between vehicles and pedestrians traveling adjacent to Burbank Avenue and to help guide students to the future street crossing.” The proposed crosswalk in the northern portion of the park, as proposed, will connect into the existing bus stop pullout lane. This should be changed to have the crossing tie into the existing sidewalk areas.

The proposed multi-use trails are too wide.

The DEIR states (page 4) “The proposed multi-use trail creek crossing would be a prefabricated bridge placed on abutments outside the top of bank. The multi–use trail meanders through the oak woodland habitat area in the center of the site and connects to McMinn Avenue. The trail wo uld be a paved 10-foot- wide path with two-foot-wide gravel shoulders on either side, providing ADA access.” Sidewalks on Burbank Avenue are not 10 feet wide, and, in some areas, they are no more than 2 feet wide, and are adjacent to the busy road of Burbank Avenue. We feel that 10-foot-wide paved trails with an additional 2 feet on either side is excessive. We recommend that 8-foot-wide trails with 1 foot gravel shoulders on either side is appropriate and are within the ADA parameters identified by the City of Santa Rosa. Emergency vehicles will still have access along this width of trail. 3 Roseland Creek Community Park
CNPS Milo Baker Chapter Comments 5/31/2024
Park improvements shall not result in impervious surfaces of more than 20 percent on the entire parcel of the park, not just 1400 Burbank Avenue property, as stated on page 5.

The Conservation Easement should not be piecemealed and should be rewritten to include the entire 20 acres under a single easement. The parameters of the easement should be standard for all of the park parcel and include impervious surfaces of no more than 20 percent.

Specific changes to DEIR
Bio Impact 1a (pages iv, page 63) – seasonality for bats Bat seasonal dates in this area are (approximately) the following:

Maternity – April 15 – August 31
Winter Hibernation - October 15 to February 28
Therefore, if work is to be conducted in areas that may support roosting bats, and occupancy is assumed, habitat removal must be conducted between March 1 and April 15 OR August 31 and October 15 . To prove absence, then one to two nocturnal surveys with appropriate night vision equipment must be conducted during those times when bats would be occupying a roost (i.e., during the maternity season). If negative findings occur, then habitat can be removed. However, if bats are present then removal must occur during the above stated times, between March 1 and April 15 OR August 31 and October 15. This would also tie in with protection measures for nesting birds.

Figure 2.2-3 Aerial Photo from 2018.

This figure should be updated to reflect the residential development on the south side of the park. There is a single parcel that is not developed but the parcel to the south at 1690 Burbank Avenue is currently under construction with 62 single family homes and 64 apartments and should be classified as residential and not rural residential.

Revise Appendix A Figure 4. Special Status Wildlife Documented within 5 miles of the Project Area.

The legend identifies plants and not wildlife species. In addition, the plants presented in the legend (alkali milkvetch, brittlescale, California alkali grass, etc.) do not occur in Sonoma County. Revise this Figure to reflect special status wildlife species reported in the area.

We feel that once the above comments, both general in nature and specific to the DEIR, are addressed and answered then the actions to ensure restoration, conservation and education within this jewel of a City park will be met.

Sincerely,
Trish Tatarian
Conservation Chair,
Milo Baker Chapter CNPS

1 Roseland Creek Community Park
CNPS Milo Baker Chapter Education Comments 6/17/2024
Jen Santos, Deputy Director Parks - [email protected]
Honorable Members of the Santa Rosa City Council c/o Dina Manis, City Clerk - [email protected] RE: Roseland Community Park Draft Environmental Impact Report (DEIR) The California Native Plant Society (CNPS) is a science based, State-wide organization with chapters in most California counties and one in Baja, California. Our State offices are located in Sacramento. The mission of CNPS is the conservation of California’s diverse native plants and related ecosystems. We also work to increase understanding and appreciation of California's biodiversity as well as encourage horticultural use of California native plants in both private and public settings.

Members of our Education committee helped identify and speak with faculty at various Roseland District schools. All the schools expressed considerable interest in the prospect of a readily accessible outdoor classroom, a living learning landscape, within walking distance of their schools. Roseland Creek Community Park also known locally as the NeighborWood became an outdoor classroom for tw o teachers from Roseland University Prep High School prior to the pandemic. This unique 20 -acre gem of a park was used on several occasions for projects involving biology and language arts. The students from the language arts class ultimately created a video about the park.

Our then District Supervisor, Linda Hopkins, referred to the land as a "micro wilderness". Very few fast- growing urban cities possess this type of readily accessible resource representing a multitude of public benefits including those of physical/mental health, social and community cohesiveness. National and world-wide studies have documented these benefits, particularly to people residing in economically distressed neighborhoods.

Our local CNPS chapter Conservation Committee Chair, retired wildlife consulting biologist, Trish Tatarian, BSc, MSc, and the Directors of The California Wildlife Foundation/California Oaks Program have provided comments regarding numerous flaws and omissions in the recent DEIR for Roseland Creek Community Park. We, too, have concerns which include the following:

1. The DEIR omitted any plans for the restoration of the section of Roseland Creek running through the Park.

Roseland Creek feeds into the Laguna de Santa Rosa and subsequently the Russian River, a major source of drinking water for County residents. There is no discussion of restoration of the natural channel including removing the concrete lining a portion of the channelized. Creek. Restoration of this portion of the creek will allow safe passage of wildlife to and from the Laguna in a restored and healthy wildlife corridor.

Healthy riparian corridors help with flood control, ground water filtration and recharge, enhance and protect biodiversity. Riparian corridors possess an unusually diverse array of plant and animal species and provide critical environmental functions. They play an essential role in moving water to local aquifers aquifers, filtering toxic materials from water via percolation through not included any of humus enriched soils, slowing flood waters with meanders, riffles and sand bars. Healthy riparian corridors with strong, well established root systems help prevent stream bank erosion.

The current DEIR did not include any mention of the 2014, appendix c, Restoration Plan or any mention of how the Park Master Plan will incorporate the critical needs of Roseland Creek , despite the

2 Roseland Creek Community Park
CNPS Milo Baker Chapter Education Comments 6/17/2024
identification of OSC - D-7 (Rehabilitate existing channelized waterways...) and OSC - D-8 (Restore waterways to a more natural condition...).

The Citywide Creek Master Plan states "... construct a self-maintaining channel with full-bank dimensions to transport sediments, containing healthy riparian vegetation and convey the 100 year flood waters." These issues need to be identified and addressed before construction of any creekside amenities.

There is no discussion in the DEIR that the above policies will be implemented in this Park. One of the logical areas for Creek restoration is where the community garden is proposed. The related drawing incorrectly identified riparian habitat on the North side of the creek where none actually exists.

2. The current DEIR does not address invasive species removal.

The Roseland Creek Master Plan identified many moderate to highly invasive plants species needing removal prior to creation of proposed Park amenities. Other comment letters provide detailed lists of these plants. A discussion of the non-chemical removal of invasive plant species should be included as part of the park plan.

Both restoration and invasive plants species removal present a unique opportunity for the inclusion of Roseland's culturally diverse residents in an Eco-Cultural model of community land stewardship. Families and individuals would have the opportunity to explore and share the histories of both invasive plant species as well as native plants, their cultural history and uses. Demonstrations, workshops, tastings, arts and crafts uses can be shared and explored as a way of drawing our diverse community together with a shared purpose. Indigenous folks, Latino, African American, Eritrean and other groups will be able to share in the literal "tending of a Park wide wild garden", a concept embraced today as well as for thousands ofyears by California's first peoples.

All these activities would help participants restore their connection to the land as well as develop a true sense of 'place' resulting in pride, connections to community and land.

Several local organizations including CNPS, the Laguna Foundation, Sonoma Ecology Center, Point Blue's STRAW program have These skilled staff and volunteers in the areas of invasives removal, native plant propagation and restoration. These groups could work with Parks and Recreation and local residents to effect a community program of invasive plants removal and restoration. The existing native species in the Park would have the space to grow and expand in this unique place.

3. The current DEIR does not address a controlled crosswalk on Burbank Avenue for the bike/pedestrian trail on the South side of the park.

The only crosswalk shown in the current plan is adjacent to a bus stop pull out at the North end of the Park. There are few sidewalks on Burbank Avenue. Originally classified as a "rural residential" road, Burbank has become an alternate commuter route with excessive speeding problems now exacerbated by increased traffic resulting from substantial new housing development in the Roseland area. The current plan needs to be reconsidered.

4. The proposed multiple use Park trails are wider than need be and will cause soil compaction, severe water runoff and damage to trees and plants.

Ten-foot-wide trails with two feet of gravel shoulder on each side is excessive. Eight foot wide trails with one foot gravel shoulders would comply with ADA requirements and will still provide access for emergency and maintenance vehicles. Paving materials should be permeable to allow water runoff to percolate into the soils. A good example of permeable paving can be seen in the large parking lot located at the rear of the SRJC Petaluma Campus. The original conservation easement for the Park calls for no more than 20 percent impermeable paving. The conservation easement should be consistent throughout the park, not piecemealed.
3 Roseland Creek Community Park
CNPS Milo Baker Chapter Education Comments 6/17/2024

5. Removal of heritage oaks for park amenities is not appropriate for this park.

California's native oak woodlands are among the richest and most diverse of our ecosystems. The oak woodland/savannah supports more life forms than any other tree genus in California. Our native oaks sustain an incredibly complex web of life above and below ground including thousands of needed insects, hundreds of bird, reptile, amphibian and mammal species. Our oaks and plant species that live in native oak ecosystems are literally champions of carbon sequestration, soil stabilization and soil management.

They provide all of us clean air and water, cooler air and soil temperatures, numerous pollinators for our gardens. The design of Roseland Creek Community Park should protect the shade, beauty, rich habitat, flood protection, carbon sequestration and cultural values of these oaks. Our native oaks enhance the biodiversity of the area. Our native oak ecosystems enhance the live ability of surrounding communities by lowering air and soil temperatures, improving air and water quality and providing a restorative natural environment. In this area of Santa Rosa, fast growing and low income, there is an obvious lack of natural areas easily accessible/bikeable/walkable. Park amenities should be redesigned to avoid all heritage oaks.

We fully concur with and support the comments/suggestions made by Janet Cobb, Executive Officer of the California Wildlife Foundation and Angela Moskow, California Oaks Program Director in their comments letter of May 30, 2024. Topics covered included the following:

A. Improvements to lands protected by a conservation easement should be protective of oaks .

B. Significant trimming of valley oak #106 should not be carried out.

C. The proposed removal of four heritage trees are also in violation of the Department of Parks and Recreation's mission.

D. Mitigation for oak pacts is inadequate.

E. This project as currently conceived should not be advanced.

We appreciate the opportunity to submit constructive comments regarding the current DEIR for Roseland Creek Community Park.

Sincerely,
Virginia B. Hotz-Steenhoven,
Certified California Naturalist, retired environmental educator and former Director/Curator, Marin Museum of the American Indian, Miwok Park, Novato
Ca. [email protected]
Catherine Lipson, Ph.D, Education Department Faculty S.F State University [email protected] Co-chairs, Education/Outreach Committee, Milo Baker Chapter, CNPS.

From: David Jarrell
Sent: S unday, May 12, 2024 4:07 PM
To: Santos, Jen <[email protected]>
Subject: [EXTERNAL] Roseland Creek Community Park
Hello Jen,
My name is David Jarrell, as a 30 year resident of the Roseland area it is nice to see we may get a park in our neighborhood. One thing I have not seen
in the plans is a dog park. There are a lot of area residents who walk their dogs daily and many area's lack sidewalks and safety can be an issue. The nearest real dog park is at A Place to Play but the distance means you have to drive there. At 19.49 acres a ½ acre dog park would be easy to include and require minimal maintenance. I don't believe a dog park would affect the Environmental Impact in any measurable way and I feel it would enhance the
overall park greatly.

Thank you for your time, David Jarrell

From: Erika Erzberger
Sent: Thursday, June 13, 2024 12:07 AM
T
o: Santos, Jen <[email protected]>
Subject: [EXTERNAL] Roseland Creek Community Park
Hello Ms Santos,
I am writing to ask that you please prioritize conservation and restoration in your plans for this area. I visited the Roseland Creek Community Park recently for a plant walk and was rewarded by hearing birds, seeing amazing mature oaks, experiencing multiple habitat types, and even seeing a baby turkey (turkey- let? turkey-chick?). I could sense the uniqueness of this wild place within city neighborhoods. With so much concern these days about access to nature and the health benefits conferred by time in nature, this is special resource for the residents of Santa Rosa.

Transforming this pocket of nature into a traditional city park would be a missed opportunity. Please, keep this land free of roads, parking lots, pavement, lawns, and landscaping. This could be a center for indigenous cultural practices, school biology lessons, forest therapy, and of course plant walks.

Thank you for your consideration.

Warmly,
Erika
Board Member, Milo Baker Chapter of CNPS Sonoma County resident

Fred Krueger
June 9, 2024
Jen Santos
Deputy Director Parks
Recreation and Parks Department
[email protected]
Dear Jen Santos,
Thank you for your letter introducing the Draft EIR on the Roseland Creek Park.

This letter is my quick response to the Roseland Creek Park draft Environmental Impact Report and your request for reflection and commentary. I will try and elaborate on these items if I can get this finished this afternoon.

The Draft Report in relation to the local community
This draft Environmental Impact Report is big – over 465 pages long. This includes the formal text, the map reports, the BC Laboratory reports and the memorandum at the end.

Do you think it is reasonable for the City to expect local residents within 45 days (April 25 to June 10) to read through all this material, digest its contents and make our own informed responses in this month and half period? Most of us have full time jobs, sometimes taking up to ten or more hours per day. For most neighbors this is too much to ask.

To express this in more specific terms, Santa Rosa City officials are asking citizens to tour through an average of over 10 pages per day, each day during this response period; digest the implications and develop an informed response back the Santa Rosa Parks and Recreation Dept. This is not fair. In fact you would get much more of a turnout and better citizen awareness, besides being a equitable and just process, if the City would begin with a public introduction to the DEIR along with an oral presentation of the issues and then begin the reflection and commentary on this report. This way you would get a lot more public participation. We are willing, even eager to participate, but citizens need time to process the issues and respond thoughtfully.

Issues that need to be addressed:

Demolition of the footbridge and tree removal on the project site See: Impact BIO-1a: Demolition of the footbridge and tree removal on the project site could potentially impact special-status bat species that may use them as a roost, and could result in the direct removal, abandonment, or destruction of the maternity roost.

Why is there consideration of tree removal in what is supposed to be a nature park? Park policy should be to preserve as many trees as possible. They suppress noise, set up a quieting atmosphere and sequester carbon dioxide which is a stated policy of the City of Santa rosa.

We already know that bats are present in the park as they can be observed right before dark on most evenings. Where they roost is not known but we do have a professional bat biologist in the neighborhood who could help address any issues dealing with bats.

From the perspective of the neighbors, the striving of the park should be to preserve as many trees as possible and have no contingency for tree removal.

The Noise Level as Proposed in the DEIR
See: MM NOI-1.1: “The City’s contractor will develop a construction noise mitigation plan to ensure noise levels would be reduced to 80 dBA Leq at sensitive receptors. The construction noise mitigation plan may incorporate, but would not be limited to, the following best management practices.”
The DEIR proposes noises up to 80 decibels.

This level is way too high. Medical doctors say that this high level is associated with Noise Induced Hearing Loss (NIHL).

NIHL tends to become a risk at around 70 dB. To have this level in a residential neighborhood is dangerous and would be as assault on neighbors and certainly a nuisance. High noise levels are associated with stress, animosity and Loud noise can create physical and psychological stress, reduce productivity, interfere with communication and concentration, and contribute to workplace accidents and injuries by making it difficult to hear warning signals.

Besides, who would bear responsibility for damages to neighbors’ hearing? See website on hearing: https://decibelpro.app/blog/how-loud-is-80-decibels/

See also OSHA statement on the effects of Noise: https://www.osha.gov/noise/health-effects Here is an introduction to the OSHA statement on noise:

Exposure to high levels of noise can cause permanent hearing loss. Neither surgery nor a hearing aid can correct this type of hearing loss. Short term exposure to loud noise can also cause a temporary change in hearing (your ears may feel stuffed up) or a ringing in your ears (tinnitus). These short-term problems may go away within a few minutes or hours after leaving the noise. However, repeated exposures to loud noise can lead to permanent tinnitus and/or hearing loss.

Loud noise can create physical and psychological stress, reduce productivity, interfere with communication and concentration, and contribute to workplace accidents and 2 injuries by making it difficult to hear warning signals. The effects of noise induced hearing loss can be profound, limiting your ability to hear high frequency sounds, understand speech, and seriously impairing your ability to communicate.

Construction Hours
See: MM NOI-1.1: The City’s contractor will develop a construction noise mitigation plan to ensure noise levels would be reduced to 80 dBA Leq at sensitive receptors. * Limit construction hours from 7:00 am to 7:00 pm Mondays through Saturdays, and 10:00 am to 6:00 pm on Sundays and holidays.

Portions of the park adjoin residential areas. Work beginning at 7:00 AM is way too early for a residential area. There is no need to start so early and continue so late into the evening. Please explain why this is proposed for such an early and/or late a time.

Active Use Master Plan Alternative
See: The Active Use Master Plan Alternative assumes a public gathering area with a restroom and shaded pavilion where the former residence at 1027 McMinn Avenue was located. A semi-circular driveway would be provided from Burbank Avenue in front of the nature center and would provide access to a single large parking lot for the nature center and dog park. A group picnic Roseland Creek Community Park Master Plan xi Draft EIR City of Santa Rosa April 2024 area and dog park would be provided behind the nature center on the 1370 Burbank Avenue property. South of Roseland Creek an expanded turf area would be provided with a picnic area along the southern property boundary and a Pomo interpretive area. This Master Plan Alternative would also construct sidewalk along the Burbank Avenue project frontage, on-street parking, and a bike lane.

This paragraph is poorly written and it is not clear exactly what is proposed. Neighbors in this region have spoken clearly and repeatedly on these issues We do not support active sports inside a quiet nature area. This would obviate the goals and requirements of a quiet nature park.

Artificial Turf
Artificial turf within the park would either be a source of toxic material or an unnecessary drain on water supplies.

The Artificial Turf Field Alternative assumes that the proposed multi-use lawn area would be landscaped with artificial turf rather than grass. The Artificial Turf Field Alternative would use less water during operation of the proposed community park.

It should be recognized that most synthetic turf surfaces contain toxic materials. 3 Numerous studies indicate that chemicals identified in artificial turf, include polycyclic aromatic hydrocarbons (PAHs), phthalates (a gender-bending chemical), and per- and polyfluoroalkyl substances (PFAS). These are known carcinogens, neurotoxicants, mutagens, and endocrine disruptors.

Please see the National Institutes of Health report on
“Health Impacts of Artificial Turf: Toxicity Studies, Challenges, and Future Directions” https://www.ncbi.nlm.nih.gov/pmc/articles/PMC10262297/
See the introduction to the statement by the National Institutes of Health. This is an introduction to this issue. The following is only part of the introduction to this issue:
“Many communities around the country are undergoing contentious battles over the installation of artificial turf. Opponents are concerned about exposure to hazardous chemicals leaching from the crumb rubber cushioning fill made of recycled tires, the plastic carpet, and other synthetic components. Numerous studies have shown that chemicals identified in artificial turf, including polycyclic aromatic hydrocarbons (PAHs), phthalates, and per- and polyfluoroalkyl substances (PFAS), are known carcinogens, neurotoxicants, mutagens, and endocrine disruptors. However, few studies have looked directly at health outcomes of exposure to these chemicals in the context of artificial turf. Ecotoxicology studies in invertebrates exposed to crumb rubber have identified risks to organisms whose habitats have been contaminated by artificial turf. Chicken eggs injected with crumb rubber leachate also showed impaired development and endocrine disruption. The only human epidemiology studies conducted related to artificial turf have been highly limited in design, focusing on cancer incidence. In addition, government agencies have begun their own risk assessment studies to aid community decisions.” Besides serious chemical toxicities, synthetic turf has been documented to reach temperatures over 200°F on a 98°F day. Synthetic turf fields are always significantly hotter than natural grass, concrete or asphalt. These higher temperatures put users of turf at risk for skin burns and heat-related illness.

I might note that obvious issues such as this should be spotted or anticipated by City staff and not find their way into a DEIR produced by professional consultants.

Additionally the auto tires used in artifical turf are now widely known to be deadly toxic to trout and other salminoids. Therefore they should be employed anywhere close to Roseland Creek. “When tires wear on pavement, the chemical 6PPD is released. It reacts with ozone to become a different chemical, 6PPD-q, which can be extremely toxic — so much so that it has been linked to repeated fish kills.” This caveat equally applies to tires used in artifiicial turf.

See the following analysis on the internet by the San Francisco Estuary Institute and The Aquatic Science Institute: “Vehicle Tires Threaten Water Quality.” https://www.sfei.org/news/vehicle-tires-threaten-water-quality

4 Dog Park
Neighbors have repeatedly declared that they do not support a dog area in this park. This is because those close to the park need to sleep at night and dog parks are notorious for a lot of loud barking and commotion throughout the day and into the night. Witness the uproar caused several years at the park “A Place to Play” by neighbors.

The park is also a place where turkeys nest and where a variety of mammals live and enjoy the woodland quiet. Dogs and wild animals do not easily coexist. School children already use this park for nature studies and they enjoy the chance to see squirrels, sometimes rabbits and birds. The introduction of a dog park defeats all of the valuable natural services that the park seeks to provide.

This proposal would cause neighbors to rise up in uproar over the insensitivity of this concept.

Roseland Creek.

The isues of the creek are not addressed in the present DEIR, yet this is perhaps the biggest issue in the park. The fact that the creek and its many issues and influences are not considered makes this DEIR inadequate as an assessment of the issues of Roseland Creek Park. It should be clear to even the most casual visitor that everything in this park is influenced by the creek which runs down through the very center of the park.

Over seventy years ago, according to old time neighbors, such as Felix and Florence Kemp (1027 McMinn Avenue) steelhead trout used to come up Roseland Creek from the Sebastopol Laguna.

This resulted in small rainbow trout fry occasionally being caught by neighborhood youth. At that time ground water levels were higher and certainly cleaner. Our groundwater was clean to drink and supposedly sweet tasting.

Since that time there has been massive ground water overdrafting, particularly by the City of Santa Rosa all across the Santa Rosa plain, and now also by Chelsea Gardens apartments, managed by Burbank Housing – right across the street from the park. As groundwater levels have dropped, by estimate over two perhaps three feet, Roseland Creek has suffered dewatering and now only flows in the winter and early spring months. (Previously this Roseland creek flowed year round).

As evidence of the impact of this decline in ground water, the black walnut trees that Mr Kemp grew at 1027 McMinn Avenue and also his English walnut trees were formerly selfsufficient with ground water. Now that the ground water is dropping all of his English walnut trees have died and the black walnet trees, with deeper roots are all stressed.

This declining groundwater level also jeopardizes the California Tiger Salamander (CTS) and all other wildlife and plant life along the riparian corridor by having caused a dessication of the land and grounds. This decline still continues into the present. For the sake of future water sustainablity, this overdrafting of groundwater should stop immediately as it will continue to cause a deeper dewatering and consequent further dessication and drying of the land and dependent vegetation.

Additionally the City of Santa Rosa, in an apparent effort to speed rain runoff, channelization 5 efforts took place in the past. This seems to have been an effort to straighten out the creek banks, and this included an attempt to pave the creek channel. Now with the onset of global climate change and the prediction of more episodes of torrential rainfall, this will cause more flooding, both in the park and to neighboring residences. The consequence of these misguided “corrections,” the creek now has a reduced capacity to handle large storms. Now every year, and the Water dept. can verify this, we have flooding over the top of the bridge on McMinn Avenue. It is probable that this flooding will cause damages to neighhood housing and this will be known as the result of City manipulation of the creek without awareness of the consequences of this bad management.

The present annual flooding is amplified by the covering of most surface areas by impermeable materials. This now causes excess runoff and in the future it is inevitable that it will cause the sewer system to be overwhelmed causing overflow that is the direct result of iatrogenic city planning and the wrongheaded manipulation of the creek. This is an important issue that begs for correction.

Another major water issue in this area is the pollution of ground water by gasoline, benzene and trichloroethylene. This happened because the City of Santa Rosa failed to enforce regulations on the auto and dry cleaning businesses who dumped toxic cleaning and other waste materials onto the ground and steadily polluted what was peviously pristine clean ground water.

The different issues listed here reflect the burden that local residents endure because of the failure of the City of Santa Rosa to follow sound science and perform due dilegence in stewarding the lands and the issues of quality of life for the citizens of Santa Rosa.

The Environmentally Superior Alternative
See: “The CEQA Guidelines state that an EIR shall identify an environmentally superior alternative. As described in Section 7.0 Alternatives, the environmentally superior alternative to the proposed project is the No Project Alternative because all of the project’s significant environmental impacts would be avoided.” There is something quite positive in this concept. The environmentally superior alternative could be understood to let nature have her way. Over the last two or three years none of the planned development to the park has taken place. Yet, another form of growth has taken place. Wildflowers have exploded in variety and number. Trees have grown in stature and made the park more beautiful and thickly green. The grasses and shrubs are thicker and of a broader variety.

Some animal species have grown in number and a few have strangely disappeared. Now as evening comes over the park, the deep sounds of the Great Horned Owl’s hoots float across the forest. Now the rats that once might be found are more cautious even as the owls have grown fat and strong. Turkeys have become abundant, particularly in the central area and so have rabbits and even skunks, particularly in areas not well trod. Strangely the raccoons and possums have disappeared. It is actually all quite beautiful with luxurious plant growth. Neighbors simply walking arrive at many times during the morning and even visitors from outside the area. Every morning hikers tour through the park, many of them students with their parents cut across the park en route to classes. And there are also the occasional homeless adventurers and the indigents. 6 Could this be the “environmentally superior” alternative which the authors of this DEIR refer to? Probably not but this still remains a nice thought that would still benefit many of our neighbors who are regularly seen strolling through this nature park.

Now Sunday evening is coming to a close and I have other duties still to address. But this is not yet done. I will supplement this beginning response with other thoughts.

Sorry I don’t have enough time to get this finished this evening.

If you have any questions, give me a call. I am usually in my office at least til 9 pm most days.

My best to you and all your work,
Fred Krueger
7 Fred Krueger
June 14, 2024
Jen Santos
Deputy Director Parks
Recreation and Parks Department
[email protected]
Dear Jen Santos,
Thank you for your note indicating that you received my first set of comments. I ran out of time with that first edition and here are further insights that I did not have time to include. Here are a few additional comments on the Roseland Creek Park draft Environmental Impact Report for reflection and commentary. See the attached *.pdf version for a formatted text.

The Potential for Fires
The Roseland Creek park grounds over the past two or three years have witnessed remarkable growth in its trees, brush and grasslands. This is a welcome development because the increased biomass density brings a stronger natural presence to the area. To protect this growth, there needs to be intentionality in ensuring fires do not erupt.

A 2023 study from Cal Fire on the causes of fires shows that 95+% of fires are due to human accidents, particularly vehicle sparks, smoking, cooking and electrical equipment.

Statewide the remaining fires are due to fork lightning or rarely arson. Fork lightning is rare in the Santa Rosa region as we typically have sheet lightning in our coastal region.

Over the past ten years this woodland area has witnessed several fires, every one of which comes from cooking, smoking or some other illegal activity. This means we need to be very careful of picnicing in the park as this is potentially hazardous.

Similarly, smoking needs to be prohibited in the park. It is just too dangerous even though many of the homeless who frequent the park are smokers. So is driving over the dry grass by vehicles as mufflers can ignite fires. All vehicles in the park should stay on designated roadways, or they too can be a cause of fires.

Roseland Creek
The history of this creek from free flowing year round to a dry streambed over half of the year reflects on the continual overdrafting of ground water. Streams and ground water constitute one body of water, manifesting in different formats.

The biggest cause of overdrafting is the City of Santa rosa, followed by the local vineyards, then local lawn watering such as that by Chelsea Gardens on McMinn Avenue and other properties managed by Burbank Housing.

Roseland Creek influences much of the area in the proposed park area. Fortunately a former employee of the City of Santa Rosa, Rhianna Frank has developed a Masters degree report while at the University of San Francisco with a focus on groundwater on the Santa Rosa Plain. See “Sustainably Managing Groundwater - Surface Water Interactions within the Santa Rosa Plain Basin,” by Rhianna Frank, Fall 12-14-2018, https://repository.usfca.edu/cgi/viewcontent.cgi?article=1976&context=capstone Rhianna quotes Senate Bill 1319 (2014): Senate Bill 1319, introduced by Fran Pavley that requires local agencies to adopt and implement a groundwater management plans (State of California, 2014). The plan must contain specific components that meet state defined sustainability objectives tailored for the basin within the SGMA timeframe. She also observes how “Overdraft caused by groundwater pumping results in surface water depletion for seventy-five percent of California’s rivers and streams” (5.1).

She observes how depletion of groundwater levels is the root cause of lowered groundwater levels, reduction of groundwater storage, water quality degradation, land subsidence, and in some cases the depletion of interconnected streams and seawater intrusion. Most of us in the Roseland area already see the effects of surface subsidence in the cracking of house foundations. Repair is expensive. The draft EIR did not examine these issues in preparing its report. Yet this increasing dessication will dry the trees and plants in this park and cause other consequences of drying, not examined in the DEIR.

This is another area where the present DEIR is inadequate.

She also points out the following about the root depth of plants in an area:

Root depth of groundwater dependent vegetation provides necessary evidence in determining if the ecosystem is impacted by depleted groundwater resources.

Each type of vegetation has a measurable root length average which sets a minimum threshold for groundwater levels. For example, if a specific groundwater dependent plant has historically grown in the area and is known to have a maximum root length of fifteen feet then this species of plant will begin to exhibit signs of impact: reduced growth, reduced reproduction and increased mortality— if the groundwater levels exceed fifteen feet below the surface.

Root depth data should be established locally since there are regional differences that can have varying effects on root length. Studies need to be conducted within the Santa Rosa Plain Basin to determine the maximum root length of the groundwater dependent vegetative species with the shortest 2 expected root length. This information is critical in determining the minimum threshold for this criterion. Figure 20 is a flow chart of the range of changes in plant physiology, ecophysiology and ecology that is associated with various durations of water stress (Eamus et al. 2016).

Neighbors already know that groundwater levels in Roseland are dropping. Some of the trees in Roseland Creek park depend on that groundwater to survive. How much of an issue this might be will require some study, but this issue was never addressed in the DEIR.

The Forest woodland
Generally, the quality of the park will be maintained to the degree that we are able to preserve and protect all of the trees. The trees are the key to maintaining the ambience of the park. Over the past three years while plans were delayed, a wonderful period of growth in the neighborhood forest took place. The effect of the forest for the neighborhood is one that is cooling, quieting of city sounds, peace-making, all while silently sequestering carbon dioxide as it partially counteracts the effect of fossil fuels on the City’s carbon debt.

Noise and Crime Abatement through the park
It is well known that noise pollution can cause health problems for people and animals. From traffic noise to music concerts, loud or inescapable sounds can cause hearing loss, stress, anger and even heightened blood pressure levels. In contrast quiet in a neighborhood park or spending time in quiet places helps calm the mind and reduce the unhealthy effects of these noise intrusions.

The Roseland area is recognized by the SR Police dept as a place with considerable gang activity. However, strong evidence exists that high-quality green spaces in residential environments are important for public health promotion. This is because both availability and quality of green spaces has positive and significant associations with park use. Quiet in the park will be important for its benefits to flourish. This should mean the prohibition of artificial methods of sound amplification and noisy events.

The National Library of Medicine (NIM) provides important findings about quiet nature parks as a means for crime abatement. This analysis provides important documentation of the value of a nature park as opposed to a play park. When the Roseland neighbors learned this fact early in our research around 2002, this helped us determine the type of park we wanted. This was decisive information for neighbors:

See these findings at: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6950486/ 3 ‘The Impact of Green Space on Violent Crime in Urban Environments:

An Evidence Synthesis”
Can the presence of green space in urban environments reduce the frequency of violent crime?
To ascertain the evidence on this topic, we [NLM) conducted an in-depth literature review.... More than 30,000 potential paper titles were identified and ultimately, 45 papers were selected for inclusion. Green spaces typically comprised tree cover, parks and ground cover. Criminal behaviors typically included murder, assault, and theft. The majority of the research reviewed involved quantitative methods (e.g., comparison of green space area to crime data). We extracted multiple mechanisms from the literature that may account for the impact of green space on crime including social interaction and recreation, community perception, biophilic stress reduction, climate modulation, and spaces expressing territorial definition. Recommendations are made for future research, such as meta-analysis of existing data and the development of grounded theory through qualitative data-gathering methods.

By providing evidence that access to nature has a mitigating impact on violence in urban settings, city governments and communities are empowered to support these interventions....

The positive impact of nature and green space on human health and well-being has been documented by over 100 studies, including several literature reviews and meta-analyses which have examined the benefits of the nature connection. Several researchers have begun to explore the relationship between nature and urban crime, focusing on outcomes such as reduced aggression and improved community cohesion. Multiple new papers and dissertations have been published in the last three years, and an expansive update is essential to setting future research agenda.

It is now well over twenty years since the neighborhood associations in Roseland realized the great benefits of a nature park over other forms of parks. Former SR Parks and Rec. director Mark Richardson realized these benefits and supported the goal of a nature park, which was originally characterized as an urban wilderness park. After the 2009 budget shortfall a change in management took place, and then without institutional memory within the Parks and Recreation Dept. Roseland, neighbors had to defend their goal of a nature park with newsletters to local residents and dialogues with the new generation of SR Park and Rec. staff.
4 Other Issues
There is a tendency among local residents to dump trash onto the park grounds.

Penalties should be established to end this tendency.

Students use the park daily as a thoroughfare to the school on Burbank Avenue. They frequently drop plastic wrappers and other non-recyclable materials along the pathway.

Trash recepticles are needed to maintain a clean and trash free park. Also education about the importance of a litter free environment.

A tendency also exists for the homeless to seek campsites in the park whenever locations along the Joe Rodota Trail become closed. The reason is that the park is a beautiful location, and no restrictions exist to suppress drug use, late night parties, campfires or other activities. Trash is a typical result of their presence in the park area, as well as drug paraphenalia, liquor bottles and worse. The solution should be to have an evening sweep to remove campers daily. The sign by itself is not sufficient as the signs tend to be ignored.

Vehicles
Cars and trucks occasionally drive onto the grounds as there are no longer any hinderance to their entry onto the grounds. Vehicles bring camping gear, cooking equipment, chairs and wide variety of other forms of trash. The Park grounds need some form of security against vehicle entry. The previous chain provided some protection and that should be reinstalled.

The prohibition should exclude cars and trucks, electric bikes and scooters; bicycles should use established paths. All of these pathways should be with permeable surfaces to maximize groundwater absorption.

It is quitting time for me, so I will conclude this second set of comments at this point.

Thank you for considering these issues in plans for the Roseland Creek Park.

My best to you and all your work,
Fred Krueger
5 From:

Sent: M onday, June 17, 2024 1:58 PM
To: Santos, Jen <[email protected]>
Cc: Chris Coursey <[email protected]>; Alvarez, Eddie <[email protected]> Subject: [EXTERNAL] Re: Further Comments on Draft EIR on Roseland Creek Park Fred Krueger

Monday, June 17, 2024
Jen Santos
Deputy Director Parks
Recreation and Parks Department
[email protected]
Dear Jen Santos,
One last set of notes on the Roseland Creek Park draft Environmental I
mpact Report. This will address issues not previously elaborated upon in previous commentary.

The ecosystem within the park includes an opportunity to showcase as aspect of what the original natural flora and fauna looked like prior to the arrival of Europeans in this area inside the City. After several years of growth and untouched natural development, the park land has increasingly become a beautiful area of wildflowers and lush grassland, second growth oaks and other trees, and especially small animals and native birds.

Children who visit the park and students delight in seeing the squirrels, rabbits, and turkeys which are abundant. An attempt should be made to manage the area as a whole ecosystem, making efforts to protect the animal population. There are also occasional raccoons, possums, skunks and arboreal salamanders and a few snakes. Once in awhile a deer can be found in the park, and increasingly visitors are arriving at dusk to hear the great horned owls who live in the tall trees in the central area of the park.

To maintain a park with an abundance of wildlife, artificial noise levels have to be kept at a minimal level. Animals and loud noise are not compatible. The same is true about noise for most humans.

The field of nature therapy is still in its infancy, yet according to WebMD, Nature therapy, also called ecotherapy, is the practice of being in nature to boost growth and healing, especially mental health. More and more research suggests that spending time in natural environments is linked to a variety of mental health be
nefits. For example, being in a green space has been linked to less anxiety, fewer depression symptoms , and lower stress le vels.

Spending time in nature helps people with depression a nd kids with attention problems think more clearly.
“One of the top benefits that we address are for people who are trying to reduce anxiety or depression a nd increase relationship and connection,” Dr.

Lung says. “I also think it’s super engaging, so for kids and teenagers ... [and] for people who are reluctant to be in therapy.”

Patricia Hasbach, PhD, a licensed professional counselor and clinical psychotherapist, is another expert in ecotherapy. She recalls one such person, a patient in a cardiac rehabilitation center, who was reluctant about therapy. “He was pretty nervous about talking with me and I suggested, ‘You want to just take a walk outside?’ And I just noticed how his voice changed,” Hasbach says. “He become more relaxed ... and that was my first ‘aha’ moment that there’s something here that I need to pay attention to.”

Researchers have studied nature’s healing list a number of benefits, including:
• ADHD
• Dementia
• Lessened pain
• Lowered stress
• Medical recovery
• Mood modification
• Obesity
• PTSD
The DEIR does not engage these possible benefits to the Roseland Creek Park, and yet this region of Santa Rosa contains a lot of wounded young people who would benefit far more from the benefits of clean nature than simple athletics or pedestrial entertainment. These benefits should be considered just as much as traditional forms of park use. Here is an opportunity to help pioneer a benefit to urban young people that is just now coming into wider realization by the medical community and park management leaders.

As a leading psychologist observes, “[It’s about] noticing what’s around you and increasing our own awareness of ourselves in relation to our world and environment,” she says. “Just the symbiotic benefits of being outside.”

My best to you and your work,
Fred Krueger

From: Gemma Villasenor
Sent: Monday, June 10, 2024 4:52 PM
T
o: Santos, Jen <[email protected]>
Subject: [EXTERNAL] Proposed Burbank ave park site
Hello,
My family and I live just right down the street from the proposed site. I believe that while a park is a nice idea, unfortunately the way things are going it would just be a waste of money because the population it is designated for are not able to use it due to the drugged homeless population that roams the streets. In addition, there is another park right down the street off of Hearn and there is A LOT of traffic as well as a big group of people who are there at all hours just day drinking or smoking marijuana. I think the land should just be preserved as is. Additional apartments would also cause more traffic than there is in the morning and in the afternoon with everyone commuting to and from the schools in the area. I think having a nice area to just roam in nature and observe is more essential for children.

Gemma

-----Original Message-----
From: Gerald Rickard
Sent: Monday, May 13, 2024 11:46 PM
T
o: Santos, Jen <[email protected]>
Subject: [EXTERNAL] Roseland Creek community Park
Just call this park the neighborhood WOOD or WOODS.

Take two out of three saplings bunch together and open up the space a little Ask a tree company to donate eucalyptus or bay tree chips as they smell nice and last a long time Put them on the path
Take out the curb on McMinn so I can ride my bike in there without stopping to lift it over the curb.

Strategically locate six heavy duty picnic tables made out of wood, not cement.

From: Hunter Scott
Sent: S unday, June 9, 2024 3:20 PM
To: Santos, Jen <[email protected]>
Subject: [EXTERNAL] Comment RE Roseland Community Park DEIR Hi Ms. Santos and Santa Rosa City Leaders,
I would like to submit my support of the City's plan for the Roseland Community Park. As a resident of the McMinn neighborhood, I'd urge the city to move forward with the current plan or any of the alternatives, except for the "no project" alternative, that will result in no further delays to building the park. I'd like to also submit my opposition to the "no project" alternative, given the findings and comprehensive mitigation plans proposed in the recently released Draft EIR. The community will benefit greatly from a neighborhood park, especially one as well designed as what can be found in the City's plan. People in the neighborhood already use the space as an "unofficial" park. Without amenities that would come with a park such as trashcans, restrooms, parking spaces, and paved paths to support and manage activities that are already happening, the area will continue to accumulate trash and become degraded. The "no project" alternative will result in more environmental harm, not less, and further delays will also not serve the neighborhood well. Please move forward quickly with constructing this park, with whichever alternative will make it happen most quickly.

Thank you,
Hunter Scott

Fr
om: Jennifer Deihl
Sent: M onday, June 3, 2024 6:05 PM
To: Santos, Jen <[email protected]>
Subject: [EXTERNAL] Re: Roseland creek project
Good evening!
My name is Jennifer Deihl. I’m a homeowner on Rose Meadow Ct in Roseland. I’m also a mother of a nature loving toddler, an avid hiker, cyclist and an owner of a big dog who loves long walks.I used to load up the boys, stroller etc and head to one of the regional parks to get our fix of exercise in nature.

About a year ago after strolling through the residential areas surrounding us; we discovered the Roseland and Colgan creek trails! I actually obtained a neat map at an event held for the community at Bayer Farm. While we’re right by Bayer Farm, and as much as we treasure it, it doesn’t offer the same experience for large dog owners and those looking to be immersed in nature while getting a long walk in. Being able to escape the busyness of development and hear birds and animals in their natural habitats was a game changer. We now regularly; at the very least once a week, make a minimum of a 3 mile loop through these areas by foot or bicycle. This morning, I met a kind neighbor who brought to my attention the approaching decision on whether or not to clear the area to make a soccer field. It motivated me to reach out and plead for the preservation of this special wildlife area. It is so dear to us.

With the existing schools, and southtwest park being nearby, I think this undeveloped area is so necessary to protect.In an area so prone to gang activity its crucial to have an area that feels like Sonoma county in all its greatness accessible to my son and growing family.

Thank you for reading and I wish to stay informed of further public decisions in my area.

Warmly,
Jennifer Deihl
Sent from my iPhone

From: John
Sent: Monday, June 10, 2024 8:47 AM
T
o: Santos, Jen <[email protected]>
Subject: [EXTERNAL] Roseland Creek Community Park, DEIR Comments Hello Jen Santos
Thanks for the opportunity to share some of my thoughts one more time. Being a long time construction guy, I respect the park’s design and process getting to this point, and how thorough this EIR is. I’m sure it will also be a tricky build.

I’d like to first comment on proposed work hours stated in MM NOI-1.1. These work hours should not be 7 days a week, but rather, 5 days with weekends and dinner time & later, off. There’s a couple schools across the street, and it's surrounded by neighborhoods. Work hours affecting the project should be agreed upon rather than just stated.

Regarding the Project Alternatives, I’ve voiced my opinion many times over the last 20ish years. My first choice is the No Project Alternative. It doesn’t mess with what is already a pretty good thing.

As a second choice, I’d prefer the Neighborwood Master Project Alternative, but with a grassy spot south of the creek for families and visitors to run around in.

The city’s proposed and approved master plan, 2.2-4, still has some key flaws, and I’ll comment below, loosely following the order of the draft as written.

2.2.2.1. I respect the design of the parking lots being shoehorned into the trees and the creeks buffer zone. But why wouldn’t some simple street parking be chewed into the park across from the elementary school’s parking lots? It would be what I assume is a city standard such as what they did at Burbank Ave & Liana Dr a few years ago, making a simple parking lane. And, why not city standard curb and gutter and sidewalks @ the entire perimeter? The scenic road designation has already been violated by the schools and the multi family builds occurring now down the block.

Regarding the amount of paving or concrete to occur in the park, I get it that it’s required for ADA paths of travel and parking, and called out as the yellow dotted ‘multi use trail’, however let’s please not pave ‘roads’ throughout the remainder of the park. The ‘network of smaller trails & walkways’ should be compacted permeable gravel, and minimalistic at 4 or 5’ wide, based on my personal municipal building experiences. The goal is to not disturb the nature as much as possible it would seem. A shady walk or jog in the trees or grasses.

2.2.2.2 I have some HUGE issues with the plan for the south of the creek: the small 2nd restroom and barbecues! This area is designated per 3.0-2 as ‘within the wildfire hazard zone’. Therefore, no fires! That restroom tucked back 3 or 400 yards away from the road‘s prying eyes, and behind the heritage trees, spells nothing but trouble to me. I can’t imagine anything but dilapidated motor homes populating that tucked away parking lot. And the school kids will be trying to enjoy that area as well. Oh boy.

A solution would be to down size to only the nature center restrooms, perhaps with a couple more stalls added if required. Plenty of visibility there. The picnic areas could be connected to it via another ADA upgrade path of travel over the bridge. There are certainly parking management issues ahead.

Figure 2.2-3 is 6 years outdated. Google maps currently shows the reason why gridlock on Burbank Ave has become so horrible. Another school, and more high density development. Table 3.0-1 also helps point out the hundreds of new homes just within walking distance, not to mention the thousands other homes listed in the city’s “Santa Rosa’s Affordable Project Pipeline”. I feel this EIR should also address Burbank Ave’s gridlock, especially at school drop off and pickup times. No one will be able to drive to, or exit from this park when it’s those times. Sebastopol Rd, Hearn Ave, Dutton Ave all have this same gridlock issue, although it’s not all attributed to schools. I’m having a hard time wrapping my head around all the greenhouse gas emissions, or the PG&E power plant’s emissions needed to power all the electric cars, all idling away in the name of affordable housing. And there’s no infrastructure upgrade

been done to accommodate the thousands of new dwellings. Yes, Sonoma Clean Power is all renewable energy as is mentioned later in this report.

2.4 So much of the creek’s bottom in the park is concrete, as well as concrete walls. Didn’t the Sonoma County Water Agency approve that in the past? Could not Sonoma Water bear some responsibility now for its removal and possibly flooding. There’s a huge flooding problem here, as McMinn Ave is typically flooded and impassable at the creek at least a few times per year. The city had its survey crew in the neighborhood for about 3 weeks mapping and checking elevations this spring. The creek flows better behind the Roseland School District offices, once it becomes channelized.

Impact AES-2 I’ve stated earlier my thoughts regarding the hidden restroom and its attached parking lot.

I’d like to see more heritage trees remain, and street parking used instead. Access south of creek from over the bridges. School parking lots are empty on the weekends and after hours also.

Impact AES-4 Lighting shouldn’t be required in a dawn to dark only locked park. If necessary, only at the nature center structure for a drive by security check.

Finally, my children and now grandchildren have played in that park for 39 years, just as it is. I’ve walked my dogs there for even longer. The school kids and walkers and dog walkers all make the park a lively and social experience. Along with the others who live close enough to the park to walk there, we’ve cleaned and monitored and enjoyed it for many years. Hoping for a sensible park build. Thank you, Jo
hn Murray
From: jorge inocencio
Sent: M onday, June 17, 2024 5:00 PM
To: Santos, Jen <[email protected]>
Subject: [EXTERNAL] feedback on Roseland Creek Park DEIR Hello Jen
I am writing to provide feedback on the draft environmental impact report for the Roseland Creek Community Park.

I am in favor of the City's proposed master plan and I think that the DEIR does a very thorough job of describing
and offering mitigations for any potential environmental impact. I think that the DEIR addressess all of the concerns
from the community regarding environmental preservation.

Thanks,
Jorge Inocencio

Judy Johnson

June 15, 2024
Jen Santos, Deputy Director, Parks
Recreation and Parks Department
[email protected]
Re: Roseland Creek Community Park Master Plan
Draft EIR SCH No. 2022080148
Jen Santos –
Please consider changes to the City’s plans for Roseland Creek Community Park that will focus on the land and its life. I refer to the letters and comments from Janet Cobb of the California Wildlife Foundation, Angela Moskow of the California Oaks Program, and Trish Tatarian of the California Native Plant Society. I am not a professional or scientist, just a human being who lives here and very much cares about our land, as do many Santa Rosa residents.

The Park must not be a profit center, event venue or recreational park. This is a struggling remainder of the very special habitat that was the Santa Rosa plain and laguna. All that is needed is to help reverse the human damage and provide a healthy, peaceful area for people to walk, be calmed and refreshed, and connect with nature.

How fortunate this is near schools, where kids can discover, enjoy and learn to protect habitat.

The next generations are becoming acutely aware of the importance of and the destruction of nature. Many are losing hope. This park, in their own neighborhood, can provide a positive and dynamic early step in caring for Earth. They don’t need a “nature mall”. All that is needed is minimal paths and some benches. It should be eyes on, not hands on.

The Santa Rosans living near Roseland Creek Park vary. Some cannot easily access or afford the time to visit the larger parks in the area. Some came to this County and this City to be near the special environment. Some have no clue what the indigenous land was like. Many want a respite from the endless noise, buildings and concrete, if only for a little while. And they don’t need a “nature mall”, either. So no parking lots, kiosks, BBQ pits, picnic areas, playing fields….

The non-human creatures also need quiet and privacy to flourish in their home.

Of course, work needs to be done on the plot. Get rid of the old pavings and foundations.

Don’t add more paving. There is plenty of street parking for those coming any distance.

Get the garbage out, garbage and recycle bins in. The woods and grasslands need invasives removed and native species reintroduced. Some trimming is needed, but no logging, and no landscape architects need apply. Once repaired, there is no need for roads. It is a small area.

Can it please be a quiet, healthy part of the plain to be visited and appreciated? We will help.

Please act responsibly for the long term. The days of “someone else will take care of it” must be over. Here is your opportunity to be an example.

Thank you for allowing me to have my say.

Judy Johnson

JenSantosDeputyDirector of ParksCityof SantaRosa
Re: CommentsontheDEIRfor RoselandCreekCommunityPark
June15, 2024
Dear Ms. Santos,Pleaseaccept mycommentsbelowandacknowledgereceipt bytheJune17, 2024date.

I amaresident of SantaRosafor over 26yearswhoappreciatesthevalueof our beautifulparks, openspace, andconnectiontonatureasaparent of twogrownchildren. I havewalkedthe20acreparcel tobeRoselandCreekCommunityParkandstronglysupport thislandtobeprotectedinitsnatural statewithrestorationof priorityareastoallownativeplants, wildlife, andpeopletothrive.

I believeauniqueapproachisneededtoprovidethegreat benefitstoresidentsof Roseland,thegeneral public, theplantsandwildlifewholivethereaswell asecological servicessuchasgroundwater recharge. Thenorthernmeadow, juvenileValleyOakwoodland, RoselandCreek,andthePurpleNeedlegrassareainthesouthneedtobeaddressedspecificallytopreserveandprotect their valueaswell ascomplywithCEQAandtheCityof SantaRosaCreekMaster Plan.

TheEIRisinadequateinaddressing invasivespeciesremoval.TheCreekMaster Planidentifiedmanyinvasivespeciesthat needtoberemovedprior tocreationof parkamenities. ThesespeciesincludeHimalayanblackberry(Rubusarmeniacus),cherryplum(Prunuscerasifera), hawthorn(Crataegusmonogyna), woolycotoneaster(Cotoneaster pannosus), hardinggrass(Phalarisaquatica), Mediterraneanbarley(Hordeummarinumssp. gussoneanum), reedfescue(Festucaarundinacea), ripgut brome(Bromusdiandrus), slimoat (Avenabarbata), Frenchbroom(Genistamonspessulana), Indianteasel(Dipsacussativus), hairycat’sear (Hypochaerisradicata), Italianthistle(Carduuspycnocephalusssp. pycnocephalus), periwinkle(Vincamajor), fennel (Foeniculumvulgare), poisonhemlock(Coniummaculatum). TheRoselandCreeksouthernpart isseverelyimpactedbyhardinggrassdominance(Phalarisaquatica). Thisinvasiveweedisveryperniciousandrequiresacomprehensiveplantoeradicate, whichwill requirelongtermmonitoring. Withremoval of invasivespecies, thenativeforbs, grassesandshrubswill beabletorecolonizesuccessfully. ThisshouldbespecificallyaddressedintheEIRfor all invasivespeciespresent.

TheEIRisinadequateinaddressingtheneedfor therestorationof RoselandCreek.Theremoval of approximately400linear feet of concreteinthecreekchannel isnecessarytocomplywiththeCreekMaster Plan. Asacentral part of thenewCommunityPark, theconcreteremoval, invasiveandother non-nativeplants, andrestorationwithnativeriparianplantsgrownlocally, thispart of Roselandcreekcanbesafelyenjoyedbythepublicwhileprovidingflood control andwildlifehabitat. Thisrestorationplanmust beconsideredintheEIR. Restorationofthecreekwill providehabitat corridors, natural areasintheneighborhoodthat allowanimalstomovethroughout areasandget much-neededhabitat. ArestorationplanshouldbeincludedintheDEIRaspart of theplanningprocess.

Thelarge, mature, valleyoaksalongRoselandcreek, combinedwiththejuvenilevalleyoakwoodlandprovideanatural resourceoncecommonlyfoundintheRoselandareawhichisnowseverelyreducedbydevelopment. Toillustratethehabitat valueandbenefitsof valleyoaks(evenwithout bearsor deer present) I present thefollowing:
“ Valleyoaktreesareakeystonespecies- aspeciesonwhichmanyother organismsinanecosystemdepend, suchthat if it werelost theecosystemwouldchangedrastically. Valleyoakssupport approximately300animals, 1,100plants, 370fungi, and5,000insectsandinvertebrates. Bears, black-taileddeer, scrubjays, magpies, woodducks, wildturkeys, quail,flickersandacornwoodpeckersall dependonoaksfor food. Insectsfeedontheleaves, twigs,acorns, barkandwoodof oaktrees(whichinturnarefoodsourcesfor other larger critters.)Someanimalsdependonoakstokeepthemsafefrompredators, whileothersusethebranches, cavities, andbarkitself asahome. Oakscontinuetobeuseful towildlifeevenaftertheydie. Salamanders, worms, snails, termitesandantsliveindecomposinglogsandhelpturnwoodintohumus, whichenrichessoil.” Source: NapaCountyRCDhttps://naparcd.org/wp-content/uploads/2017/10/1-Introduction-to-Oak-Ecology.pdf TheEIRisinadequateinthat it didnot citethe2014CitywideCreekMaster Plan(CCMP)AppendixCRoselandCreekRestorationPlanandstatehowtheparkMaster PlanwillincorporatetheRestorationneedsof RoselandCreek. TheCCMPidentifiesthefollowing:“Construct aself-maintainingchannel withadequatebank-full dimensionstotransport sediment,containhealthyriparianvegetationandconveythe100-year flood.”Thisinadequacyshouldbeaddressedbeforeconstructionof anyCreeksideamenities. TheRoselandCreekMaster plancitesthefollowingSantaRosaGeneral PlanPolicies:OSC-D-7Rehabilitateexistingchannelizedwaterways, asfeasible, toremoveconcreteliningsandallowfor aconnectionbetweenthestreamchannel andthenatural water table.OSC-D-8Restorechannelizedwaterwaystoamorenatural conditionwhichallowsfor morenatural hydraulicfunctioning, includingdevelopment of meanders, pools, rifles, andother streamfeatures. Restorationshouldalsoallowfor growthof riparianvegetationwhicheffectivelystabilizesbanks, screenspollutantsfromrunoff enteringthechannel,enhancesfisheries, andprovidesother opportunitiesfor natural habitat restorationThereisnodiscussionintheEIRthat thesepolicieswill beimplementedfor thispark.

AlsoaffectingtheRoselandCreekriparianhabitat istheplantobuildaparkinglot inthesouthernportionwith17spaces. Duetotheproximityof thecreekat theSWcorner, thenarrowentranceoff BurbankAveleaveslimitedspacebetweenthecreekandtheareaplannedfor theparkinglot. Anentranceroadwith handicappedparkingandaturnaroundwouldbebettersuitedfor thispart, withtheparkinglocatednorthof thecreek. Also, theadditionof alargeturfarea, sportscourts, andplaygroundsarenot all appropriatefor thissmall space, andthereis potential for adverse effects on the Purple Needlegrass sensitive area in the SE corner.

Therefore, walking and bike trails, picnic areas, and natural playgrounds would be best for this space. A fitness circuit could be installed without too much impact to the natural vegetation. The nearby schools and other community parks nearby have sports courts and turf sport facilities.

The EIR is inadequate in addressing the restoration needs of the entire park regarding invasive species removal and monitoring The northern meadow has a significant invasion of Harding grass (Phalaris aquatica). The Purple Needlegrass area in the SE corner may also be negatively impacted by the planned adjacent turf area, which will have to be mowed. Lawn mowing equipment can often transport and spread weed seeds, which will impact the native grasses. There should be some separation of the irrigated turf area and the Purple Needlegrass area, with either a berm or a buffer zone, such as a native plant landscaped area, to avoid weed introduction and overwatering. Any plan for the undeveloped area south of the creek should specifically address the invasive Harding Grass present on site and restoration using locally jsourced grasses and forbs should be implemented.

Finally, the paths proposed for the park are excessive in width, at 10 feet wide with a 2 ft gravel shoulder on each side. I propose the roads to be 8 feet wide, which is adequate for maintenance and will save money on materials. This change will also allow for more surface area for rainwater percolation and groundwater recharge.

This 20 acre parcel is unique in the neighborhood and in Santa Rosa. A remnant, regenerating Valley oak forest surrounded by development, it provides highly valuable natural resources to native plants and the animals who depend on them. A community nature park here, mostly undeveloped and restored where necessary, provides access for children to walk to school, for teachers to teach about oak woodlands and riparian habitat, for families to see wildflowers and birds, and for recreation such as dog walking, picnicking, and unstructured play in the neighborhood and for the City as a whole.

Thank you for accepting these comments.

Sincerely,
Lynn Houser, B.S. Botany

Madrone Audubon Society is qualified as an organization recognized under Section 501(c)(3) of the Internal Revenue Code.

Contributions are deductible by the donor under Section 170. Federal Tax I.D. 94-6172986 P. O. B OX 1911  S ANTA R OSA , C ALIFORNIA 95402
http://madroneaudubon.org
Madrone Audubon Society

INCORPORATED
Transmitted by email 06/05/2024
June 5, 2024
Jen Santos
City of Santa Rosa
55 Stony Point Road
Santa Rosa, CA 94510
Re: Roseland Creek Community Park – Draft Environmental Impact Report – Comment Dear Ms. Santos:

We are writing to share our impressions and requests regarding the Draft Environmental Impact Report (DEIR). Madrone Audubon is headquartered in Santa Rosa and continues to enjoy a productive and positive relationship with the City of Santa Rosa. Our nonprofit Audubon organization is also a Chapter of National Audubon. Madrone Audubon serves approximately 3000 members in Sonoma County and the Bay Area.

You may recall we have taken an active interest in both the longstanding advocacy for acquisition with conservation of the Roseland Community Park parcels and subsequent planning process. Our interest has been in a balance of protecting and enhancing this ecological reserve with appropriate passive recreation for community members. We shared discussions about a possible environmental task force, offering to lead that, to convene our County nonprofit organizations, sharing in activities and education for this special Nature Preserve in the making. The building to remain on-site was considered as a “Nature Center.” Like many, we were disheartened and deeply concerned about the outcome of the park design, which included multiple impactful elements in the supposed context of conserving, restoring and enhancing the wild acreage to support habitat, species and the ability to provide an educational Nature area. Indeed, this land should be considered local critical habitat.

Madrone Audubon Society is qualified as an organization recognized under Section 501(c)(3) of the Internal Revenue Code.

Contributions are deductible by the donor under Section 170. Federal Tax I.D. 94-6172986 P. O. B OX 1911  S ANTA R OSA , C ALIFORNIA 95402
http://madroneaudubon.org
City of Santa Rosa, Roseland Creek CP DEIR 06/05/2024 2 We agree that a formal Environmental Impact Report to document and assess attributes and impacts was both appropriate and needed.

During the public review process, prior to obtaining the DEIR, your City staff and elected officials heard multiple comments from residents and students about the very strong desire to ensure protection of the oak woodland, creek and riparian corridor, grassland and overall habitat. We also heard concurrent support for appropriate passive recreational opportunities that would fit well within the context of an ecological reserve.

When I first visited the Roseland Creek property, I observed a large active Red-tailed Hawk Nest high in a tree on-site. This was a remarkable observation. With many site visits in the past 8 years, even with some detrimental activities occurring on the property, the importance of the Roseland Creek property as the ecological reserve it continues to be, with potential for quiet passive enjoyment and habitat protection and enhancement, cannot be overstated.

Our DEIR review and comments will focus on supporting this continuing experience and opinion by discussing Biological Resources.

In the midst of Roseland, across from Roseland Creek Elementary School, with nearby residences, the Roseland Creek Community Park land is described as follows:
“Seven biological communities were identified on the project site (refer to Figure 3.4-1). Nonsensitive biological communities include non-native grassland, developed/landscaped areas, and disturbed valley oak woodland. Potentially sensitive biological communities observed on the project site include intermittent stream (Roseland Creek), valley oak riparian woodland, riparian wetland, and purple needlegrass grassland, all of which are detailed following Figure 3.4-1. bio resources”… (p. 38)
The variety of habitat types, including the creek with riparian corridor and possibility for ongoing restoration, also reflect the biological resources/species who rely on this area for survival as well as the City of Santa Rosa securing this habitat in a climate crisis where all we can do to support species survival is very important. Your Santa Rosa students from elementary to high school age will understand your positive action in this regard - if you make decisions to support high level conservation. Educational opportunities as well as community volunteering will help connect community members to their ecological reserve – and conservation that is needed will occur. It is not an understatement to say the City of Santa Rosa and the Roseland community can cultivate and support a world-class Nature Preserve while also providing passive recreational amenities for residents of the community.

Madrone Audubon Society is qualified as an organization recognized under Section 501(c)(3) of the Internal Revenue Code.

Contributions are deductible by the donor under Section 170. Federal Tax I.D. 94-6172986 P. O. B OX 1911  S ANTA R OSA , C ALIFORNIA 95402
http://madroneaudubon.org

City of Santa Rosa, Roseland Creek CP DEIR 06/05/2024 3 We encourage you to review and consider the opinion and report of Shawn Smallwood, Ph.D., his report filed from 2021. Dr. is a highly reputable biologist whose observations, analytical and reporting skills are skills are excellent and reliable. Through his report, comparing to the WRA report(s), you will gain insights as to accurate representation and documentation of biological resources on the Roseland Creek Community Park property. Dr. Smallwood’s September 2021 report includes:

“…While visiting the site, I detected 38 species of vertebrate wildlife, 5 of which were special-status species (Table 1). The site supports oak titmouse, of which there are many, and Anna’s do hummingbirds (Photos 8 and 9). I saw Nuttall’s woodpeckers and a colony of acorn woodpeckers (Photos 10 and 11), Pacific-slope flycatcher and black phoebe (Photos 12 and 13), California scrub- jays and mourning doves (Photos 14 and 15), hooded orioles (Photo 16) and turkey vultures (Photo 17), among other species. I also saw invasive species, including wild turkeys and Eastern fox squirrels, both species of which were introduced to California from their natural ranges east of the Mississippi River, and a house cat on the hunt (Photo 18). Occurrences of non-native species, and more explicitly the ratio of non-native to endemic species, reflect on the ecological integrity of a place (Smallwood 1994). In the case of Roseland Creek Community Park, the ratio of 3 non-native to 35 endemic species of vertebrate wildlife, or <8% of the species I detected, indicates a high degree of ecological integrity. Given its interior location within the City of Santa Rosa, I would have expected a higher percentage of non-native species. The Park is relatively intact, ecologically, and it is rich in wildlife”…

The park project design the City of Santa Rosa Council approved is too impactful and unbalanced.

Community groups, residents, students and teachers have appealed to the City for many years to create an ecological reserve with passive recreation, cultural elements, and educational opportunities.

This direction is what is optimal for the Roseland Creek property. We strongly encourage you to consider changing course to a more positive, balanced, climate-supportive and innovative park design and project. Of course, we remain interested in supporting and participating. Understanding and achieving the balance of human activity with sensitivity to habitat areas can lead to best decisions and outcomes. Madrone Audubon has a 12-year history of nesting support for the West 9th Street heron and egret rookery in SW Santa Rosa. We are expanding our relationship with Lincoln Elementary School, thanks to a grant from National Audubon, for habitat gardening to support survival of birds, butterflies, bees and other species in need. We would, as we have shared in the past, want to support the City of Santa Rosa’s change of course and decisions for the ecological reserve in Roseland.

Sincerely yours,
Susan Kirks
Susan Kirks, President
Madrone Audubon, Sonoma County [email protected], 707-241-5548 cc: Sonoma County Water Agency
Sonoma Co. Ag and Open Space District
-----Original Message-----
From: Mary Goe
Sent: Saturday, May 11, 2024 3:38 PM
To
: Santos, Jen <[email protected]>
Subject: [EXTERNAL] Roseland Creek Park
I would like to see the nature park kept as natural as possible. The fewer parking spaces the better. I would like to see the creek restored and the concrete removed. Some of the concrete wall along the creek has collapsed and I fear it could be dangerous to children playing in the creek bed.

Thank you
Mary Goe

Sent from my iPhone

June 17, 2024

Jen Santos, Deputy Director – Parks
[email protected]
RE: Roseland Community Park Draft Environmental Impact Report (DEIR)

Dear Ms. Santos,

Please acknowledge receipt of this letter.

I am a 25-year resident of Santa Rosa and have walked the proposed Roseland Community Park many times with various agencies and residents who are passionate about saving one of the last remaining valley oak woodlands in Sonoma County. I concur with the comments of three letters you have received regarding the DEIR: from the California Oaks Program of the California Wildlife Foundation, from Milo Baker Chapter CNPS and from Lynn Houser. I would like to add, from an aesthetic and environmental perspective, developing a “standard city park” requiring significant infrastructure that removes established native trees and vegetation, destroys a valuable ecosystem and its biodiversity, adds heat islands of concrete and asphalt, contradicts Santa Rosa’s greenhouse gas reduction goals, and climate resilience goals, which include the human need for natural spaces so important in a quickly changing climate. And finally, the irony of the expense of destroying an ecosystem important to all life, humans, and animals, and then spend maintenance hours maintaining an unnatural system is based on old ideas. Let us go forward differently, and make this a training ground for environmental inquiry, by the local community, schools, and non-profits. We are way beyond business as usual, we cannot afford business as usual.

Thank you for considering my comments.

Regards,
Natasha Granoff
June 17, 2024
Jen Santos
Parks Deputy Director
City of Santa Rosa
637 First Street
Santa Rosa, CA 95404

Roseland Creek Community Park
Draft Environmental Impact Report

Dear Ms. Santos,
Thank you for the opportunity to submit comments regarding the DEIR.

My comments pertain, in part, to sections within the DEIR regarding Land Use and Planning, Hydrology and Water
Quality and Wildfires. Analyses within these three sections of the DEIR appear incomplete:
• Impacts regarding Land Use and Planning have not
considered the transition of the future park from it’s
past use under private ownership to public use.
• Impacts regarding Hydrology and Water Quality have
not considered the potential for ongoing occupation by
unhoused people.
• Impacts regarding Wildfires have not considered the
fuel load inventory as it relates to both park
maintenance capability the the potential for ongoing
occupation by unhoused people
The DEIR is, as well, silent concerning a discussion regarding Public Safety. Our environment, how we live, how we utilize Richard Ingram

2 public spaces, how public spaces are administered and maintained, all influence Public Safety. In our modern era, design elements of public spaces, including parks, are typically shaped with major considerations toward Public Safety. How the park will be maintained, administered, policed are all factors that may significantly impact the environment as it relates to water quality, wildfires and the health and welfare of those residents using the park and those who live adjacent to the park. Will there be sufficient resources dedicated by police, fire and parks departments to maintain this new park in a manner that avoids environmental impacts? That
question needs to be considered in the DEIR in a way that assures those public officials who are considering the project for approval that the development of the proposed park will put an end to the significant risks to the environment that, for the past several years, have occurred on the parcels of land where the park is planned.

The DEIR should assess whether the City has capacity with current infrastructure and staffing levels of the police, fire and parks department to actually do what is necessary to provide a level of service that will assure people using that park or people living adjacent to the park that it will be a safe place.

The four parcels that make up the land for future park are now open space, owned, maintained and policed by the City.

The 19-acre site has, for the past several years, been a revolving door for unhoused transients. The site has been set on fire numerous times over the years. Huge accumulations of trash left by unhoused people have occurred. There have been fights, arrests, trespassing and theft from adjacent homes boardering the future park. Unhoused people have used the future park site and Roseland Creek as a toilet and a trash receptacle.

3 Section 3.11, Land Use and Planning, speaks to the conformity of the proposed park with the current land use. This land has been open space for some time and the creation of a park is certainly a natural progression given the City’s growth and annexation of Roseland. Prior to being open space, it was rural farmland. Existing homes, for instance, along Hughes Avenue which border the entire northern boundary of the proposed park, were constructed in the early 1950’s and bordered what was then farmland. Being adjacent to a proposed public park is significantly different than being adjacent to private farmland. The real change in land use that needs to be
addressed in the DEIR is from private land that was held by individuals where access was controlled and maintenance of that land was responsibly undertaken, to now - ownership by public entities. The development of the park is just the final step in the conversion of what was once private land to public land. The issues associated with private residences bordering public land include public safety issues. Those owning homes in the neighborhood along Hughes Avenue that back up to the proposed park have long had to suffer the consequences of the lack of maintenance and security of what was once private land and is now public land.

Questions of how the City will prevent unhoused people from camping in the park, building fires in the tall grass should be addressed in the EIR. The park plan that's associated with this environmental document creates very little change to the landscape. As an example, the first several hundred feet south of the northern park border will remain essentially unchanged. The DEIR indicates that there are no impacts associated with land use changes. In fact, there have been impacts associated with the creation of this public land. The open space district and now the City have historically not provided an adequate level of maintenance throughout the 4 period of this long and drawn out process of creating a park.

Weeds are not mowed until they are 6 feet tall. Unhoused people camp and build fires during high fire danger periods subjecting the entire neighborhood to unnecessary risks.

Prior to public or quasi-public acquisition of this property, the land was farmed in a responsible manner. Trespassing was not allowed. Now that the City has the property, unhoused people have more rights to use the land than they once did when the land was under private ownership. This change in ownership created a change in land use, a change in the level of public safety and definite impacts to the environment.

These impacts are not being addressed in the DEIR.

Section 3.10 discusses Hydrology and Water Quality. Currently there are environmental impacts occurring every day within the proposed park boundary from unhoused people that are not utilizing sanitation facilities. With the creation of the park, how will the City ensure that these impacts do not continue.

The plan for the park calls for the installation of a split rail fence along Burbank Avenue and closing a gate at night. Will that be adequate to prevent unhoused people from
continuing to do what they do now? These potential impacts are not discussed in the DEIR.

Section 3.20 discusses Wildfires. The DEIR indicates there are no significant impacts associated with wildfires. Unhoused people building fires in tall grass has the potential to create huge environmental impacts. The potential exists for the destruction of an entire neighborhood. Air quality, water quality, impacts to health and welfare are all potential impacts. There have been numerous unhoused people who
5 are allowed to camp on City owned property for extended periods of time without facilities, without water, without sanitation, without rules to be followed. The creation of the park does not solve these problems if the land that is being utilized does not change and the enforcement of the rules remains the same.

Parks and open space are terrific ideas and healthy for a neighborhood. Housing the unhoused is a complex and
daunting problem facing Cities. The issues around the
interface between public and private land are difficult problems to address. However, the City should take
ownership of these problems and provide resolutions to an ongoing and old issue that has plagued this neighborhood.

And it needs to begin by including evaluation of these real issues within the context of this environmental document.

It is unfortunate that this land has not been developed into a park in a timely fashion. Now that the City is involved I am hopeful that a wonderful park will be created. The City has inherited numerous pre-existing problems with the
annexation of Roseland. One of the largest problems may be one that is not well recognized. Surface water drainage in the Roseland area is a very big challenge. Sebastopol Road, north of the proposed park, collects an inordinate amount of
debris/garbage that makes its way into surrounding
waterways. This is an environmental problem that is likely beyond the scope of this DEIR, however Roseland Creek runs right through the middle of the proposed park and the creek is subject to ongoing degradation from surface water discharges from streets in the area. An opportunity exists with the 6 creation of this park to improve and address some of these surface water discharges while also reducing wildfire risks and addressing security concerns.

Along the northern boundary of the proposed park, some of the past proposed park alternatives involved the creation of vernal pool wetlands. Some opinions expressed by consultants indicated that the vernal pool wetlands would not be as successful as one would hope. However, the creation of vernal pool wetlands is only one type of maintained wetland that can benefit the environmental health of the area. If the focus of the constructed wetlands were to change from creating vernal pool habitat to controlling pollution that's coming from street runoff, then wetlands could be successful. Much of the area north of the park eventually drains to Roseland Creek. If surface water collected during storms could be diverted before entering the Creek and routed through surface water treatment wetlands, harmful pollutants could be treated through passive natural processes by being slowly routed through these wetlands. The potential for area flooding could also be diminished by utilization of these wetlands as well by slowing the speed of the runoff thereby reducing the peak flows in the creek. These newly constructed treatment
wetlands could act as a buffer between people that were utilizing the park and the residents that border the northern boundary of the proposed park. In this way, security for those residents could be improved, storm water pollution could be mitigated, and wildfire threats could be lowered by careful maintenance of these new wetlands.

The development of a park of this size is a significant undertaking for the City and it's also a significant opportunity to make Roseland better as a whole. Not enough has been done on this property for too long.
7 I implore that the City use thoughtful leadership to see that this park gets built and is done right, as well as being open to the opportunity that the creation of this park provides to address other issues in Roseland.

Sincerely,

Richard Ingram
From: Seth Tippey
Sent: S unday, June 2, 2024 12:32 PM
To: Santos, Jen <[email protected]>
Subject: [EXTERNAL] Roseland Creek Community Park

Hi Jen,

I want to start by saying that I know this project has been worked on for years and years, and there has been a lot of community involvement, both in trying to push this park forward and in resisting any change to the area. And as much as I want the natural beauty of this park to remain completely unchanged, I recognize that my wish is quite selfish, and that improving access will allow more people to enjoy this beautiful park. So I can see the need to add parking and make it easier for people of all ages to be able to walk the paths.

The part that I feel most compelled to comment on is the addition of the lawn area and sports court. My wife and I have been living in Roseland for years, and we've watched as all the open fields have disappeared. Development is everywhere -- including just beyond Roseland Creek Park where dozens of houses are being built as we speak -- and Roseland's natural beauty is being replaced. This is one of the few natural parks in Roseland that remains intact. Given how many other parks already exist in the area with sports fields/courts, why does this one need to turn into the same thing? Again, I do recognize that keeping the park exactly the same is unrealistic. What exists here is worth sharing, and I would be happy if more people got to enjoy it. Just don't destroy the parts of the park that are unique and replace them with generic sports fields/courts that you can find at every other park.

My wife and I watched two baby great horned owls grow up last year. I've never seen that in my entire life. I regularly encounter flocks of baby turkeys. Red shouldered hawks nest in the trees. This park is amazing. The fact that it's still here is amazing. The reason we bought our house here is because our property backs up to its open fields and trees. We have the gift of getting to walk our dog in this park every day, and I want more people to experience what they might not even know exists in their own neighborhood.

Please consider keeping the park as natural and undisturbed as possible. I know it won't be the same as it is today, but I think people would greatly benefit from having access to a park that's this beautiful and unique. Leave it undisturbed and see how the community reacts to having easier access to its paths along the creek before deciding to add features that make it like every other park in Roseland.

Thank you for your time and effort on this project.

--Seth