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Agenda-Item-Number-19-Grand-Jury-Response-FINAL-UpdatedwithProposal8292025

Sebastopol City Council
September 2, 2025

Document
Agenda-Item-Number-19-Grand-Jury-Response-FINAL-UpdatedwithProposal8292025
Meeting
September 2, 2025
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Sebastopol City Council
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172
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8.3 MB
Text extracted from the city's file for reading and search. Open the original on www.cityofsebastopol.gov. That file is the official record.

CITY OF SEBASTOPOL CITY COUNCIL
AGENDA ITEM REPORT FOR MEETING OF: September 2, 2025
=========================================================================================== To: Honorable Mayor and City Councilmembers
From: City Attorney Alex Mog
Interim City Manager Mary Gourley
Responsible Department: Police
Subject: Approval of City of Sebastopol Response to Grand Jury Report and Authorize for Mayor to Sign Letter to the Grand Jury and Discussion/Action for Consideration to Issue Request for Proposals for Contract for Animal Control Services and Enter into a Month to Month Contract with North Bay Animal Services until such time the RFP is completed and staff returns to a future City Council meeting with award of contract for Animal Control Services
=========================================================================================== RECOMMENDATION:

That the City Council approve the City of Sebastopol Response to Grand Jury Report and Authorize for Mayor to Sign Letter to the Grand Jury and Discussion/Action for Consideration to Issue Request for Proposals for Contract for Animal Control Services and Enter into a Month to Month Contract with North Bay Animal Services until such time the RFP is completed and staff returns to a future City Council meeting with award of contract for Animal Control Services.

EXECUTIVE SUMMARY:

This item presents a formal response to the Sonoma County Civil Grand Jury’s findings and recommendations related to animal control services in Sonoma County. Currently, the City of Sebastopol contracts with North Bay Animal Services (NBAS) for animal sheltering and control.

As required by California Penal Code §933 and §933.05, the City is obligated to respond to the Grand Jury’s findings and recommendations that pertain to Sebastopol’s role in providing or contracting animal control services.

PROCESS OF AGENDA ITEM:
a. Presentation of agenda item by the City Attorney and Police Chief b. Questions and discussion from Councilmembers
c. Public comment period
d. Council deliberation and motion
BACKGROUND:

The Sonoma County Civil Grand Jury investigates and reports on the operations of local government entities to ensure accountability, transparency, and responsiveness.

The primary function of the grand jury is to examine all aspects of local government, ensuring that the county is being governed honestly and efficiently and that county monies are being handled judiciously. Each grand jury is charged and sworn to investigate or inquire into matters of civil concern within the county. [Penal Code Section (PC) § 888]. The Civil Grand Jury has two basic civil functions: (1) to act as the public’s watchdog by investigating and reporting upon the affairs of local government and (2) to weigh the allegations of misconduct against public officials and determine whether to present formal accusations requesting their removal from office as prescribed Agenda Item Number: 19 Agenda Item Number: 19
City Council Meeting Packet for Meeting of: September 2nd

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in Article 3, Section 3060, Chapter 7, Division 4, Title 1, of the Government Code. The grand jury is comprised of citizens who apply to serve. While they have no specific expertise in the matters they report on, they conduct interviews and investigations before issuing a report.

Under California Penal Code Section 933(c), a response to the Presiding Judge of the Superior Court regarding the Civil Grand Jury’s Report is required 90 days after the submission of the Civil Grand Jury’s final report. No later than 90 days after the grand jury submits a final report on the operations of any public agency subject to its reviewing authority, the governing body of the public agency shall comment to the presiding judge of the superior court on the findings and recommendations pertaining to matters under the control of the governing body,
On June 13, 2025, the Grand Jury issued a report titled "Animal Services in Sonoma County: Separate and Note Equal – The Costs and Consequences of Decentralization" which includes findings and recommendations that pertain to the City of Sebastopol.

California law requires the City to respond to each finding and recommendation with one of the following:

1. Agreement or disagreement with the finding

2. Explanation of whether a recommendation has been implemented, will be implemented, requires further analysis, or will not be implemented, with supporting rationale DISCUSSION:

In June 2025, the Sonoma County Civil Grand Jury released a report following a complaint filed regarding the management of North Bay Animal Services (NBAS) in Petaluma. The report outlines several concerns that members of the Grand Jury had with NBAS’s operations, financial model, and facilities, along with broader concerns and recommendations for the animal care system throughout Sonoma County. The City is required to formally respond within 90 days of the report publication date.

FINDINGS TO BE RESPONDED TO:

REQUIRED RESPONSES

The Sebastopol City Council (R1-R2, R4-6, F1-F3, F6-F11) R1. By November 1,2025, the Board of Supervisors will direct DHS to establish an Animal Services Task Force comprising county, city, and shelter representatives to revisit the 2012 DHS Animal Services Report and recommend a governance structure for animal services that will: 1) provide county-wide oversight to ensure compliance with State Law; 2) standardize fees and engage a common licensing vendor to enhance public health and safety, licensing rates and revenue, and; 3) achieve economic efficiencies through shared resources. (Fl, F3, F4-F6 and F9-Fl0) City Response: The City of Sebastopol agrees with Grand Jury Recommendation R1 and supports the establishment of an Animal Services Task Force by the Sonoma County Board of Supervisors, as outlined in the report. While the authority to carry out this recommendation rests with the Board of Supervisors, the City commits to participating in the Task Force and contributing to discussions on governance, service standards, and licensing practices, and will provide feedback and recommendations in a timely manner to support county-wide animal services improvements.

R2. By January l, 2026, each of Sonoma County's 9 cities will delegate one or more representatives to participate in the county-wide Animal Services Task Force convened by DHS. (Fl) Agenda Item Number: 19 Agenda Item Number: 19
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City Response: The City of Sebastopol agrees with Grand Jury Recommendation R2 and will designate one or more representatives to participate in the county-wide Animal Services Task Force convened by the Department of Health Services (DHS) by the requested date of January 1, 2026.

The City is committed to active engagement in the Task Force to collaborate with other Sonoma County cities, county officials, and shelter representatives. City representatives will provide input and feedback to support the development of a coordinated governance structure, standardized fees, and efficient animal services across the county.

R4. By May 1,2026, the Board of Supervisors will direct DHS to launch a county-wide public information campaign in cooperation with the cities to explain the legal imperative and benefits of licensing pets. The campaign will commence no later than July 1,2026. (F7-F9)
City Response: The City of Sebastopol acknowledges Grand Jury Recommendation R4 and supports the launch of a countywide public information campaign by the Board of Supervisors and the Department of Health Services (DHS) to explain the legal requirements and benefits of licensing pets.

The City is committed to cooperating with DHS and other Sonoma County cities to help design and disseminate accurate and effective messaging to the public. Sebastopol will assist in promoting the campaign within the community and encouraging pet owners to comply with licensing requirements, thereby supporting public health, safety, and responsible pet ownership.

R5. By November l, 2025, each city contracting with North Bay Animal Services will inspect and evaluate the shelter condition, and evaluate the shelter operation and animal control services, to determine whether NBAS is complying with legal mandates and other terms of its contract. (F2, Fl l-Fl2) City Response: The City of Sebastopol acknowledges Grand Jury Recommendation R5 and has already conducted a thorough inspection and evaluation of North Bay Animal Services (NBAS).

The City has assessed the condition of the shelter, evaluated shelter operations, and reviewed the provision of animal control services to determine whether NBAS is complying with legal mandates and the terms of its contract. The City is committed to taking any necessary corrective actions in collaboration with NBAS to ensure that animal care and control services meet legal, operational, and community standards.

R6. By September 30, 2025, each of the cities that contracts with NBAS will require quarterly reports that include data and performance criteria sufficient to evaluate compliance with its contract and all relevant laws. (F2, Fl l) City Response: The City of Sebastopol acknowledges Grand Jury Recommendation R6. The City is issuing a request for proposals to solicit a new long-term animal services provider. The City will require the selected entity (including North Bay Animal Services (NBAS) if they are selected) to submit quarterly reports beginning no later than 30 days from award of contract .

These reports will be required to include data and performance metrics sufficient to evaluate the provider’s compliance with the terms of its contract and all applicable laws. The City is committed to reviewing these reports regularly and taking appropriate action to ensure that animal control services meet legal requirements and community expectations.

Agenda Item Number: 19 Agenda Item Number: 19
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Fl. Failure by the county and its nine cities to adopt recommendations in the 2012 DHS Animal Services Report has left Sonoma County animal service agencies operating without shared standards, communication channels, data sharing or oversight.

City Response: The City of Sebastopol acknowledges Grand Jury Finding F1 and concurs that the absence of county-wide adoption of the 2012 DHS Animal Services Report may have resulted in inconsistent standards, limited communication, and gaps in oversight among animal service agencies.

The City is committed to participating in county-wide efforts, including the Animal Services Task Force, to establish shared standards, improve communication channels, enhance data sharing, and strengthen oversight. Sebastopol will actively collaborate with other cities, the county, and shelter representatives to help implement a more coordinated and effective animal services system. However, the City does not have any authority to adopt standards outside of Sebastopol.

F2. Services provided to the four Sonoma County cities by North Bay Animal Services are non-compliant either with state laws or industry standards for the care of shelter animals as specified in its contracts.

City Response: The City of Sebastopol acknowledges Grand Jury Finding F2 and recognizes that North Bay Animal Services (NBAS) must fully comply with state laws and industry standards for the care of shelter animals as outlined in its contracts with the four Sonoma County cities. While the City does not necessarily agree with every allegation regarding services in the Grand Jury’s report, the City agrees there are areas for service improvements.

The City is committed to actively monitoring NBAS operations through regular inspections, quarterly reporting, and contract compliance evaluations. Sebastopol will work collaboratively with NBAS and other contracting cities to ensure that animal control and shelter services meet legal requirements, contractual obligations, and community expectations for humane and professional care.

F3. A lack of coordination between SCAS and NBAS is an obstacle to a fully coordinated implementation of the countywide disaster response plan for animal evacuations.

City Response: The City of Sebastopol agrees with Grand Jury Finding F3 and recognizes coordination is key between Sonoma County Animal Services (SCAS) and North Bay Animal Services (NBAS) and is essential to ensure an effective, county-wide disaster response for animal evacuations.

The City supports efforts by the County to establish clear communication protocols, shared training opportunities, and joint planning exercises between SCAS, NBAS, and other municipal and nonprofit animal service providers. We encourage the development of a unified operational framework that addresses roles, responsibilities, and resource sharing before, during, and after disaster events to eliminate service gaps and reduce delays in animal evacuation and care.

F6. Having multiple different fee structures for animal licenses and services is confusing to the public and complicates billing and collection of license fees and fines.

Having multiple different fee structures for animal licenses and services is confusing to the public and complicates billing and collection of license fees and fines.

Agenda Item Number: 19 Agenda Item Number: 19
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A consistent fee structure across jurisdictions would improve public understanding, simplify administration, and reduce the risk of errors in billing and collection. However, fees must reflect the cost of the services provided. If different levels of services are provided to different cities, or the costs of services differ across jurisdictions, uniform fees will not be possible.

F7. Failure to achieve high levels of licensing in all government jurisdictions and provide access to shared information undermines mandated rabies control, makes it more difficult to return lost pets, and results in a loss of revenue.

City Response: The City of Sebastopol acknowledges Grand Jury Finding F7 that failure to achieve high levels of licensing in all government jurisdictions and provide access to shared information undermines mandated rabies control, makes it more difficult to return lost pets, and results in a loss of revenue.

Increased licensing compliance and access to shared licensing data are essential for effective rabies control, reuniting lost pets with their owners, and ensuring revenues receive are necessary to support animal services.

F8. Based on SCAS data, uniform adoption of online licensing management through DocuPet (or a comparable vendor) would increase county-wide licensing rates and enhance compliance with state law.

City Response: The City of Sebastopol agrees with Grand Jury Finding F8 that uniform adoption of online licensing management through DocuPet (or a comparable vendor) would increase county-wide licensing rates and enhance compliance with state law.

A standardized online licensing system would streamline processes, improve compliance, and make licensing more accessible for residents.

F9. Failure to promote the benefits and legal requirement to license dogs, and failing consistently to send license renewal reminders, contribute to low license compliance and loss of revenue.

City Response: The City of Sebastopol acknowledges Grand Jury Finding F9 that failure to promote the benefits and legal requirement to license dogs, and failing consistently to send license renewal reminders, contribute to low license compliance and loss of revenue.

Consistent public education and timely renewal reminders are important strategies to improve licensing compliance and maintain revenue.

Fl0. Making centralized training resources available could enhance performance of animal services employees and volunteers.

City Response: The City of Sebastopol agrees with Grand Jury Finding F10 that making centralized training resources available could enhance performance of animal services employees and volunteers.

Centralized training resources would help ensure consistent performance standards and enhance service quality across jurisdictions.

Agenda Item Number: 19 Agenda Item Number: 19
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F11. Insufficient oversight either by the cities or by the organization's board of directors has allowed NBAS to be noncompliant with state law and the terms of its contracts by: failing to effectively manage licensing and renewals; failing to offer legally mandated rabies vaccination clinics; failing to perform legally mandated spay/neuter of animals prior to placement; failing to consistently submit bite reports to the county health officer (through SCAS); failing to maintain the Petaluma animal shelter in compliance with industry standards; and failing to collect accurate data and provide reports that demonstrate compliance with contract terms.

City Response: The City of Sebastopol acknowledges Grand Jury Finding F11.

The City recognizes that oversight of contracted services is essential to ensure compliance with state law, contractual obligations, and industry standards. While NBAS has provided needed services to the community, the concerns identified by the Grand Jury warrant attention, corrective action, and improved reporting mechanisms. The City is taking steps to implement enhanced oversight measures to ensure contractual and legal compliance. The City can’t comment on the level of oversight by other jurisdictions.

STAFF (RESPONSIBLE DEPARTMENT) ANALYSIS:

Police Chief Comments:

North Bay Animal Services Site Visit:

I performed a lengthy and detailed inspection of North Bay Animal Services (NBAS) on July 8, 2025 and was provided a comprehensive tour by Exec Director Mark Scott, who is in charge of the facility. I was actually very impressed with their facility and its condition. Whether it was cleaned up after the grand jury document surfaced, I can neither confirm nor deny. All I can report is the current condition of the property and found it to be, in my opinion, more than adequate for the services provided to our city. They also offer more comprehensive services to our city than any other provider appears to be able to and this is confirmed by our staff through their experience dealing with other previous service providers.

I addressed each of the ‘observations’ about NBAS’s in the grand jury document with Mark while I was there and responses are below for your information, in red.

1. Multiple professionals and private citizens stated that NBAS places unaltered animals in foster and "foster-toadopt" homes and that appointments for legally mandated spay/neuter surgery can be delayed for many months.

The Grand Jury obtained an email which confirmed that NBAS was aware of multiple similar complaints about delays in sterilization and vaccination. Executive Director Mark Scott advised me that there is no legislative requirement to spray/neuter animals until they are permanently adopted out.

2. NBAS doesn't facilitate rabies vaccination. State law assigns responsibility for vaccination and licensing both to dog owners and every government jurisdiction. Cities are responsible for enforcing these laws through their designated Animal Control Officers, which is NBAS in the case of Petaluma, Cloverdale, Windsor and Sebastopol.

Executive Director Mark Scott advised me that this is not required until adopted out permanently.

3. Jurors were told that NBAS received 350 to 370 bite calls a year, but the Jurors were unable to secure evidence that legally mandated bite reports had been filed or that potentially dangerous animals were being quarantined as required by state law. This is a matter of concern for public safety and poses the potential for city liability resulting from dog bites. Executive Director Mark Scott advised that while many calls are called in as a ‘dog bite’, many of Agenda Item Number: 19 Agenda Item Number: 19
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those calls do not meet the elements of the crime to be classed as bite calls and that their code categorizes various levels and stages relating to a dangerous dog. Executive Director Mark Scott advised that he reports all qualifying dangerous dogs and actual bite incidents to the county as required.

4. NBAS does a poor job of facilitating dog licensure and license renewal. NBAS licensing data for 2024 showed only l27o compliance across NBAS cities compared with 23% in Santa Rosa and 3 I % in unincorporated Sonoma County. (See Appendix C for licensing rates as estimated based on a state methodology.) Executive Director Mark Scott advised that they send out a letter each month, for up to three months in an effort to license animals as required before taking any form of enforcement action.

5. NBAS advised the Grand Jury that animals are taken to one of several veterinarians when in need of emergency or routine care, so there is no supervising veterinarian in charge of animal medicine. The shelter has no single veterinarian contracted to consult on written protocols for physical, conditions, sanitation, or general animal care at the shelter. Executive Director Mark Scott advises that Dr Steve Wood of County Care Vet is their ‘veterinarian of record’, which provides the necessary supervision of animal medicine, who visits weekly and advises the facility on protocols for physical, conditions, sanitation and/or general care at the facility.

6. No NBAS staff member is identified as having had the training and oversight by a veterinarian that is required to conduct physical and behavioral assessment of incoming animals. Executive Director Mark Scott advises that employee Bella O’Toole has a Bachelor’s of Science in Cynology, also known as Canine Studies, and is a degree focused on the scientific study of dogs, encompassing their biology, behavior, and relationship with humans. She has near 7 years with the organization and is the Dog Care Coordinator. Kathy Sousa is one of the Cat Care Coordinators at the facility and has 20 years experience. Executive Director Mark Scott further advised that there are no specifically required or mandated qualifications for these positions.

7. Employees serving in the key positions of Dog Coordinator and Cat Coordinator were described as "experienced," but without any specific veterinary certifications included in their bios on the NBAS website. Refer to above information and the Veterinarian of Record, Dr Steve Wood, provides the necessary vet related services and oversight to the facility.

8. There is no documentation of training or continuing education of staff or volunteers. Executive Director Mark Scott advised that there is no specific or mandated education required for staff, but that they are working on staff attending a NACA training/certification. Further information is available on this link NACA ACO Certification | National Animal Care & Control Association

9. The workspace for food preparation observed by the Grand Jury is cramped and cluttered; open bags of pet food, some stacked on the floor, are accessible to rodents and other pests, in violation of shelter standards. I found the area to be more than satisfactory, neat, clean and organized.

10. During visits to the shelter the Grand Jury experienced an overpowering foul odor that suggests that the ventilation system is unlikely to be providing air quality consistent with the health and safety of both animals and humans. I found the facility to be clean and organized, and the smell was appropriate for the amount of animals in care. I have run an animal shelter as the Chief of Police in another state and am quite familiar with typical smells of such facilities. Executive Director Mark Scott advised that some of the exhaust vents were old and making some bearing related noises, and are being replaced, however, they still function and perform their role appropriately.

Agenda Item Number: 19 Agenda Item Number: 19
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11. NBAS does not have a written plan for emergency response. Nor does it have an MOU with the county to specify its role as an emergency responder. Executive Director Mark Scott advised that he has previously attempted to work with SoCo regarding written agreements and MOU documents but they have not been advanced by either party to the point of completion. He further advised that regardless of the existence of an MOU, they provide emergency services and have done so effectively over the past years and emergencies, seamlessly working alongside other organizations to effectively achieve common goals when the time calls and that he will continue to do so.

To provide further information, Executive Director Mark Scott advises that NBAS are an ‘open admission’ facility and will take all admissions. SoCo’s facility is not open admission.

NBAS offer free vaccination and microchip clinics every other Wednesday in three different locations (Cloverdale, Windsor and Petaluma) and these are advertised on their social media.

Sonoma County Humane Society Site Visit:

In mid-August, I visited the Sonoma County Humane Society shelter for a visit and inspection. I found the facility neat and clean, and in a similar condition to the NBAS shelter. SCHS provides very like services to NBAS with respect to veterinarian care for the animals, and what I consider to be more than adequate care and facilities for the animals.

SCHS and NBAS both advise that they could take deceased animals.

From my visit, I did not identify any conditions or services offered by SCHS that were materially greater scope or quality than NBAS. NBAS provides full animal control services, where they attend and collect animals as necessary, provide investigations and prosecution if necessary, which allows police department personnel to focus on other law enforcement work, which is important given our current staff shortages. The Department does not have the capacity to provide animal control services, and must rely on a third party.

Chief Recommendation:

After digesting the grand jury report, I could not identify any evidence of any specific incident or situation that seemed to warrant concern and my inspection of the facility did not warrant any concern whatsoever. NBAS has been providing services to the City of Sebastopol for at least a couple of years.

My recommendation is to continue with their services on a month-to-month basis while the City goes through the RFP process.

Agenda Item Number: 19 Agenda Item Number: 19
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INTERIM CITY MANAGER ANALYSIS:

The Sonoma County Civil Grand Jury report raises important questions about oversight, consistency, and accountability in the delivery of animal services county-wide. In the near term, Sebastopol must maintain continuity of animal control and sheltering services while ensuring compliance with the Grand Jury’s recommendations. Staff recommends proceeding with a Request for Proposals (RFP) to ensure that the City is evaluating all available options for animal services providers.

Pending completion of that process, the City should continue services under a month-to-month contract to avoid any gap in service delivery.

CITY COUNCIL GOALS/PRIORITIES; AND/OR GENERAL PLAN CONSISTENCY:

This agenda item represents the City Council goals/priorities as follows:

Goal 4: HIGH PERFORMANCE ORGANIZATION
Restoring public trust
Improve Public Communications
COMMUNITY OUTREACH:

This item has been noticed in accordance with the Ralph M. Brown Act and was available for public viewing and review at least 72 hours prior to schedule meeting date. The City has also used social media to promote and advertise the City Council Meeting Agenda Items.

As of the writing of this agenda item report, the City has not received public comment. If staff receives public comments following the publication and distribution of this agenda item report, such comments will be provided to the City Council as supplemental materials before or at the meeting and will be posted to the city website.

FISCAL IMPACT:

There is no fiscal impact with approval of this item as follows:
• No fiscal impact for submission of the response to the Grand Jury • The FY 25 26 budget has funding allocated in the budget in the amount of $25,000 for animal control services • There is no cost to conducting a formal RFP process
Per NBAS: “Our proposed cost for the month-to-month arrangement is $1575.00 per month, with the same scope of services currently being provided.”
Per Sonoma County Humane Society: “
RESTATED RECOMMENDATION:

That the City Council approve the City of Sebastopol Response to Grand Jury Report and Authorize for Mayor to Sign Letter to the Grand Jury and Discussion/Action for Consideration to Issue Request for Proposals for Contract for Animal Control Services and Enter into a Month to Month Contract with North Bay Animal Services until such time the RFP is completed and staff returns to a future City Council meeting with award of contract for Animal Control Services.

OPTIONS:

1. Deny the request for any or all items listed above and provide further direction to staff.

Agenda Item Number: 19 Agenda Item Number: 19
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ATTACHMENTS:

1. Grand Jury Report 24-25

2. Grand Jury Response Requirements

3. Response to Grand Jury Report Form

4. Response Letter from City of Sebastopol

5. NBAS Proposal for Temporary Services

6. Sonoma County Humane Society Proposal for Temporary Services – not provided to city at this time
APPROVALS:

Department Head Approval: Police Chief Approval Date: 8/28/2025 CEQA Determination (Planning): Approval Date:

The proposed action is exempt from the requirements of the California Environmental Quality Act (CEQA) Administrative Services (Financial): Approval Date: 8/28/2025 Costs authorized in City Approved Budget: ☐ Yes ☐ No XX N/A Account Code (f applicable) ___________________________ City Attorney Approval: Approval Date: 8/28/2025
City Manager Approval: Approval Date: 8/28/2025
Agenda Item Number: 19 Agenda Item Number: 19
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2024-2025 Final Report
Sonoma County Civil Grand Jury
This ancient oak is next to Jack London’s cottage at Jack London State Park in Glen Ellen. It is revered by the Pomo Nation and protected by the State of California. Photographer, Don Roberts Agenda Item Number: 19 Agenda Item Number: 19
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Para leer los informes del Gran Jurado Civil 2023-2024 en español, visite https://sonoma.courts.ca.gov/general-information/grand-jury/grand-jury-reports-responses Reports issued by the Civil Grand Jury do not identify individuals interviewed. Penal Code Section 929 requires that reports of the Grand Jury not contain the name of any person or facts leading to the identity of any person who provides information to the Civil Grand Jury.

Sonoma County Civil Grand Jury Final Report 2024-2025
Table of Contents
Letterfrom the Presiding Judge 1
Letter from the Foreperson/Introduction 2
Breves Resúmenes de Informes, en español 3
Sonoma County Airport
Addressing Challenges and Preparing for the Future 5
Permit Sonoma 2025
Management Review a Beginning, not an End 13
Local Fees, Local Subsidies
Fees and subsidies cause local pain 36
Animal Services in Sonoma County: Separate and Not Equal 43 Sonoma County Emergency Evacuation Plans
Are We Ready for the Next Major Evacuation? 60
Who Can Afford to Live in Sonoma County?
A Tale of Two Cities 79
Sonoma County’s Surplus Property Disposal
Housekeeping takes time but pays long term benefits 97
Providing Continuity by Following Through on Previous Investigations:

Responsesto the 2023-2024
Sonoma County Civil Grand Jury Reports 104
Responsesto the 2018-2023
Sonoma County Civil Grand Juries’ Reports 116
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INSERT NEW JUDGE LETTER HERE FROM PDF

SUPERIOR COURT OF CALIFORNIA COUNTY OF SONOMA
Agenda Item Number: 19 Agenda Item Number: 19
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The Sonoma County Civil Grand Jury
PO Box 5109 Santa Rosa, California 95402
(707) 565-6330
[email protected]
www.sonomagrandjury.org
To the Citizens of Sonoma County and the Honorable Judge Christopher Honigsberg:

On behalf of the 2024–2025 Sonoma County Civil Grand Jury and pursuant to California Penal Code Section 933, it is both my duty and privilege to present our Final and Consolidated Report.

Throughout this term, our jurors dedicated countless hours to conducting thorough investigations, reviewing complex data, and crafting detailed reports. Despite the unexpected reduction in our ranks from 19 to 13 jurors, the remaining members demonstrated exceptional perseverance, integrity, and commitment to the responsibilities entrusted to us by the people of Sonoma County. Their unwavering dedication ensured that our work was completed with rigor and care.

Service on the Civil Grand Jury demands far more than time—it calls for collaboration, critical thinking, respectful dialogue, and a shared sense of civic responsibility. It is a powerful platform for effecting positive change by illuminating areas within local government that warrant reform, increased efficiency, or enhanced accountability.

Over the course of our term, we completed a series of reports addressing critical topics that affect the lives of Sonoma County residents. These include housing affordability and displacement, the state of animal services, airport infrastructure and growth, disaster evacuation planning, building permit processing, surplus property disposal, and local fee structures. Each report offers carefully considered findings and recommendations aimed at improving transparency, equity, and public service delivery.

Now more than ever, in a national climate where transparency is often elusive and public trust is strained, the Civil Grand Jury stands as a beacon of democratic engagement. It is one of the few remaining institutions that offers ordinary citizens a direct, impartial, and constructive voice in local governance. Our efforts this year reaffirm the essential role the Civil Grand Jury plays in safeguarding the public interest and fostering a more responsive, accountable government.

We are proud to present our findings and recommendations, and we invite all residents of Sonoma County to engage with this report as a catalyst for informed dialogue and meaningful action.

Sincerely,
Karen Rocco
Foreperson
Sonoma County Civil Grand Jury 2024–
2025 Term
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Página de resúmenes en español
Los informes del Gran Jurado en español estarán disponibles en el sitio web del Gran Jurado a partir del 1 de julio de 2025. (https://sonoma.courts.ca.gov/general-information/civil-grand-jury/current-year-reports-and-responses) A continuación, se presentan resúmenes de los informes.

Aeropuerto del Condado de Sonoma: Abordando los desafíos y preparándose para el futuro El Gran Jurado recomienda actualizaciones estratégicas para el Aeropuerto del Condado de Sonoma el Aeropuerto Charles M. Schulz del Condado de Sonoma (STS) ha crecido significativamente en los últimos años, atendiendo a más de 770,000 pasajeros en 2024 y convirtiéndose en un enlace de transporte vital para la región de North Bay. Un nuevo informe del Gran Jurado Civil reconoce este progreso y recomienda actualizaciones estratégicas para ayudar al aeropuerto a mantener el ritmo de su crecimiento. Las sugerencias clave incluyen la contratación de una empresa para crear un plan maestro basado en el número actual y proyectado de pasajeros, y recomienda una estructura de gestión que refleje un aeropuerto de tamaño mediano, no un aeropuerto local de aviación general.

Enajenación de Bienes Excedentes en el Condado de Sonoma: La gestión del hogar requiere tiempo, pero ofrece beneficios a largo plazo
El Gran Jurado Civil del Condado de Sonoma ha publicado sus conclusiones sobre la gestión de los bienes excedentes en el condado, destacando el sólido desempeño de la División de Gestión de Flotas en la enajenación de vehículos y equipos, que genera importantes ingresos anuales gracias a un sistema bien organizado y sostenible. Por el contrario, el Gran Jurado concluyó que el condado carece de un enfoque estratégico para la gestión de terrenos y edificios excedentes —sus activos más valiosos—, citando oportunidades perdidas y una transparencia limitada. El informe recomienda mejor acceso público a los datos territoriales y una estrategia proactiva para aprovechar al máximo el valor de los bienes públicos infrautilizados.
¿Quién puede permitirse vivir en el Condado de Sonoma?: Una historia de dos ciudades A medida que se intensifica la crisis de vivienda en el Condado de Sonoma, impulsada por un precio medio de la vivienda de $900,000 y una creciente escasez de opciones asequibles, dos ciudades se destacan como modelos de progreso. Healdsburg y Rohnert Park, a pesar de sus diferentes identidades, han obtenido la Designación Pro-Vivienda de California y están superando los objetivos estatales de vivienda mediante estrategias innovadoras y adaptadas a las necesidades locales. Al agilizar las aprobaciones, aprovechar los terrenos públicos, obtener financiación estatal y local, y fomentar una profunda participación comunitaria, estas ciudades demuestran que, con un liderazgo sólido y una planificación inclusiva, es posible crear soluciones de vivienda que beneficien a todos los residentes.

Servicios para animales en el condado de Sonoma: Separados y desiguales: Los costos y las consecuencias de la descentralización
Un nuevo informe del Gran Jurado Civil del Condado de Sonoma 2024-2025 destaca serias preocupaciones sobre la desigualdad en los servicios para animales en todo el condado, especialmente en las zonas atendidas por los Servicios para Animales de North Bay (NBAS). La investigación reveló que NBAS opera con una supervisión insuficiente, incumple contratos y presenta deficiencias en el cumplimiento de las normas de salud pública, lo que pone en riesgo el bienestar animal y la seguridad de la comunidad. En contraste, agencias como los Servicios para Animales del Condado de Sonoma y el Refugio de Animales de Rohnert Park demuestran un firme apego a las mejores prácticas. El Gran Jurado insta a los gobiernos de los condados y ciudades a redoblar esfuerzos para coordinar y estandarizar los servicios de control de animales y refugios, mejorar la supervisión y garantizar el cumplimiento de las leyes estatales para proteger mejor tanto a los animales como a los residentes.

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Tarifas y subsidios locales: Las tarifas y los subsidios causan problemas locales Un informe reciente del Gran Jurado Civil del Condado de Sonoma concluyó que, si bien Santa Rosa, Petaluma y Rohnert Park siguieron los procedimientos legales para ajustar las tarifas de los permisos, cada ciudad podría mejorar la transparencia y la comunicación, especialmente en lo que respecta a la eliminación de los subsidios que llevaron a aumentos significativos de las tarifas. En Santa Rosa, la tarifa de un permiso de renovación histórica aumentó de $1,700 a $17,000 en 2024, lo que generó preocupación en la comunidad y una revisión del proceso de permisos de la ciudad. El Gran Jurado recomendó que los gobiernos locales identifiquen con mayor claridad los cambios en las tarifas y sus impactos para ayudar a los residentes a comprender mejor y prepararse para los ajustes de costos.

Planes de evacuación del Condado de Sonoma: ¿Estamos listos para la próxima evacuación? Un nuevo informe del Gran Jurado Civil del Condado de Sonoma concluye que el condado no está preparado para evacuaciones a gran escala durante incendios forestales e inundaciones, debido al retraso en el cumplimiento de las leyes estatales de planificación de evacuación y a la inadecuada infraestructura vial. Las rutas de evacuación clave siguen siendo peligrosamente estrechas o propensas a cuellos de botella, mientras que los sistemas de comunicación, especialmente en zonas rurales, carecen de la fiabilidad necesaria para emitir alertas oportunas. Si bien el condado cuenta con un plan de emergencia escrito y un centro de operaciones activo, ha pospuesto el mapeo completo de las rutas de evacuación y la modernización de los semáforos hasta 2030. El informe insta a la inversión inmediata en herramientas de planificación de evacuación, mejoras viales y sistemas de alerta comunitaria más robustos para garantizar la seguridad pública durante futuros desastres.

Permit Sonoma 2025: La Revisión de la Gestión es un Principio, No un Fin El Gran Jurado Civil del Condado de Sonoma publicó sus conclusiones sobre Permit Sonoma, la agencia de permisos de planificación del uso del suelo y desarrollo del condado, y elogió su progreso sustancial en la modernización de sus operaciones y el cumplimiento de los mandatos legales. El jurado determinó que Permit Sonoma cumple ampliamente con los requisitos del Proyecto de Ley 2234 de la Asamblea de California, que impone plazos estrictos y estándares de transparencia en los procesos de permisos de construcción. También elogió el compromiso de la agencia con la implementación de las 15 recomendaciones de la revisión de gestión de Berry Dunn de 2023, destacando logros clave como la reducción de los tiempos de revisión de permisos, la ampliación de las aprobaciones directas, la mejora de la atención al cliente y el uso de verificadores de planos externos para evitar retrasos. Sin embargo, el Gran Jurado enfatizó la necesidad de una mayor inversión en tecnología y sistemas de flujo de trabajo para realizar un seguimiento completo de las métricas de rendimiento y estandarizar los procedimientos.

Si bien el informe confirma la dedicación de Permit Sonoma a la reforma, también insta a los líderes del condado a mantener el impulso y proporcionar recursos adicionales para garantizar el éxito a largo plazo, la confianza pública y el apoyo continuo a los objetivos de vivienda y desarrollo del condado de Sonoma.

Puede ver los informes competo en este sitio de web.

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Sonoma County Airport
Addressing Challenges and Preparing for the Future

SUMMARY
Over the past two decades, Charles M. Schultz-Sonoma County Airport has evolved from a small general aviation facility1 into a thriving mid-sized commercial airport, now serving more than 700,000 passengers annually. Its growth places it on par with regional airports such as those in Green Bay, WI, and Peoria, IL. However, during this rapid expansion, the airport’s management structure, planning efforts, and infrastructure have struggled to keep pace—creating challenges that hinder it from reaching its full economic potential.

Key issues limiting operational efficiency include FAA compliance shortcomings, insufficient management resources, inadequate TSA space for screening during peak travel times, and limited parking capacity. These factors strain the airport’s ability to grow sustainably. Missed opportunities in parking revenue and commercial leasing continue to limit the airport’s ability to generate maximum benefit for both it and the county.

This report highlights these critical concerns and proposes ways to enhance regulatory compliance, improve airport operations, and modernize management practices. The objective is to position Sonoma County Airport for sustainable growth while maximizing its economic contributions to the region.

The Sonoma County 2024-25 Civil Grand Jury extends its gratitude to the many county officials, private stakeholders, and community members who provided valuable insights throughout this review. We are also encouraged by the county’s initiative to launch a citizen-led oversight effort, fostering collaboration and innovative thinking to shape the future of the airport and surrounding property.

Sonoma County Airport can continue to grow as a vital economic engine for the region while providing an exceptional experience for passengers and businesses by proactively addressing these challenges.

METHODOLOGY
The Civil Grand Jury (Grand Jury) pursued multiple avenues of inquiry to ensure accuracy and depth. The investigation included extensive internet searches to gather publicly available information, a thorough review of documents published by local news organizations, and an analysis of records from public meetings of airport commission and local government officials. Additionally, the Grand Jury conducted interviews with key personnel knowledgeable about the airport operations and management practices.

BACKGROUND
Charles M. Schultz-Sonoma County Airport (Airport code STS) is a county-owned, public-use airport. Sonoma County Airport has a rich history that dates to the late 1930s. Sonoma County purchased 339 acres of agricultural land and began constructing a runway in 1939. During World War II, in 1942, the U.S. Army took control of the site, expanded it by adding 826 acres, and 1 General aviation (GA) - Refers to all civil aviation operations other than scheduled commercial airline flights and military aviation.

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developed additional infrastructure, extending the original runway, building a second runway, taxiways, apron areas, and other facilities. The airport was officially opened for military operations in June 1942 as Santa Rosa Army Airfield. After the war, on July 8, 1946, Sonoma County resumed operation of the airport as a civil facility. Therefore, while initial construction began in 1939, the airport commenced operations in 1942 under military control and transitioned to civilian use in 1946.

STS, like all public airports in the United States, is regulated by the Federal Aviation Administration (FAA). Air traffic control, safety and runway facilities requirements, noise and other environmental impact and security administration must all meet FAA minimum standards. One particular aspect of FAA requirements pertains to Airport Master Plans: Advisory Circular (AC) 150/5070-6B outlines the recommended practices and requirements for developing airport master plans, which serve as long-term planning tools to guide the sustainable development of airport facilities. The FAA emphasizes that the master planning process should be tailored to the specific needs of each airport, whether it's a small general aviation facility or a large commercial service airport. This comprehensive document lists the many things that an airport is required to consider when establishing and executing its operational plans and budgets, including:

1. Inventory of Existing Conditions: A comprehensive assessment of current airport facilities, infrastructure, airspace, and environmental considerations.

2. Aviation Activity Forecasts: Projections of future aviation demand, including passenger enplanements, aircraft operations, and cargo volumes.

3. Facility Requirements: Identification of the necessary facilities and infrastructure to meet projected demand, ensuring compliance with safety and design standards.

4. Alternatives Analysis: Evaluation of various development options to meet facility requirements, considering factors such as cost, environmental impact, and operational efficiency.

5. Airport Layout Plan (ALP): A detailed, scaled drawing depicting existing and proposed airport facilities, which must be approved by the FAA for federally obligated airports.

6. Implementation Plan: A phased approach to development, including cost estimates, funding sources, and project timelines.

7. Environmental Considerations: Assessment of potential environmental impacts associated with proposed developments, in compliance with the National Environmental Policy Act (NEPA) and other relevant regulations.

8. Public Involvement: Engagement with stakeholders, including the community, airport users, and governmental agencies, to gather input and foster transparency throughout the planning process.

While initially serving general aviation, private, and charter flights, the airport currently hosts commercial carriers such as Alaska Airlines, Avelo, and American Airlines.

The airport's rapid expansion, particularly in the years following the post-COVID economic recovery, has made it into one of Sonoma County’s greatest success stories. It is the nearest airport to Sonoma county’s renowned wine-growing region and the greater North Bay area, with a service area encompassing more than 800,000 residents. The closest other major airports—Sacramento, Oakland, and San Francisco International—are significantly farther, making Sonoma County Airport a crucial gateway for both business and leisure travelers. Sonoma County Airport directly and indirectly supports approximately 1,700 jobs and has a significant multiplier effect on the local economy.

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Recognizing the airport’s increasing importance, the Grand Jury initiated an investigation to assess how effectively the airport is planning, adapting, and responding to its rapid growth. This inquiry was not driven by complaints or concerns of misconduct but rather by a commitment to ensuring that the airport continues to serve the county efficiently and sustainably. Given STS’ position as a major economic engine and essential public asset, it is critical to evaluate its development strategy, operational readiness, and long-term vision.

DISCUSSION
Airport Management and Operations
Sonoma County Airport is owned and operated by Sonoma County. The airport’s 22 staff members are county employees; the Airport Manager reports to the Director of the Sonoma County Public Infrastructure Department, who reports to the Sonoma County Executive, who reports directly to the Sonoma County Board of Supervisors. In fiscal year 2025, the Board approved the addition of two Airport Operations Specialist positions to enhance operational efficiency and safety. STS’s annual operating budget is $25.4 Million.

Terminal Modernization and Expansion:

In November 2022, the airport unveiled a modernized terminal following a comprehensive $40 million renovation project. The expansion added over 27,000 square feet, bringing the terminal's total size to approximately 56,000 square feet. Key enhancements included a renovated ticketing lobby, improved security lanes, additional boarding gates, expanded concessions, a new baggage claim area with dual carousels, and outdoor seating options. The project aimed to elevate the passenger experience and accommodate growing air travel demand.

Passenger Volume Trends:

Passenger traffic at STS has demonstrated a consistent upward trajectory in recent years:
• 2015: 263,142 passengers
• 2019: 488,179 passengers
• 2020: 195,303 passengers (a decline attributed to the COVID-19 pandemic) • 2021: 435,427 passengers
• 2022: 614,481 passengers
• 2023: 641,178 passengers
• 2024: 772,758 passengers
In 2024, Sonoma County Airport experienced record-breaking passenger traffic, with a total of 772,758 travelers, marking a 20.5% increase from the 641,178 passengers in 2023.

When evaluating STS's performance relative to similar regional airports of similar size and usage, several factors are noteworthy:
• Passenger Growth: STS has experienced a robust recovery and growth trajectory postpandemic, with 2023 passenger numbers surpassing pre-pandemic levels and 2024 volume establishing a new traffic record.
• Terminal Enhancements: The $40 million terminal modernization completed in 2024 was intended to position STS competitively, offering amenities and capacities comparable to other medium sized airports, thereby enhancing its appeal to both leisure and business travelers.

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• Airline Partnerships: The presence of carriers such as Alaska, American, and Avelo Airlines, offering direct services to 8 U.S. destinations, underscores STS's strategic importance and connectivity. Airport management continues to try to attract additional carriers and flights.

These developments align STS with national trends observed in regional airports that have invested in infrastructure and service enhancements to meet evolving passenger expectations and stimulate further growth.

Challenges and Opportunities
Sonoma County Airport has faced several operational and infrastructure challenges in the past year.

These issues, while documented extensively in local media, highlight the growing pains associated with increased activity at the airport, as well as the complexities of maintaining aging infrastructure and complying with FAA regulations. The following are among the most pressing issues currently affecting STS:

Runway Structural Integrity and Maintenance Deficiencies In mid-2024, Sonoma County Airport experienced significant runway issues, including the discovery of multiple sinkholes. In May 2024, a hole measuring between 12 and 18 inches in depth was identified on the main runway, leading to a temporary closure for emergency repairs. Subsequent inspections revealed additional pavement failures, which were linked to the deteriorating condition of a culvert beneath the runway. These structural deficiencies necessitated emergency repairs, and the airport has embarked on plans for further maintenance to ensure the continued safety and operational integrity of its main runway. The FAA recently notified the airport that the pace of runway repairs is unacceptable. This situation underscores the challenge of maintaining aging infrastructure at an airport that has seen increased traffic in recent years.

Noise Abatement Issues
Sonoma County Airport noise complaints from residents increased by more than 200% in 2024.

Complaints are largely attributed to the growing presence of larger, louder jet aircraft and new FAAmandated traffic patterns. As the airport experiences heightened passenger traffic, community members have voiced concerns over the disruption to their quality of life. These complaints have become a point of tension with residents pushing for changes, including potential adjustments to flight paths or operational hours, to mitigate noise levels.

Emergency Planning
The FAA requires every airport providing commercial passenger service to have a complete and comprehensive Emergency plan. The FAA has notified STS that the current Emergency Plan does not meet FAA standards, and that Sonoma County Airport is required to develop a compliant emergency plan. It has also found repeated violations of regulations for emergency services response time requirements, failure to update pilot communications regarding airfield communications, and a variety of other violations that collectively suggest inadequate airport management resources and non-compliance with mandated safety and operational regulations.

Master Plan and Strategic Planning
The airport’s current Master Plan was completed in 2007, with an update in 2011. The plan has not been regularly revised to meet the growing demands and challenges of an airport whose traffic has increased by more than 50% in the past six years and tripled in the past decade. The master plan, rather than being a proactive guide for future development, largely serves as a reactive update to the 2007 plan. The Sonoma County Airport Master Plan Update primarily revises projections rather than Agenda Item Number: 19 Agenda Item Number: 19
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offering a comprehensive, forward-thinking framework as recommended by FAA Master Plan guidelines.

The need for, and absence of, a fully updated long-term strategic plan is a significant concern and may partially explain why the airport has an ongoing history of operational and infrastructure issues.

Following FAA planning guidelines would have included:
• comprehensive assessment of facilities infrastructure (which should have noticed failing runways)
• implementation planning (such as proactive design to reduce TSA screening delays); and • public involvement regarding environmental concerns (which should have exposed the problems with revised traffic routes producing added air traffic noise) The Grand Jury recommends that the airport prioritize the development of a comprehensive, updated master plan that considers both immediate needs and long-term projections for the airport's growth.

A forward-looking plan will better position the airport to manage future demands and ensure compliance with evolving FAA regulations.

FAA Compliance requires more Resources and more proactive STS Airport Management While the airport is generally in compliance with FAA regulations, inadequate management resources have led to a lack of continuity and a reactive approach to issues rather than a proactive, anticipatory stance. The airport’s inability to handle aircraft noise complaints is one notable example of this issue.

The FAA sets takeoff and landing protocols for commercial airlines without input from the local airport or the surrounding community. Airport management was unaware of new FAA flight protocols until noise complaints began to surface. While the FAA is not required to consult with the airport in advance of such changes, more proactive airport management would have communicated the changes to the public before complaints arose and taken early steps to address community concerns. Airport management is now taking a reactive approach by engaging with the FAA to advocate for adjustments in future flight traffic patterns.

Another example of an FAA compliance issue: the airport’s property portfolio includes two countyowned properties that are not related to airport operations and are not generating rental income.

These properties—one an equipment yard for the Sonoma County Public Infrastructure Department and the other the North County Detention Facility operated by the Sonoma County Sheriff—do not comply with FAA regulations, which require all airport usage to contribute to the airport’s revenue.

While negotiations are ongoing to transfer some of this land back to the airport for public parking and to secure rental payments for the remaining property, these discussions have progressed slowly and remain unresolved at the time of this report.

More robust management structure is needed to improve the airport’s responsiveness to emerging issues. Proactive engagement with community concerns and FAA partners, especially regarding noise mitigation and operational changes, will help build stronger stakeholder relationships.

Organization structure concerns
Sonoma County Airport is a department within the Public Infrastructure Division of County government, a common organizational placement for small airports in rural counties. STS’s growth, however, has turned it into a regional airport with most of the requirements and challenges of a very public-facing agency: it needs long term investment plans, marketing and communication capability, Agenda Item Number: 19 Agenda Item Number: 19
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management succession plans, and staff capable of addressing a host of operational management challenges that are atypical for a local government agency.

The current organization structure has one manager, an assistant manager, four administrative assistants/aides, one IT specialist, a real estate project specialist, a marketing specialist, and an administrative services (budgeting & contracts) officer. Its 2025 budget is approximately 9% of the Public Infrastructure Division total budget, and it gets minimal Infrastructure Division senior leadership attention unless there are significant problems or opportunities.

The Civil Grand Jury notes that the Airport division of Sonoma County Public Infrastructure has essentially the same staffing today that it had in 2019 - while serving almost 300,000 more passengers and twice as many commercial flights. The only staffing additions during this 5-year period are an IT specialist and (2) operations staffers. Management resources and qualifications are unchanged, in an undeniably more challenging environment. In effect, county leadership is treating the airport as if the significant traffic growth and larger facilities under management don’t require more resources, or more capable staffing, than were needed to handle a much smaller business six years ago.

Sonoma County Airport significantly impacts multiple aspects of Sonoma county business development, interacts with (and answers to) both Federal and State of California authorities, and needs senior leadership that is able and empowered to navigate these challenges. The Civil Grand Jury notes that the Airport Division’s current organizational placement as an entity within a much larger Sonoma County department with other priorities may not result in the resources and leadership attention required for long-term success.

Facility Constraints and Parking Issues
The recently completed terminal expansion, while providing some relief, has left the airport with limited room for further expansion. The TSA checkpoint at Sonoma County Airport continues to be a bottleneck during periods of heavy traffic, with little room for dedicated “Pre-check” lines to expedite passengers with pre-cleared security profiles. The recently completed expansion has left the airport with limited room for further expansion to accommodate the projected growth in passenger traffic.

As passenger traffic has increased, Sonoma County Airport has been unable to meet the rising demand for parking. A notable instance of this occurred in October 2024 when the airport saw a surge of approximately 200 more vehicles than available parking spaces could accommodate. This increase coincided with the introduction of Avelo Airlines’ service to Ontario, California. The airport’s parking facilities are being stretched to their limits as passenger numbers continue to grow, raising concerns about the need for further investment in parking to meet demand.

Parking and passenger pick-up space limitations also led airport management to adopt a counterintuitive policy that precludes scheduled passenger pick-up by Uber and Lyft, the (2) major rideshare providers. Passenger inability to pre-arrange pickup, especially for early morning and late evening arrivals, means fewer passengers will choose to use third party transportation and thereby decrease parking demand.

Avelo Airlines closed its base at Sonoma County Airport on May 1, 2025, due to low demand and underperformance. While some routes will be discontinued, others like Burbank and Las Vegas will remain. The closure is expected to have only a minor financial impact on the airport—less than $200,000 in lost revenue. Passenger traffic and parking demand will likely decrease slightly, potentially easing parking demand. Airport officials believe operations will remain stable despite the Agenda Item Number: 19 Agenda Item Number: 19
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changes and are hoping to attract additional airlines and route service to enable continued traffic growth.

CONCLUSIONS
Sonoma County Airport is a critical economic and transportation asset for Sonoma County. It has grown rapidly from a sleepy general aviation airport to serve more than 700,000 passengers a year.

However, its current management structure and planning approach are not consistent with this growth, and are on a slow track to react. Current staffing and funding resources do not align with STS’s rapid growth and evolving role in Sonoma County. STS faces significant challenges in strategic planning, management continuity and capability, and facility capacity.

Sonoma County Airport must address structural runway construction deficiencies. Community concerns over air traffic noise, and inadequate parking capacity are hurdles that the airport must navigate as it continues to expand. Addressing these operational and infrastructure challenges will be critical in maintaining the airport’s role as a vital gateway to Northern California, while also ensuring it remains a good neighbor to the surrounding community.

The airport must also address all FAA compliance issues and further enhance the physical infrastructure to fully capitalize on its potential as a regional economic driver. During the past 5 years, Sonoma County Airport has demonstrated resilience and growth, and these efforts position the airport favorably among its national peers and contribute significantly to the region's economic vitality and connectivity, but the lack of a comprehensive forward-looking master plan is a significant concern that will likely constrain future development.

Looking ahead, STS aims to continue its growth trajectory by attracting additional airline services and expanding its destination offerings. Ongoing investments in infrastructure and community engagement are central to the airport’s strategy to strengthen its role as a key transportation gateway in Northern California. However, airport management must also recognize and proactively plan for increased airline activity and expanded flight schedules if it hopes to sustain growth while maintaining satisfactory customer service.

FINDINGS
The Sonoma County Civil Grand Jury determined that:

F1. Charles M. Schultz - Sonoma County Airport’s failure to update and execute its Master Plan in compliance with FAA recommendations is a root cause of airport maintenance and development problems.

F2. STS’s current management resources are more appropriate for a general aviation or small commercial airport than for the medium sized passenger airport that Sonoma County Airport has become.

F3. Sonoma County Airport’s management is reactive rather than proactive due to inadequate resources and staffing.

F4. Sonoma County Airport projects compete with road repair, traffic management, purchasing and other projects for senior Public Infrastructure Department leadership attention.

F5. Parking is the largest airport revenue source, but the absence of adequate parking on site is a material barrier to continued growth.

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F6. Sonoma County use of airport land for non-airport purposes without paying rent could expose the County to significant FAA penalties.

RECOMMENDATIONS
The Sonoma County Civil Grand Jury recommends that:

R1.By November 1, 2025, Sonoma County Public Infrastructure will determine how to resolve all FAA non-airport land use issues and submit this plan for Board of Supervisors’ review.

R2.By December 1, 2025, the Sonoma County Executive Officer will evaluate whether Sonoma County Airport should continue to be a department within Public Infrastructure or become a stand-alone agency and will forward an appropriate recommendation to the Board of Supervisors.

R3.By December 1, 2025, the County Executive Officer will evaluate the need for engaging a qualified Airport Master Plan consultant as suggested in FAA Advisory Circular (AC) 150/5070- 6B to facilitate a comprehensive review of the Charles M. Schultz-Sonoma County Airport Master Plan.

R4.By June 1, 2026, Sonoma County Airport shall complete and publish a full update of the Airport Master Plan using the most current version of FAA Advisory Circular (AC) 150/5070-6B to guide requirements for completing the updated plan.

REQUIRED RESPONSES
Pursuant to Penal Code §§ 933 and 933.05, the civil grand jury requires responses as follows:
• Sonoma County Infrastructure Department to respond to F1, F1, F3, F4, F5; R1, R4 • Sonoma County Executive Officer to respond to R2 and R3

BIBLIOGRAPHY AND REFERENCES
• US Department of Transportation - FAA, “Airport Master Report”, December 9, 2024. • Press Democrat, “Sonoma Jet Center sues Sonoma County Airport, raising concerns over fuel tank project as feud breaks out between tenants.” June 22, 2024. • October 17, 2024, Sonoma County Airport Commission meeting notes. • County of Sonoma, “Charles M. Schulz – Sonoma County Airport report to Board of Supervisors shows continued growth in passengers, revenue.” October 16, 2024. • Sonoma County Airport, “Master Plan” 2007.
• FAA Reauthorization Act of 2018, Section 163 Grant Assurance #25.

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Permit Sonoma 2025
Management Review is a Beginning, not an End

SUMMARY
In August of 2024, the Sonoma County Civil Grand Jury set out to answer two simple questions:
how many residential construction permits are issued in the unincorporated area of Sonoma County each year, and how long does it take to get a permit? Finding answers was harder than expected, and the inquiry became a more comprehensive investigation of Permit Sonoma.

Permits are required to construct (or modify construction of) any structure of public interest – meaning all residences and buildings that might be habitable or otherwise occupied by people. A permit is required to add or replace anything that might affect public or personal safety in a building:
a water heater, solar panels, or even a new deck railing. Permits are a prerequisite to any work that must comply with legal requirements for environmental standards, zoning and property line encroachment, or any construction in a County “special area” with specific building style, placement or reflectivity constraints. A common perception of the permit process is that it will take forever to get a permit, cost way too much, and require more expertise and patience than the average person could possibly have. The Civil Grand Jury decided to assess this perception to see whether it is true for Permit Sonoma.

Delays in permit processing have the practical effect of hindering housing construction in many locales and can be an effective tactical tool to delay or prevent housing construction. Permitting delays lead to construction delays, which lead to housing shortages. Therefore, in 2022 the California State Legislature took action to reduce roadblocks by passing a law (Assembly Bill 2234) requiring all county and city permitting agencies to review and issue construction permits on a timely basis. Coincidentally, the Sonoma County Board of Supervisors concluded that the county would benefit from an independent review of construction permitting in Sonoma County and engaged Berry Dunn (a management and workflow consulting firm) to conduct a formal assessment of Permit Sonoma’s performance. The consultants’ final report was presented to the Board of Supervisors in January of 2023.

Equipped with this information, the Civil Grand Jury amended its inquiry and initiated a formal investigation of Permit Sonoma with the intent of answering these two questions:

1. Is Permit Sonoma meeting the requirements for permit review and issuance established by AB 2234?

2. Has Permit Sonoma made significant progress toward adopting and implementing the specific recommendations included in the Berry Dunn report?
The conclusion: Permit Sonoma is essentially meeting requirements for AB2234 and fulfilling the Berry Dunn Report recommendations. This report will tell you how Permit Sonoma’s performance compares with internal goals set in 2024 in response to the Berry Dunn report recommendations. The Civil Grand Jury also learned that Permit Sonoma’s workflow isn’t as efficient as it could be: there are loose ends to tie down and systemic impediments to overcome, and we will suggest how Permit Sonoma could make permit application better, faster, and cheaper in the future.

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METHODOLOGY
The 2024-2025 Sonoma County Civil Grand Jury (Civil Grand Jury) • Conducted more than 20 interviews with Permit Sonoma staff & leadership, third party contractors and service providers
• Reviewed and analyzed more than 500,000 data records related to construction permit applications
• Researched permit activity for other California counties and cities’ timely performance, selfcertification and over-the-counter permitting processes and workflow systems deployments • Reviewed Sonoma County ordinances regarding Permit Sonoma (and its predecessor Permit and Resource Management Department) authority and Sonoma County building and safety codes

BACKGROUND
What is Permit Sonoma and What Does It Do?
Permit Sonoma (PS), formerly known and formally ordained as the Permit and Resource Management Department (PRMD), is a Sonoma County government agency established by Sonoma County Ordinance 4906 in 1995. It is responsible for regulating construction projects to ensure that new buildings, structures, or renovations meet local, state and federal standards for structural safety, health, environmental efficiency, and (in the case of ‘area-specific plans’) community expectations constraining land use, housing density, and construction appearance. Permit Sonoma is also charged with developing and organizing county-wide plans for new housing construction and critical review of proposed housing developments in the unincorporated areas of Sonoma County. In the words of Permit Sonoma senior leadership, “our mission is … to support our entire community, through excellent customer service, to balance environmental protection with sustainable development.” Oversight of these processes means Permit Sonoma has enormous influence on construction efficiency in Sonoma County, from initial design to finished build—and if Permit Sonoma does its job well, County residents should see lower construction cost, faster project completion, and ultimately more and better housing at all price points. Conversely, inefficiencies in Permit Sonoma operations can slow down construction progress, delay project completion, and make housing more expensive at all price points.

Why Does Permit Sonoma Do What It Does, and Who Put Them in Charge? Permit agencies play a crucial role in safeguarding public welfare and ensuring orderly development in communities. Their work addresses several key objectives:
• Public safety: Ensuring buildings are safe for occupants and the surrounding community, and preventing accidents or disasters, such as building collapses, fire hazards, or electrical failures. • Planning: Assisting local governments with planning for sustainable development and helping balance growth with environmental considerations and infrastructure needs. • Reasonable use of and demand for public infrastructure: Ensuring new developments do not overload existing infrastructure (e.g., roads, water systems, waste disposal) by adhering to guidelines that balance growth with available resources.

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• Compliance with local, state, and federal requirements: Ensuring that construction projects comply with a broad range of legal requirements, from local zoning laws to state fire codes and federal accessibility standards.

In California, a permit agency’s authority comes
from both state and local governments. The State of
California grants overarching authority to local
permit agencies through state laws and regulations,
particularly through the California Building
Standards Code. California law allows local permit
agencies to amend the state building code, in line
with their own specific zoning laws and development
guidelines. Specifically, localities may add specific
requirements but may not prescribe lesser standards
than are required by the state code. You can find an
abridged version of Sonoma County’s local building
code on the PS website and a complete copy of
County ordinances is also available online; chapters
7, 11 and 13 are particularly relevant.

The California Building Standards Code is updated
every 3 years (most recently in 2022) and is largely
based on the International Building Code (IBC).

These updates are part of an ongoing effort to
incorporate new knowledge, technology, and best
practices for builders; improve building safety,
sustainability, and energy efficiency; respond to
emerging threats such as climate change; and
incorporate advances in construction materials.

How Does a Permit Agency Ensure That Buildings
Comply with the Building Code?
Permit agencies ensure that buildings comply with
the building code through a two-fold process: plan
checks and inspections.

Plan checks: Before construction begins, developers or homeowners submit their building plans to the permit agency. A trained plan checker reviews the plans to ensure they meet all relevant building codes, zoning laws, and safety standards. This step is crucial for preventing non-compliance before work even begins.

Inspections: Once construction starts, permit agencies conduct periodic inspections to ensure work is done according to the approved plans and building codes. Inspectors visit the site at various stages of construction, including foundation, framing, electrical installation, and final completion, to ensure everything is up to standard. If non-compliance is found during inspections, the construction project may be halted, and corrections will be required before the project can move forward.

Plan checkers and building inspectors typically have backgrounds in construction, architecture, or engineering. They are required to have specialized training and certifications to ensure they understand and can apply building codes effectively. The following qualifications are typical:

A quick history of California Building Codes
California’s first official statewide building code was established in 1927, with the adoption of the California Building Standards Code. The code has evolved since then, incorporating updates based on changes in technology,
building materials, and safety knowledge.

What Major Laws lead to the California Building Code?
Over the years, several major laws have amended the
California Building Code to address safety concerns,
technological advancements, and changesin community
needs. Here are some significant changes:

Title 24: Title 24, known as the California Code of
Regulations, is a comprehensive set of regulations that includesthe California Building Standards Code. This code governs all aspects of construction in California and was first established in the 1970s. Title 24 is regularly updated to reflect changes in building safety, energy efficiency, and accessibility standards.

The California Energy Code (Title 24, Part 6): One key
amendment to Title 24 came in the form of more stringent energy efficiency standards. The state has continually
updated these standards, aiming to reduce the
environmental impact of construction and improve building sustainability.

The Americans with Disabilities Act (ADA): In response to the ADA, California made significant amendmentsto buildin codes to ensure accessibility for people with disabilities, mandating features such as ramps, wider doorways, and
elevators in larger buildings.

Seismic Safety Laws: After devastating earthquakes in the 20th century, California’s building codes were significantly amended to address seismic safety, especially in areas such as Los Angeles, San Francisco, and other earthquake-prone regions.

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Education: A bachelor’s degree or equivalent experience in civil engineering, architecture, or construction management.

Certifications: Many plan checkers and inspectors hold certifications from organizations like the International Code Council or California Building Officials. These certifications indicate a professional’s knowledge of building codes and construction practices.

Experience: Several years of practical experience in construction or a related field are often required before becoming a plan checker or building inspector.

How Many Permits Does Permit Sonoma Process? The chart below was obtained from Permit Sonoma web site data:

Permit Sonoma Annual Activity Report
Division Permit Type 2022 2023 2024
BLD Building 8,696 8,100 8,003
BLD Building - Demolition 798 603 515
BLD Building - Field Review 19 3 9
BLD Safety Assessment NA 67 115
Subtotal, Building Division 9,513 8,773 8,642
ENG Encroachment 532 518 389
ENG Engineering Project 24 20 30
ENG Grading 274 242 217
ENG Surveys & Improvement Plan 368 13 28
ENG Low Impact Development 16 3 11
ENG Roiling 2 6 3
ENG Sewer Construction & Fees 275 204 175
ENG Storm Water 1 3 10
ENG Transportation 858 682 685
Subtotal, Engineering Division 2,350 1,691 1,548
W&S Gray Water Systems 7 3 1
W&S Septic Design 22 20 23
W&S Septic 562 421 364
W&S Well & Septic Field Review 890 597 391
W&S Well & Well Study 558 431 464
Subtotal, Well & Septic Div 2,039 1,472 1,243
PLAN Admin Design Review 110 86 83
PLAN Minor Subdivision 8 16 18
PLAN Planning Project 34 27 28
PLAN Use Permit 74 52 103
PLAN Vacation Rental License NA 266 1,334
PLAN Water Resource Monitoring 223 14 46
PLAN Zoning Permit 241 182 215
Subtotal, Planning Division 690 643 1,827
Total, Permit Sonoma 14,592 12,579 13,260
Total, Ex Vacation Rental Licenses 14,592 12,313 11,926 Agenda Item Number: 19 Agenda Item Number: 19
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This is an incomplete list, as there is at least a dozen more types of permits, including “design review”, environmental impact assessment and “building envelope modification”1 applications.

There is a noticeable decline in the number of permit applications since the peak (Covid) year of 2022. The data was developed from Permit Sonoma’s web site.

How does Permit Sonoma Do What It Does?
Applying for a permit is a fairly straightforward process, even though many (especially amateur/homeowner) applicants find the process daunting. Based on documents on the PS website describing permit application flow, here is a standard workflow diagram that encapsulates the process:

This diagram understates the complexity of the permitting process when the application is for more than simple permits (such as water heater replacement or electric panel upgrades): over and above construction code compliance, applications may need to be checked for conformance with local zoning, availability of septic capacity, and potentially dozens of related conditions. Regardless, Permit Sonoma’s basic workflow is the same: determine the list of applicable requirements; check the plans to see if they’re compliant; inform the applicant of any identified issues and request resubmission of conforming plans; or issue the permit when everything looks good. And, of course, collect permit application fees.

Prior to 2017, Permit Sonoma did everything on paper: record keeping was done manually, and permit applicants usually had no idea how far along the plan check path the permit had progressed, or even which engineer had been assigned to review plans. Permits, when issued, were on paper and paper copies of the permit were required to be attached to an official set of plans (maintained on site, along with a paper copy of inspection(s) records).

In 2017 (a few months before the Tubbs fire), Permit Sonoma contracted for a “Workflow Management” software package from a company, Accela, to keep track of “who’s done what, where, and when” with application paperwork. As the system was deployed across all PS departments, applicants began to benefit too: they could see online when an application had been accepted for plan check and get rudimentary information about the processing status of their permit application(s).
1 “Building envelope” is the area of a zoned plot designated as the allowable building location. Plans to construct a building outside the recorded building envelope require an additional application and fee.

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Then Covid hit in 2020 and shut down Permit Sonoma’s physical interaction with permit applicants.

PS switched almost immediately to electronic submission of (formerly paper) plans. PS plan checkers switched to electronic review of plan documents, which required running changes to the Accela workflow management system. It also exposed shortcomings in the workflow:
communications previously handled by permit employees walking to an adjacent cubicle had to be done electronically. Accela modifications were the only practical solution, so during the next 2 years Permit Sonoma adapted by adopting and developing a series of changes to Accela-based workflow in conjunction with functional reorganization of “who does what”.

Today, every aspect of PS’s interaction with permit plans and applicants is (supposed to be) noticed and tracked in Accela so that staff, management and applicants can see their application status at any moment, including who has signed off, who still needs to sign off, and what changes (if any) are needed to get a permit issued. For the most part, the system works well enough. At any given time, PS has a thousand or more permits in some stage of completion, is working on 500-1,000 new applications every month, and the current state of each application can be seen on the PS web site.

Processing Permit Applications Faster: California Assembly Bill AB2234 (2022) The Covid emergency elevated public awareness of California’s housing shortfall and multiple legislative efforts resulted: Project Homekey (AB 83, 2020) provided funding to convert hotels and motels into short term housing for homeless people; the California Home Act (Senate SB9, 2021) required localities to permit lot splits and accessory dwellings in many more places than had been previously allowed; and the Assembly passed AB 2011 in 2022, allowing residential housing on commercially zoned lots in locations that many cities and towns had forbidden.

In 2022, the state legislature concluded that one reason for the statewide housing shortage is that it simply takes too long to get permission to build. Many localities (generally not Sonoma County) use permit processing slowdowns as a first line of defense against housing development, and permitting delays were a significant contributor to the state’s housing construction issues. Assembly Bill AB2234 establishes a simple requirement: permit agencies are required to review a permit application for completeness within 15 (business days and completed applications must then be assessed for code and ordinance compliance within 30 business days. Failure to meet these deadlines carries a significant penalty: by law, if a permitting agency doesn’t do its job consistent with the requirements of AB2234, the application will be considered accepted.

Permit Sonoma is the Sonoma County agency that is required to meet these targets. Each “Authority Having Jurisdiction (AHJ)” in the County’s nine cities are also required to comply with AB2234.

NB: this report is limited to discussion and review of the County agency, not the city AHJ’s. The statute includes definitions and legal caveats that add specific requirements and exceptions to this simple statement, but both the language and the requirements are straightforward and understandable. [A more comprehensive summary of the law is included in Appendix 1].

Improving Permit Sonoma Performance: The Berry Dunn Report The Sonoma County Board of Supervisors (BoS) is ultimately responsible for the performance of all County agencies. In February of 2022, the BoS decided it would like an independent assessment of Permit Sonoma’s operations and engaged third party experts to conduct the analysis. In January of 2023, the list of calendar items on the County Board of Supervisors’ agenda included this notice:
“The Sonoma County Administrator’s Office (CAO) periodically conducts department reviews to evaluate County departmental programs, operational, and organizational effectiveness. Permit Sonoma was selected for review.”
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… “The consultant, Berry Dunn McNeil & Parker LLC (Berry Dunn) delivered the results from their management review of Permit Sonoma to the Board of Supervisors on January 31, 2023. Permit Sonoma is actively working to implement changes identified in the review, make our permitting more efficient, and improve our customer service.”
The Berry Dunn Report (BD Report) includes many observations regarding PS workflow and behavior, and concludes with 15 specific recommendations in three general categories:

1. Change the way Permit Sonoma works, in ways that benefit the customer.

2. Establish explicit permit processing performance targets and make sure that hard data exists to measure throughput.

3. Ask your customers to tell you how PS can do a better job and then do what they tell you.

Permit Sonoma leadership reviewed these recommendations with the Board of Supervisors in February of 2023, and accepted all of Berry Dunn’s recommendations.

How well is PS doing towards these goals? According to a management update delivered to the Board of Supervisors in February 2024, Permit Sonoma has done a great job of achieving all of its objectives:
“In aggregate, the result is a 67% reduction in processing times acrossthe department’s most common permit types without compromising critical compliance reviews that keep our community safe.” Average Days to Review Reduction
Permit Type June 2023 Dec 2024
Building Permit 71 23 68%
Encroachment Permit 49 22 55%
Grading Permit 82 41 50%
Septic Permit 98 21 79%
Well Permit 123 18 85%
Average 67%
Permit Sonoma’s update to the Board of Supervisors concludes as follows:
“…the service that is being delivered to the residents of Sonoma County has been continually strengthened over the last 18 months. In addition to the average 67% reduction in permit response times the department has strong customer service scores from our permit center surveys with a positive response of 95.41% out of 1,592 survey respondents…. has also resulted in stronger working relationships between the department’s six divisions and has laid the groundwork for improving employee recruitment, onboarding, and retention.”

DISCUSSION
Is Permit Sonoma Compliant with AB2234 Requirements?
Assembly Bill 2234 has two distinct timely review requirements: first, that submitted applications be reviewed for documentary completeness within 15 business days and either accepted or returned to the applicant with specific notice of any insufficiency; and second, an accepted application must be reviewed for compliance with construction codes, zoning and planning ordinances within 30 business days of acceptance.

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Requirement 1: 15 Days to Review an Application for Completeness The Permit Intake department is the PS gateway for all new permit applications and is also the department tasked with explaining document review requirements to prospective permit applicants.

We reviewed thousands of 2024 initial permit applications and are pleased to report that Permit Intake only failed to review applications for completeness and acceptability within the 15-day limit a handful of times – out of more than 7,000 permit applications. That being said, the way that Permit Intake interacts with Accela makes it VERY difficult to prove the truth of this statement: AB2234 makes it clear that if an applicant is informed that documentation is incomplete or inadequate, the 15-day clock resets. However, Permit Sonoma’s Accela system doesn’t reflect the reset so PS Permit Intake’s Accela data can’t be used “as is” to report permit acceptance performance versus AB2234 requirements.

One of the senior managers within Permit Sonoma has developed a ‘work around’ for this Accela system shortcoming: Permit Intake records are extracted from Accela and inserted into a homebuilt Microsoft Access database, wherein a series of scripts and queries converts the inconsistent Accela data into a form that allows for Intake and Acceptance date calculations. The results of this data manipulation are used to inform PS management about its general performance (and identify problematic applications nearing the 15-day limit) but is not the permanent and auditable solution that would exist if Accela were modified to integrate this functionality.

Requirement 2: 30 days post-acceptance to Review and Comment on Plan Issuance After a plan is accepted by Permit Intake technicians, applicants are required (in most cases) to pay for the time it will take Permit Sonoma to review the details of the proposed work for compliance with building codes, zoning requirements, stormwater and erosion control, and myriad other rules governing permit issuance. Payment of this plan check fee triggers a second clock under AB2234:
review the plans and issue the permit within 30 business days or tell the applicant why it isn’t acceptable. These “Plan Check Comments” are required to be specific and comprehensive, such that an applicant knows exactly what changes need to be made to application documents for successful plan resubmission.

AB2234 requirements presented new but (mostly) manageable processing timelines for Permit Sonoma. The most challenging problem still hasn’t been solved: while each of the plan check department managers have their own way to keep track of plan check engineers’ progress, PS’s Accela system implementation doesn’t include management reporting that reliably tracks the amount of time between the “Plan Check Fee Paid” date and the date when comprehensive Plan Check Comments are sent. When multiple departments are required to review the plans, Accela records the date when each department does its work, but there is no systemic recognition of the requirement for all departments to complete their work within 30 business days—and if any one department hasn’t finished its work, they can all be deemed to have failed to meet the statutory requirement.

The Civil Grand Jury knows this is a problem because it tried (on multiple occasions over many, many hours) and failed to identify a programmatic method for confirming the actual amount of time PS was taking to get from plan check start to first comments sent. Interactive review with PS staff and management confirmed that the problem is real: the Accela database can be queried to retrieve sets of records that are representative of the work being done, but there is no way to reliably and consistently calculate how much time has elapsed since the clock started ticking–and it will take PS and Accela a significant amount of work to fix this problem. The Civil Grand Jury shared this experience, with multiple members of Permit Sonoma staff and management, and confirmed that this is a known problem within PS. The recognized "solution" is the ad hoc Microsoft Access system Agenda Item Number: 19 Agenda Item Number: 19
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referenced above — with the same caveats: the integrity of PS’s Access-based tool is neither audited nor auditable, and its maintenance depends on a single individual. If that person leaves the department, critical knowledge may be lost.

Caveats and concerns aside, the Civil Grand Jury can report that a time-consuming manual review of more than 5,000 permit review task status records for the months of February and October, 2024 found that fewer than 20 of ~1,100 permit applications requiring plan check failed to meet the AB2234 requirements. All of the failures were permits that required review by multiple departments; and we saw meaningful reductions in overall processing time between February and October of 2024.

Has Permit Sonoma Fully Implemented the Berry Dunn Report Recommendations? California Civil Grand Juries are chartered to conduct independent inquiries and investigations into local government operations, so in the words of the old Russian adage that Ronald Reagan repeated to Mikhail Gorbachev: “Trust but verify”. Here’s what we learned about Permit Sonoma’s progress toward implementing the Berry Dunn recommendations:

1. Berry Dunn categorical recommendation: change how PS works in ways that benefit the customer
In Permit Sonoma’s traditional workflow, plan check was a serial process and each person in the queue waited to be notified that the person before them had completed their task. Berry Dunn suggested an alternate approach: work in parallel and use the Accela system’s workflow management capabilities to keep track of “who’s done what” using systems-based tools to trigger additional review as needed. Implementing this approach required several significant changes to Permit Sonoma operational process:
• Establish Standard Operating Procedure: Everyone in the workflow chain needs to use a known and standardized set of operating procedures (SOP).
• Integrate the Procedural Steps into the Accela Workflow: These procedural steps need to be incorporated in the Accela system so when significant progress is made, everyone who needs to know (including the customer) is informed–and conversely, when issues arise, people who can fix the problem are invited to do so.
• Permit Sonoma had to find ways to deal with seasonal loads that increase the volume of plan checks in excess of PS capacity.
• Permit Sonoma should have the ability to outsource plan check and certification of field work to third parties whenever practical, especially in cases where this would produce customer cost savings. One major point of emphasis was review of permit types to see how many additional types of permits could be issued “over the counter” to reduce the number of simple applications flowing through a system designed to handle complex permits.

BD Recommendation: Establish Standard Operating Procedures Similarly skilled personnel in different departments all work in similar ways, but the absence of globally standard operating procedures (SOPs) for Accela nomenclature, combined with inadequate staff training regarding Accela system changes and updates means that SOPs aren’t actually standardized across departments. For example, almost everyone in Permit Intake and the six plan check departments uses a personal checklist to review application documents, but there is no universal checklist that is used department-wide in any PS department—let alone standardized across all of Permit Sonoma.

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PS has undertaken an agency-wide effort to develop SOPs for each PS department but only one department (Code Enforcement) has actually published a document that could reasonably be described as a formal SOP framework; most other departments have made an effort to initiate SOP development but have considerable work to do to complete this task. After the individual departments are done establishing their own SOP’s, the entire agency needs to finish the task by establishing and implementing standardized cross-department procedures—a task that hasn’t been started, let alone completed.

Failure to implement efficient and standard operating procedures is costing Permit Sonoma money and time and is an opportunity for future improvement.

BD Recommendation: Integrate Procedural Steps into the Accela Workflow The good news is that PS customers have much more visibility into the status of their permit application than they had even one year ago. One HUGE improvement: customers can see the names and phone numbers/email addresses of the individuals assigned to process their permit applications so they know who to contact when questions arise or when the review process is stalled. Additionally, inconsistencies in task names and status have been reduced (although there are still instances where departments use different names for the same task).

The bad news? As currently implemented by Permit Sonoma, Accela only handles process tracking, not workflow management. There’s more work to be done on the Accela implementation and no plan to do it. While the data for each individual permit application is reliable, highly likely to be accurate, and shared with the applicant, two permits for exactly the same type of work, processed by different Permit Sonoma employees, may be described differently in the Accela system and/or recorded more or less accurately. Consequently, the Accela system as implemented by PS doesn’t produce reliable reports on individual and aggregate employee performance. Given the fact that reports generated externally via Microsoft Access are not integrated into Accela, their results are impossible to verify independently.

BD Recommendation: Develop Systemic Awareness of Interdepartmental Collaboration Requirements
Complex permits for major remodels and new construction usually require action by multiple PS departments with overlapping requirements. For example, a building permit might require a well and septic permit that calls for additional leach field capacity—which requires agreement by Engineering that the site can be graded—before issuing a permit involving additional bedrooms.

Permits can’t be issued until all conditions are met, and when they involve multiple PS departments, each department needs to be systematically aware of outstanding tasks that must be completed before other departments can finish their work.

The Accela system currently tracks task status within each department but has no facilities (other than engineers posting “Read Me” comments) for communicating interdepartmental dependencies. A true systematic workflow would recognize these dependencies and ensure that every permit’s interdepartmental status and sequence is understood across all of PS. This shortcoming results in systemic delays and is also the reason that sometimes permits get “lost” while each department waits for another department to act.

Commercial entities often use “program management” systems and personnel to ensure that complex processes proceed in an orderly fashion. Currently, no individual or department within Permit Sonoma is tasked with ensuring that all necessary inter-department work proceeds on a timely basis. Complex permit processing—especially for projects that involve both Planning and Agenda Item Number: 19 Agenda Item Number: 19
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Engineering review and require public notice—would benefit from PS adoption of standard program management methods.

The remaining Accela work recommended by Berry Dunn should be completed, even though it will require currently unbudgeted work and additional management attention, for 3 reasons:
1) Management, staff and applicants should know at every point along the permit issuance path how much time has been taken to get to issuance, and how much more time is left before the permit can legally be presumed to have been issued. This requirement is implicit in AB2234’s statutory requirement.
2) Interdepartmental communications regarding “Who’s doing what, and are they done yet?” is the single biggest challenge that PS has toward achieving significantly improved permit throughput for complex applications. Fixing systemic issues preventing the simple calculation and reporting of elapsed time will also reduce time wasted by one department not realizing that another department had finished its work. While this problem doesn’t happen as often as it used to, it shouldn’t happen at all.
3) Permit Sonoma senior management, the County Executive, and the Board of Supervisors cannot know how well the Permit Sonoma staff is doing its job until this problem is fixed.

As currently implemented, the workflow system is far from perfect. It could certainly be easier to use (for both applicants and staff), more comprehensive in its record-keeping capabilities, and provide much more “exception reporting” to facilitate management and customer insight and intervention. If Permit Sonoma workflow is improved, permit processing could be much faster for everyone—and cheaper, too. So, regarding this group of Berry Dunn recommendations, “there are still a few bugs in the system” and Permit Sonoma has more work to do. PS’s Board of Supervisors update is generally accurate, but tasks recommended by Berry Dunn are not as complete as has been reported.

2. BD Categorical Recommendation: Use Third Party Plan Check and Self-Certification to Cut Permitting Times
The Berry Dunn report made five specific recommendations to help applicants get permits more quickly at lower cost. By adopting the BD recommendations, Permit Sonoma committed to the following:
• Over the Counter Permitting: Expanding the range and scope of permits that could be issued “over the counter”.
• Express Permit Review: Implementing an Express Permit review process that would engage all reviewing departments concurrently (instead of each department waiting until precedent reviewers had completed their work).
• Third Party Plan Check: Employing (licensed and certified) 3rd party engineering firms to augment the Permit Sonoma plan check staff both for cost-saving and load management purposes.

The Civil Grand Jury reviewed permit application data to see whether the impact of each of these initiatives could be verified. Permit Sonoma staff and management were interviewed to gather their collective opinion on the success of (and enthusiasm for) changing workflow in these ways. Here is a brief summary of learnings:

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BD Recommendation: Over the Counter Permitting (OTC):

One might think that a search for “over the counter” on Permit Sonoma’s website would lead to a description of all the work that can be permitted this way… perhaps even a specific form or forms that would make a simple permit application fairly painless. One would be wrong.

The search returns just 10 documents, and here is all the text in those 10 documents that actually refers to “over the counter” building permits:
“Building permits for minor work, such as a re-roof, new water heater, electric upgrade or other work that does not involve any structural modification, can be issued over the counter.” and (regarding installation of new electric service to residential or commercial construction) “Residential Service…400 amp or less: No plans required. Can be issued over the counter with no plan check.” That’s all. No form and certainly not a complete list of work that can be permitted over the counter.

Here is a more complete list of work that may be permitted “over the counter” without plan check required (obtained by reviewing actual permits issued over a 6-month period):
• Water heater replacement
• New electric service and meter
replacement
• Replacement of heating and cooling
systems
• Replacement of roofing shingles not
requiring structural modifications
• Siding replacement
• Some (but not all) residentialsolar panel
installations
• Sidewalk and driveway repair
• Minor interior remodels with no structural
changes
• Minor demolitionssuch as septic tank
destructs
• Covered parking waivers, legal
nonconforming determinations
• Temp campaign signage
• Designating structures as Accessory Dwelling
Units
• Residential setback reduction with neighbor
approvals
• Telecom tower modification
Permit engineers were asked to suggest other items that could or should qualify. For example, if an electric service is upgraded, could the load panel design be self-certified by a licensed master electrician? How about installing a Level 2 EV charger in a garage? Or even replacing an air conditioner and forced air heating system with a heat pump? Virtually everyone we spoke to had ideas for work that could be permitted OTC, but no one in authority has plans to actually add OTC permit types to the list. Nor is there a formal process to submit additional types of OTC permit recommendations.

BD Recommendation: Express Permit Review
The idea for “express permitting” came from within Permit Sonoma staff, and it’s simple and exciting: put someone from every department responsible for reviewing routine building permit applications in the same room, (virtually) pass the plans around the room to see whether any department has material concerns, and (finding none) approve the permit on the spot! The goal is to eliminate the typical delays that happen during serial application review and ensure that every department that needs to review an application does so on a timely and rapid basis. And… it works! The process was tried for the first time in the fall of 2024, with excellent results: half a dozen permit applications were reviewed and issued in an afternoon, saving weeks of time for applicants with no additional work on Permit Sonoma’s part. Since then, the Express Permit team (an ad hoc group with one engineer from each plan check department in Permit Sonoma) has been meeting (almost) every week and the Express Permit team self-reports that the process works well, is effective, and saves Agenda Item Number: 19 Agenda Item Number: 19
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both applicants and Permit Sonoma time and money. Permit Sonoma staff says they plan to continue, and possibly even expand, collaborative application review in the future beyond the 8-10 typically processed during the current pilot.

Why not make Express Permit review the default SOP? Reportedly, expanding the scope and scale of the Express Permit program would require changes to organization structure and ‘additional resources’ (meaning more staff) so significant expansion of this innovation is unlikely.

The Civil Grand Jury disagrees with PS management on this point: knowledgeable members of staff believe a much higher percentage of permits could be processed using the Express approach without additional resources, and observations suggest that the staff is correct. The “express permit” process doesn’t work well for complex projects with significant engineering challenges, but these applications are a small fraction of Permit Sonoma’s residential construction volume.

BD Recommendation: Self-certification of construction plans and installation methods This is a concept that every quality builder has wondered about since permits were first required in ancient times. The BD Report recommended that licensed (and insured and certificated) professionals including architects, structural and civil engineers, master electricians and plumbers and other specialty engineering trades should be allowed to check their plans for code compliance and certify that their work has been done conformant to both plan and code, rather than have to call a County inspector to come to the jobsite and check it for them.

This isn’t a new idea, nor is it original to Sonoma County: the city of Bellflower has had a plans selfcertification program for some years; Riverside County allows self-certification of a variety of construction work and Los Angeles is considering a new ordinance allowing self-certification in the wake of the devastating Eaton and Palisades fires, in hopes of expediting fire rebuild construction.

Sonoma County has also experimented with self-certification. Permit Sonoma allows over-thecounter permitting for roofing material replacement, with self-certification of the work after it’s done, and a majority of roofing replacement is already being done this way. Permit Sonoma is also considering (but has not yet committed to) allowing some earthwork and grading to be self-certified in the future.

Permit Sonoma staff are not optimistic about significant expansion of this program, however. A quick look at this February 2025 Permit Sonoma activity report will demonstrate that the majority of Permit Sonoma building permit applications (289 of 525) require no plan check – but still charge a plan check processing fee – and 25-50% of the remaining applications are for solar panel and battery installations which are largely routine designs.

Examples of allowable “Building Permit No Plan Check” applications include (in addition to roofing) hot water heater replacement, window replacement, electrical panel replacement, deck board and home siding replacement, plumbing fixture replacement, sidewalk repair, and driveway repair. All seem to be good candidates for self-certified inspection by master tradespeople.

It should also be noted that, in other locations where self-inspection of trade work is allowed, the Authority Having Jurisdiction (i.e. Permit Sonoma in our case) retains the right to inspect. In most other AHJ’s, inspections are conducted randomly with loss of self-certification privileges resulting from failed inspections.

BD Recommendation: Third Party Plan Check
The analysis done to produce the Berry Dunn report occurred at a time when Permit Sonoma had a big backlog of permit applications. Covid workflow hadn’t yet been fully implemented and many Agenda Item Number: 19 Agenda Item Number: 19
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people decided to use their new-found at-home time to launch renovation and rebuilding projects.

The result was a significant increase in the time it took to issue a permit. In response, Berry Dunn recommended 3 things:

1. Pay third party resources—i.e. commercial engineering firms with qualified and certificated plan reviewers on staff—to bring down the backlog.

2. Expand applicants’ access to (and awareness of) the availability of third party plan check resources in lieu of Permit Sonoma application review; and

3. Implement checklist-based initial review and resubmittal procedures to ensure that plan checks would be conducted consistently, regardless of which Permit Sonoma or third-party person did the review.

Permit Sonoma did fulfill both of the first two recommendations. It contracted with three private engineering firms and, by year-end 2024, had reduced the backlog to levels that Permit Sonoma management can handle using on-staff reviewers. It also published a list of nine third parties that applicants can pay to review plans on an expedited basis. The cost of third party review is incremental to (somewhat reduced) plan check fees charged by Permit Sonoma.

Item 3, however–a task that is reportedly “complete” on Permit Sonoma’s Board of Supervisors update–is still a work in progress. While almost all Permit Sonoma plan checkers have a checklist they use to conduct their reviews, they all use different checklists and none of those checklists are public–which reduces both the presumed benefit and cost savings that were the basis of the Berry Dunn recommendation.

3. BD Categorical Recommendations: Establish Explicit Performance Targets and Systems Improvements to Improve Throughput and Reduce Cost
This group of recommendations are the most essential changes proposed by the BD management review. Berry Dunn observed that while Permit Sonoma staff works hard, it could work smarter. To that end, BD recommended five changes that collectively could increase Permit Sonoma management and applicant visibility into plan check productivity.

The first task was for Permit Sonoma to clearly identify how long it should take to review permit applications. Conveniently, AB2234 established statutory requirements for turnaround time so that task was complete.

The four remaining tasks—still works in progress—were to modify the Accela workflow system to keep track of how much time is being spent on each individual permit review, and then use experiential data to establish plan review timetable expectations.

A rudimentary implementation of this time tracking capability was added to Accela, and some (but not all) plan checkers include their estimate of the ‘time on task’ in their Accela data. However, there is no systematic management review of the data, nor is there any systemic requirement that this data be recorded for every permit so the task (while “complete “in PS task tracking reports”) hasn’t actually been done.

Has PS made progress toward establishing explicit performance targets and implementing systems improvements?
Metrics, metrics, metrics: Management consultants implore organizations and their leaders to define clear goals and then measure performance toward them. Berry Dunn made a good effort to advance the appreciation of metrics by PS management, but it appears to have fallen on deaf ears.

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PS has very few Accela system-generated performance analysis reports and the principal reports telling senior management (and the public) how Permit Sonoma is performing are created by a single skillful but self-taught senior manager who creates data queries using Microsoft Access (an application that isn’t supported by Sonoma County Information Systems and is definitely not intended by Microsoft to be enterprise software). There are no other Access developers on the staff at Permit Sonoma. Accordingly, if and when that singular senior manager retires or chooses another path, the entire corpus of Permit Sonoma management metrics will need to be refactored.

What metrics are missing? The place to start is “time on task”, both individually and collectively. Permit Sonoma should know, specifically, how much time is being spent on primary tasks like plan review, site visits, staff education, and preparation and attendance at public meetings. Objective data would result in clear appreciation of both individual and collective performance. Less obviously, capturing time spent on secondary tasks, such as composing and responding to customer communication, interacting with applicants in an advisory context, or even addressing BoS constituent
inquiries, would help management decide where to invest in training, tools, and resource allocation.

The other major benefit of improved performance metrics:
quantifying the volume of work being done is essential to calculation of appropriate fees. Conversely, not knowing how much time it takes to do a type of work makes it impossible to know whether agency fees are charged correctly. Multiple staff members raised this concern, with consensus that both PS and its customers would benefit from understanding the true costs associated with permit application review and approval.

Government agency performance is mandated (and often limited) by a myriad of statutes, codes and ordinances; and budget constraints are a fact. But every enterprise, private or public, can benefit from setting clear performance goals and measuring progress towards them. Permit Sonoma has chosen not to prioritize the benefits that would result from rigorous metric assessment of its own performance and is unlikely to achieve optimal performance until it does.

Other Categorical Berry Dunn Report Recommendations
The Berry Dunn recommendations were grounded in the presumption that Permit Sonoma should want to deliver more, better, and faster customer response. While the foregoing topics were the principal mechanisms for achieving these goals, there were also 3 recommendations for expanding customer focus, improving customer interaction, and more and better communication.

The goal of Berry Dunn’s customer relationship management recommendations was to reflect a commitment to customer-centric behavior in PS workflows: some combination of more, better, faster, cheaper service for builders and their customers. Permit Sonoma’s SHOVEL initiative summarizes the message that Permit Sonoma has chosen to encapsulate its customer service program, and this graphic is pretty much the entire program:
"You can't manage what you don't
measure" Peter Drucker
"Measure what is measurable and
make measurable what is not so"
Galileo Galilei
“If you don’t know where you’re going,
you’ll end up someplace else” Yogi
Berra
“The thingsthat get measured are the
things that get done.” Tom Peters
"If you can't measure it, you can't
improve it" Peter Drucker
“Measure twice, cut once”
Mike Brady
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If Permit Sonoma succeeds at improving internal processes and making the workflow system better, then getting permits approved or rejected as quickly as possible will follow naturally.

Berry Dunn Report Review Conclusions
The authors of Permit Sonoma’s Berry Dunn management review presented a clear prescription for Permit Sonoma’s workflow systems issues, but PS still hasn’t been able to do what Berry Dunn said it should do. There is inconsistent systematic recognition of simple permits and expedited plan check, no systematized task checklists for intake or plan check, no integral recognition of due dates, time on task, or even which permits are overdue, and very limited ability to generate reliable management and performance metrics. Permit Sonoma has made an excellent beginning toward implementing all of the other recommendations included in the Berry Dunn report.

Other Observations about Permit Sonoma
Any report that purports to be comprehensive will have limits and exclusions, and sometimes the exclusions are more significant than the included material. This report is like that: the list of what wasn’t learned may be more important that what is covered.

What Questions About Permit Sonoma Weren’t Answered?
• How long does it actually take to do a plan check? Anecdotal statements in interviews and data recorded by some plan checkers suggests that a typical residential construction plan check takes 4-8 hours of staff time, but the Accela system doesn’t capture (or require staff to record) real processing times.

Why does this matter? According to both state law and Sonoma County ordinances, fees charged should only cover actual costs incurred and the cost of a plan check should clearly correlate with the amount of time it takes—but since PS doesn’t record how much time is spent on each plan review, plan check fees are averaged based on an opaque estimate of amalgamated staff and overhead expense that literally no one thinks is representative of the actual work being done. Bad actors who require multiple reviews or excessive amounts of plan rework (or submit design changes in the middle of the review) are often charged the same amount as applicants who submit a fully compliant, properly annotated set of plans that can be reviewed in a few hours.

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• This study did not review how Permit Sonoma conducts inspections or code enforcement. In hindsight, it was a significant omission. Inspections are a time-consuming and expensive element of construction permitting and Permit Sonoma’s inspections department is reported to do an excellent job of being both responsive and comprehensive. As self-certification programs evolve, the inspections department must lead the way towards determining the correct balance between improving operational efficiency and ensuring public safety. Similarly, the code enforcement process (which happens when builders and property owners fail to secure permits or build structures that don’t meet code, zoning and planning permit requirements) is an opaque intersection of authority meeting the reality of personal and public interest and safety.

It isn’t clear that Permit Sonoma code enforcement is worthy of the applause that most other PS divisions deserve.
• Why do permits cost as much as they do and how much should they cost? Permit Sonoma’s current fee schedules are based on a “fee study” published by a contracted consultant in 2021 using methods that meet state requirements for fee analyses. The consultant applied a legal, but not particularly thoughtful, formula which basically divided total department costs by total hours worked. The resultant fees aren’t based on actual time spent on permit processing.

Permit Sonoma, like many other County agencies, does a great deal of work on the public’s behalf that has little to do with the cost of processing permit applications. The fees collected from home builders and developers cover many costs that are loosely (or not at all) related to the direct cost of the services that PS provides to builders, and this fact was of concern to many of the Permit Sonoma staffers that were interviewed.
• How much, and why, is so much unpermitted work being done? We suspect that complex permit application processes and excessive permit fees are why there is so much unpermitted work.
• Why does it take as long as it does to process permit applications? If a permit plan check takes 4-8-12 hours, why does it take 4-8-12 weeks to work its way through the system? Could most permits be issued in days or weeks instead of months if PS were a bit more ambitious? The Future of Permit Sonoma
During the course of this investigation, the Civil Grand Jury inquired about the behavior of other Authorities Having Jurisdiction in California. One learning from this research is that permitting agencies play an important role in the state of housing development in California and the statewide housing shortage can’t be overcome without improvement in permitting agency performance.

It is highly likely that technology solutions are imminent and much of the work needed to review plans for code and ordinance conformity will be automated in the next 5 years. This should free the many knowledgeable and experienced people at Permit Sonoma to do work that can’t be automated:
coaching builders and their customers on construction best practices, compliance with legal mandates, fire-sensible construction alternatives, and alternate approaches to environmentally sensible construction. In other words, improving public safety in meaningful ways.

CONCLUSIONS
Permit Sonoma plays a significant role in Sonoma County public safety and, in answer to the two questions that the Civil Grand Jury set out to answer, Permit Sonoma is doing what it’s supposed to do: processing thousands of permit applications on a reasonably efficient basis and complying with state mandates for timely review. Although the Civil Grand Jury can’t be absolutely certain that Agenda Item Number: 19 Agenda Item Number: 19
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Permit Sonoma is meeting its legal obligation to process permits as quickly as AB2234 requires, our research suggests that PS is compliant. We wish we could prove it.

The fact that the case can’t be proven is a problem that must be corrected. PS’s workflow systems need work and don’t support PS management or (more importantly) permit applicants’ need for better and more automated access to individual and overall performance metrics.

This absence of meaningful plan check performance data precluded inclusion of permit cost analysis in this Civil Grand Jury study. Permit Sonoma doesn’t know whether the fees it charges fairly reflect the work it does because the workflow systems don’t capture time-on-task data in ways that are necessary to complete the analysis. Capturing this data programmatically would be more efficient, and fair, than repeatedly hiring fee study consultants who imagine creative legal methods to justify fee schedules.

PS has done a fine job of accepting and interpreting the Berry Dunn report recommendations and made an excellent plan to achieve these recommendations. Victory was declared prematurely, however: there is still meaningful work to be done and it would be a shame to stop short of full implementation. Permit Sonoma has completed the initial phase of its management review. Now, staff must focus on continued process improvement with particular emphasis on improving customer service and empowering additional express permitting teamwork. Factors such as lower permit volumes and smarter fulfillment of regulations will require Permit Sonoma to operate with greater efficiency and embrace new technology to do better work, faster, at lower cost in the future.

Permit Sonoma management’s report to the Board of Supervisors, while generally accurate, glosses over work that still needs to be done and funded.

The Civil Grand Jury concludes that PS is doing a good job of accepting and reviewing permit applications on a timely basis and has both opportunity and organizational capability to be more ambitious. A moderate additional investment in the workflow platform – and staff with the skills to improve it as needed – will produce significant gains in Permit Sonoma efficiency and an excellent return on investment for Sonoma County builders and taxpayers.

FINDINGS
The Sonoma County Civil Grand Jury determined that:

F1. Permit Sonoma meets California Assembly Bill 2234 (2022) requirements for initial acceptance of permit applications on a timely basis.

F2. Permit Sonoma generally meets AB2234 (2022) requirements regarding review of permit applications within 30 business days.

F3. The Civil Grand Jury was unable to conclusively verify AB2234 (2022) compliance because Permit Sonoma workflow systems do not reliably and consistently capture elapsed time for permit reviews.

F4. Permit Sonoma is not able to factually report permit review and approval throughput because its workflow tracking systems are not capturing data on a consistent and reportable basis.

F5. Permit Sonoma has made excellent plans to implement all of the Berry Dunn management review recommendations, but its reports overstate the actual progress observed by the Civil Grand Jury.

F6. Full implementation of Berry Dunn management review recommendations will take additional application development resources that are not currently in place within Permit Sonoma.

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F7. Other than compliance with California Assembly Bill 2234 (2022), Permit Sonoma senior management has not established objective expectations for staff performance regarding plan review or timely permit issuance.

F8. Permit Sonoma does not provide information to the public about over the counter and express permit review requirements and opportunities in a manner that is easily accessible and comprehensive.

F9. Permit Sonoma permit intake and plan check staff need additional workflow systems training to ensure accurate data entry and consistent use of status reporting conventions.

RECOMMENDATIONS
The Sonoma County Civil Grand Jury recommends that:

R1. By October 17, 2025, Permit Sonoma shall require that all employees record, within the workflow systems, time spent on task for permit intake and plan check, site visitation, field inspection and code enforcement review.

R2. By December 19, 2025, Permit Sonoma shall develop a plan to implement all workflow system changes required to capture and report, in a reliable and sustainable manner, individual employee and collective permit throughput; and agency compliance with California Assembly Bill 2234 (2022) timely performance requirements.

R3. By December 19, 2025, Permit Sonoma will establish and publish objective performance and throughput goals regarding permit review and approval.

R4. By December 19, 2025, Permit Sonoma shall review and make available on its website and other publicly accessible documents all over the counter permit processes and requirements.

R5. By December 19, 2025, Permit Sonoma shall review and publish its requirements and expectations for express permit review and approval, third party plan check, permit and inspection self-certification, and use of program management techniques to fulfill all Berry Dunn Report recommendations.

R6. By December 19, 2025, Permit Sonoma shall review and publish an accurate update to its January 2025 Board of Supervisors report on progress toward fulfillment of the Berry Dunn report recommendations.

R7. By March 27, 2026, Permit Sonoma shall determine whether additional resources are required to fully implement the workflow system upgrades needed to fulfill all Berry Dunn Report recommendations and communicate such incremental budget requirements to the County Executive Officer and the Board of Supervisors.

R8. By March 27, 2026, Permit Sonoma will review, publish (and require consistent staff usage of) requirements checklists for issuance of all permit types.

R9. By March 27, 2026, Permit Sonoma shall review and update its workflow system training materials and protocols for all Permit Intake, Plan Check, and Planning personnel.

R10. By March 27, 2026, Permit Sonoma shall establish and publish, in a consistent format, standard operating procedures for all Planning, Building, Engineering, Well & Septic, and Code Enforcement permit issuance/compliance review processes.

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R11. By May 1st, 2026, the County Executive shall review Permit Sonoma’s resource requirement noted in Recommendation 7 for inclusion in the Board of Supervisors’ 2026-27 budget review.

R12. By July 10, 2026, and annually thereafter, Permit Sonoma shall publicly post an accurate annual report of each department’s permit processing performance and compliance with timeliness requirements of 2022 California Assembly Bill 2234.

R13. By July 13, 2026, or as soon thereafter as allowed by budget authority, Permit Sonoma shall implement workflow system upgrades sufficient to ensure that individual and collective throughput performance is captured and reported in a reliable and consistent manner.

RESPONSES REQUIRED
Findings F1-F9: Permit Sonoma
Recommendations R1-R10, R12-13: Permit Sonoma
Recommendation R11: County Executive and Board of Supervisors Reports issued by the Civil Grand Jury do not identify individuals interviewed. Penal Code Section 929 requires that reports of the Civil Grand Jury not contain the name of any person or facts leading to the identity of any person who provides information to the Civil Grand Jury.

APPENDIX 1. SUMMARY OF CALIFORNIA ASSEMBLY BILL AB 2234 (2022) Title: AB 2234 – Post entitlement Phase Permits
Authors: Assemblymembers Robert Rivas and Tim Grayson
Signed Into Law: September 28, 2022
Effective Date: January 1, 2023
AB2234 includes provisions that address what happens if local jurisdictions fail to meet the specified deadlines for processing housing permit applications. If a local agency does not adhere to the 30- or 60- business day limit for reviewing applications, the application is deemed approved under certain conditions.

This serves as a form of penalty by automatically moving the project forward if the local agency does not act in time.

The focus is on ensuring that housing projects are not unduly delayed by bureaucratic processes. This system of deemed approval encourages local governments to prioritize and expedite their review processes, indirectly penalizing them by removing their ability to deny or request further changes to applications that they do not review within the mandated time frames.

Purpose and Background
AB 2234 was introduced to streamline and bring greater transparency and efficiency to the post entitlement permit approval process for housing developments in California. The bill is a response to significant delays and inconsistencies in the approval of post entitlement phase permits (such as grading, demolition, and building permits) at the local level, which have historically hindered housing production.

This legislation builds upon previous housing reform efforts, including SB 330 (2019), which aimed to expedite the housing approval process by limiting local governments' ability to delay projects.

Key Provisions of AB 2234

1. Standardized Timelines for Permit Approvals
• Local agencies must review and decide on post entitlement housing permits within specific timeframes:

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o 30 days for projects with ≤ 25 housing units
o 60 days for projects with > 25 housing units
• If the local agency finds that an application is incomplete, they must notify the applicant within 15 business days with a detailed list of missing information.

2. Online Permit Tracking and Transparency
• Local governments are required to maintain an online system where applicants can:
o Submit applications electronically
o Track the status of their permits in real-time
o Receive notifications of any required modifications
• This provision is aimed at improving government accountability and reducing bureaucratic inefficiencies.

3. Restrictions on Permit Denials
• Agencies cannot reject a post entitlement phase permit unless they provide:
o A written explanation detailing the reasons for denial o References to specific laws, ordinances, or codes that justify the rejection • If a permit is denied, the applicant has the right to appeal, ensuring due process.

3. Standardized Checklists:
• Cities must develop and publish objective checklists detailing permit application requirements, ensuring clarity for developers.

4. Scope and Applicability
• Applies to all local jurisdictions in California.
• Covers post entitlement permits for residential developments that have already been approved through zoning and land-use approvals.
• Does not override the California Environmental Quality Act (CEQA) or other state/local regulatory requirements but ensures that the final approval process is not unnecessarily prolonged.

Expected Impact
• Accelerates housing production by preventing unnecessary delays. • Enhances transparency in the local permitting process. • Supports affordable housing initiatives by reducing regulatory barriers. • Reduces construction costs by providing a more predictable and efficient permitting process.

Conclusion
AB 2234 is part of California’s broader housing reform efforts aimed at addressing the state’s severe housing crisis. By ensuring that post entitlement permits are processed within reasonable timeframes, the bill helps remove bureaucratic roadblocks that often delay much-needed housing developments. It represents a significant step toward streamlining housing construction, making the process more efficient, transparent, and predictable for developers and home
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APPENDIX 2. COUNTY MUNICIPAL CODE
Ordaining Permit Sonoma (formerly Permit & Resource Management Division) as the Authority Having Jurisdiction in unincorporated Sonoma County.

See Municipal Code, Section 7 for a more comprehensive list of Permit Sonoma authorities.

Sec. 7-5. - Building permit required.
a) No person, firm or corporation shall erect, construct, enlarge, alter, repair, move, improve, convert or demolish any building or structure in the unincorporated area of this county, or cause the same to be done, without first obtaining a separate building permit for each such building or structure as required by this chapter. Permits shall be issued and fees shall be collected by the permit and resource management department. The building standards for the work authorized by the new permit shall be governed by the codes in force at the time of the new permit application as described in Chapter 1, Division I, of the California Building Code as to the erection and construction of dwellings and appurtenant structures for which construction was lawfully commenced, commenced to legalize a violation, or approved prior to the effective date of this ordinance. b) Permits shall not be issued by the permit and resource management department for work which includes any of the following, unless and until written approval has been received:

1. The construction, alteration or modification of: (i) Any on-site disposal system (approval required from the well and septic section of permit and resource management department), (ii) Any water supply system which under state law or county ordinance is required to have a permit to operate (approval required from the health officer or the state health services department), (iii) Any establishment selling or preparing food or food products, any public or semi-public swimming pool as defined in the 2013 California Administrative Code (approval required from the health officer);

2. The construction, alteration or modification of any structure which will result in the structure being connected to an on-site wastewater disposal system or water system; (approval required from the well and septic section of permit and resource management department),

3. The alteration or modification of any existing structure which is connected to an on-site wastewater disposal system or water system requiring a permit, where the alteration or modification may impose additional burdens upon the existing system, such as, but not limited to, the addition of rooms or the modification of floor plans for potential additional occupancy. This section shall not apply to repairs, such as replacement of roofing or siding. Where the permit is for modification or alteration of an existing structure, no permit will be issued where, in the determination of the chief building official, such modification is likely to result in exceeding the capacity of the system;

4. The construction, alteration or modification of any structure which may result in the property being improved in excess of its capacity to absorb sewage effluent. This section is intended to cover any change in the property which might adversely affect sewage disposal such as, but not limited to, grading or the construction of a barn or swimming pool which might infringe on the leach field (approval required from the well and septic section of permit and resource management department);
c) For the purposes of this section, approval by the well and septic section of permit and resource management department shall mean either an office clearance, field clearance, or issued well and septic permit for on-site wastewater disposal system.
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applicable, including basin plans and other standards promulgated by the North Coast Water Quality Control Board and the San Francisco Bay Regional Water Quality Control Board. e) Building permits must be cleared as to zoning considerations in Chapters 26 or 26C, grading and drainage requirements in Chapter 11, and stormwater requirements in Chapter 11A of this Code.

Building permits for projects regulated by the California Fire Code and Sonoma County fire safe standards may be subject to review and approval by appropriate fire service agencies. Where county road encroachment is necessary, a permit for same shall be first secured. A water and/or sewer clearance is first required in areas serviced by special districts and cities before building permits can be issued.
f) Notwithstanding any other provision of this chapter or the codes adopted hereby, emergency maintenance work or repair of buildings and structures requiring a permit hereunder may be commenced before obtaining a permit without violating this chapter provided the permit and resource management department or the public health officer, in the appropriate case, is notified prior to noon of the next following business day and the permit required is obtained within twenty-four (24) hours thereafter, and provided further that no work shall be covered before it has been duly inspected and approved. Compliance with the State Subdivision Map Act, the Sonoma County subdivision regulations, and the Sonoma County zoning regulations, including compliance with conditional permits issued thereunder, and compliance with all laws, is a condition precedent to the issuance of any permit required by this chapter for work to be done on any particular parcel of real property in the unincorporated area of this county.
g) As a condition precedent to the issuance of a building permit required by this section for which an application was made on or after November, 1989, the applicant shall pay to the county development fee as specified in Section 26-98-660 of this Code. The permit required for Section 105 of Appendix 1 of the California Building Code for structures subject to the requirements of this subsection shall not be issued unless and until the development fee has been paid. h) Within flood-prone urban areas as defined in Section 7-13(a)(10), a building permit authorizing excavation for foundations shall not be issued until a disposal location for excavated material has been designated. Acquisition of a building permit does not relieve the permittee of the responsibility for acquiring any other state and local permits required for the activity. i) In any unincorporated portion of Sonoma County where stormwater discharges are subject to the requirements of one or more NPDES permits, as referenced in Chapter 11, any construction site for which building permits are approved pursuant to Chapter 7 must be developed and used pursuant to any applicable requirements of said NPDES permit(s). Failure to adhere to applicable NPDES permit requirements at any time will be deemed to be a violation of this section and may subject the permittee to the penalties established by this chapter. Permittees may meet this requirement by filing with the Regional Water Quality Control Board the appropriate notice of intent to comply with the state general construction activity stormwater permit or by obtaining approval of an individual NPDES permit from the Regional Water Quality Control Board.

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SUMMARY
Local Fees, Local Subsidies
Fees and subsidies cause local pain
Nobody likes paying government fees, especially regulatory ones like permits for home renovations.

But frustration can turn to anger when these fees suddenly increase dramatically without warning or alternatives.

That’s exactly what happened in the summer of 2024 when a fee for reviewing home modifications in Santa Rosa’s historic districts jumped from $1,700 to $17,000. The fee was meant to cover the cost of reviewing major renovation projects in historic areas. Although the City of Santa Rosa followed the legal process for increasing fees, the Cultural Heritage Board (CHB) which had been responsible for reviewing projects wasn’t informed of the public hearings until after the fees had already been approved. While such notification was not required by law, CHB members considered the increase excessive and likely to discourage major renovations in historic districts. Several resigned in protest.

To its credit, the Santa Rosa City Council acknowledged that the historic district fee increase was not what it intended. The increase was buried in a broader fee study undertaken to adjust hundreds of fees that hadn’t changed since 2014. There was nothing to signal the unusual size of the increase or the fact that the fee had been subsidized in the past. The resulting uproar led to an eight-month review process that streamlined service delivery and simplified regulations. Despite these improvements, it left many Santa Rosa residents angry and wondering how such an outrageous increase was ever proposed.

This incident prompted the Grand Jury to investigate how fees are set and controlled in Santa Rosa and other cities. By state law, a fee is a charge for a service or product provided directly to those who pay it. Unlike a tax, a fee may not exceed the actual cost of providing a specific service. The Grand Jury examined fee-setting practices in Santa Rosa, Rohnert Park, and Petaluma—the three largest cities in Sonoma County. The study reviewed the legal requirements for raising fees and explored ways local governments could prevent excessive increases from being approved without proper consideration and oversight.

BACKGROUND
Over the past 50 years, California voters dramatically changed how local governments are funded. A brief recap of these changes may be instructive to understanding local government finance. • Proposition 13 (1978). This state-wide proposition limited property taxes to 1% of the assessed value of real property set at the last sale price. It allowed property assessment values to increase no more than 2% per year until a property was sold again. At sale, the property’s assessed value would be changed to the sale price or market value. The law further required that any property tax increase would need to be approved by a 2/3 vote of the electorate. • Proposition 218 (1996). This proposition was called the Right to Vote on Taxes Act. In the uncodified Section 2 it stated:

Findings and Declarations. The people of the State of California hereby find and declare that Proposition 13 was intended to provide effective tax relief and to require voter approval of tax increases. However, local governments have subjected taxpayers to excessive tax, assessment, Agenda Item Number: 19 Agenda Item Number: 19
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fee and charge increases that not only frustrate the purposes of voter approval of tax increases, but also threaten the economic security of all Californians and the California economy itself.

This measure protects taxpayers by limiting the methods by which local governments exact revenue from taxpayers without their consent.
• Proposition 26 (2010). Proposition 26 amended State Constitution Article XIII to add new definitions of state and local “taxes,” defining all revenue measures imposed by the government as “taxes” unless within one of seven express exemptions for local government or five express exemptions for state government.

The takeaway from all these actions is that local governments are under strict mandates to ensure that their revenue raising activities follow requirements imposed by the voters of California. To not be a tax, fees must comply with an exemption process. Specifically, Proposition 26 stated:
e. As used in this Article "tax” means any levy, charge, or exaction of any kind imposed by a local government, except the following:

2. A charge imposed for a specific government service or product provided directly to the payor that is not provided to those not charged, and which does not exceed the reasonable costs to the local government of providing the service or product.

Another six exemptions are discussed in Proposition 26 but are not relevant to this investigation. The main point of Proposition 26 is that fees may not exceed the cost of providing the service or product.

Cities often outsource cost-of-service fee studies and rely on these assessments to set fees that cover, but don’t exceed, the actual cost of providing each service.

Sometimes, governing bodies decide it’s in the public interest to charge less than the full cost for certain services. For example, local governments often use General Fund subsidies to reduce fees for youth recreational programs to encourage more participation. In contrast, adult recreational programs are usually expected to cover their full costs. Similarly, building permit fees may be reduced for projects that benefit the public, such as daycare centers. These policy decisions are up to the governing body.

A challenge with fee subsidies is that if the governing body or staff doesn’t closely monitor changes, a previously subsidized fee can shift to a full-cost fee, causing steep increases. In the Santa Rosa example, a fee increased tenfold without being flagged when presented to the governing body. The increase was approved without council members recognizing the magnitude of the increase. This led to public outrage. While the increase was legal, it caused significant disruption and led to heartfelt apologies by City Council Members.

METHODOLOGY
The Grand Jury performed Internet searches of public information, reviewed documents posted by the cities under investigation, reviewed video recordings of public meetings and interviewed personnel familiar with the fee setting and approval process.

Agenda Item Number: 19 Agenda Item Number: 19
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DISCUSSION
The Grand Jury limited its investigation to the three largest cities in Sonoma County: Santa Rosa, Petaluma, and Rohnert Park. The Grand Jury expected to find the following in each city’s fee-setting process:

1. A study justifying the fees.

2. A staff report discussing the fees.

3. When appropriate, a discussion of which fees would be subsidized or no longer subsidized.

4. A discussion about how much the proposed fees would change from current fees.

5. A public hearing when adopting the fees.

Santa Rosa
The City of Santa Rosa presented proposed Planning and Building Department fees at a study session on January 30, 2024. The fees had not been updated since 2014. The fee study was conducted by MNG Consultants. In March 2024, the Council approved the new fee structure, which took effect on July 1, 2024.

While the Council discussed subsidizing certain fees, it did not review which fees were losing previously approved subsidies. Ultimately, the Council approved the staff’s recommendations, including one fee increase of more than $15,000.

After the new fees were approved, a member of the Cultural Heritage Board (CHB) discovered that certain fees affecting historic districts had jumped from $1,700 to $17,000. Outraged by the drastic increase, CHB members resigned in protest.

Following the resignations, the City of Santa Rosa re-evaluated its permit requirements and determined that many projects subject to the increased fees did not require full CHB review. Instead, they could be handled through a director-level review, eliminating the need for costly permit fees.

Santa Rosa also simplified its design review process by merging the CHB with the existing Design Review Board, creating a single Design Review and Preservation Board. However, the city did not adjust the new fees to reflect the streamlined process. Instead, it approved a 92% subsidy that substantially reduced permit costs for homeowners. Commercial and non-profit property owners in historic districts will not receive the subsidy but will benefit from the streamlined process and reduced review requirements.

At the adoption meeting for the revised process on February 4, 2025, several homeowners testified that the fee hikes had been excessive. Many were frustrated that it had taken eight months to address the issue. Ten individuals spoke about the historic district fees during a 25-minute public comment period. Some of the comments included:
• "I’ve always had a problem paying these crazy permit fees. I didn’t know what the fees were before, but to remodel my backyard, the fee went from $409 to $8,300 — and you voted for it." • "I’m thrilled that the city is dropping fees by 92%." • "It was insane to discover fees increasing by over $1,000. Tonight, we’re undoing what was done — it feels like smoke and mirrors."
• "We weren’t told about the permit fee increases — it’s ridiculous." Agenda Item Number: 19 Agenda Item Number: 19
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Smaller Fee Increases More Frequently vs Large Fee Increases Infrequently In our review, Petaluma decided to revise fees annually by the Consumer Price Index (CPI). Such a practice allows for smaller fee increases instead of larger fee increases when a fee study is conducted after multiple years. It also increases revenue as costs increase, resulting in higher net revenue. Consider the example below in which City A has a CPI increase each year and City B only increased fees after 7 years. Table I, Hypothetical City Fees, shows the annual change in the fee and revenue generated per fee paid.

Table I
Hypothetical City Fees
• “I am glad Santa Rosa is streamlining its approval process.” • "I did $60,000 of work on my home. If I’d had to pay another $10,000 in permit fees, I couldn’t have afforded it."
• "The fees would have been comical if they hadn’t had real impacts on people. They only look reasonable compared to the enacted fees. If fees must exist, they should be as low as possible." Council members acknowledged their responsibility to approve reasonable fees and expressed regret for allowing the previous increases. The Grand Jury noted that if Santa Rosa’s process had clearly flagged the substantial fee increases nearly a year earlier, the public outcry and subsequent Council remorse might have been avoided.

Petaluma
The City of Petaluma hired the Willdan consulting firm to prepare a cost-of-service fee study. The report on city fees was presented to the City Council on April 8, 2024, and adopted on May 6, 2024.

It justified the full cost of fees and outlined the changes from current fees. However, this information was among numerous line items in a lengthy report printed in small type.

The last comprehensive fee review took place in the 2015–2016 fiscal year, eight years earlier. Since then, the city had adjusted fees annually based on the Consumer Price Index (CPI).

Although not legally required, the report did not identify which previously subsidized fees were no longer recommended for subsidy. The Council approved the staff recommendations. The largest increase for existing fees was under $1,000.

One reason Petaluma’s fee increases were smaller than those in other cities may be its practice of adjusting designated fees annually based on the San Francisco-Oakland-San Jose CPI. While not perfect, this method tends to prevent large, sudden fee hikes. It also provides increased revenue as costs increase with inflation.

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Fee Comparisons to other Local Governments
Rohnert Park’s fee comparison to other local governments has the benefit helping a local governing body avoid approving a fee at great odds to what is being done in the local area. Its main defect may be that the fee is not supported by some methodology showing that the fee is not more than the cost to produce the service or product, as required by State Law.

Here is an example of a fee comparison from Rohnert Park.

Rohnert Park
As part of its municipal code, Rohnert Park has certain requirements that go beyond California State Law. One municipal requirement found in Chapter 3.32 asks for an annual report which shows:

1. The services for which cost recovery fees are charged;

2. The amount of the cost recovery fee charged for each service;

3. The percentage of actual costs recovered by each cost recovery fee;

4. Whether or not the fee includes an annual escalator;

5. The year in which the fee was last comprehensively reviewed; and

6. Recommendations for modifications to the services for which cost recovery fees are charged, the amounts of cost recovery fees or the percentage of costs recovered in order to assure that the cost recovery fees continue to recover the reasonable and proportional share of costs from applicants requesting services.

Upon review of Rohnert Park Council actions, the Grand Jury found no record of the required report.

When asked about compliance with the municipal code, the city admitted it was not currently compliant.

The Grand Jury did find that some departments, such as the Police and Parks & Recreation Departments, had presented fee resolutions to the City Council and held public hearings. However, these reports lacked the detail required by the municipal code. Additionally, Police Department fees had not been adjusted since 2004. Instead, the department compared its fees to those of other agencies to determine appropriate rates. This comparison of fees among local governments tends to keep fees from increasing dramatically but may not meet the legal requirement of showing how a local governments fees are not greater than the cost to provide the service or product.

Even if the city had followed its municipal code, the Grand Jury would still have concerns about the lack of clarity regarding previously subsidized fees. Without this information, it is difficult to assess changes in subsidies and their impact on residents.

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CONCLUSION
California state law requires certain procedures to ensure that fees do not exceed the cost of providing a service. However, the law does not specify how often a fee study must be conducted or require escalation clauses for gradual increases. The two cities that conducted studies had last done so 8 and 10 years earlier.

The law also does not require local governments to clearly state previous fees when proposing new ones. When fee increases are large and abrupt — such as when a previously subsidized fee is no longer subsidized, as happened in Santa Rosa — residents may see the new fees as excessive and punitive.

By reviewing all fees with significant increases, governing bodies can better assess what level of fee increases are justified.

FINDINGS
The Sonoma County Civil Grand Jury determined that:

F1. Long intervals between fee studies can result in large fee increases that are unacceptable to the public.

F2. Without some mechanism for fee increases to keep pace with inflation, governments are unable to recover increased costs and the public is confronted, periodically, with large increases.

F3. Because the fee studies examined did not routinely discuss prior subsidies, Santa Rosa City Council Members were disadvantaged in recognizing excessively large changes.

F4. Staff’s failure to complete an annual fee report was noncompliant with the requirements of the Rohnert Park Municipal Code and resulted in Council Members lacking information needed to evaluate and adjust the fee schedule to cover, without exceeding, actual costs.

RECOMMENDATIONS
The Sonoma County Civil Grand Jury recommends that:

R1.By December 31, 2025, the City Councils of Petaluma, Rohnert Park, and Santa Rosa direct staff to include a section in all future fee proposals that identifies any fee changes that will exceed a council-specified threshold and any fees with past or proposed subsidies.

R2.By December 31, 2025, the City Councils of Rohnert Park and Santa Rosa will adopt a policy to avoid abrupt fee increases.

R3.By December 31, 2025, the City of Rohnert Park will either direct staff to submit a fee report in the 2025–2026 fiscal year that complies with Rohnert Park Municipal Code Chapter 3.32 or revise that code section to align with state law.

REQUIRED RESPONSES
Pursuant to Penal Code §§ 933 and 933.05, the Grand Jury requires responses as follows:
• The City Council of Petaluma to respond to R1 and F1 by September 30, 2025. • The City Council of Santa Rosa to respond to R1, R2 and F1-F3 by September 30, 2025. • The City Council of Rohnert Park to respond to R1- R3 and F1-F4 by September 30, 2025.

Agenda Item Number: 19 Agenda Item Number: 19
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BIBLIOGRAPHY
• League of California Cities, “Proposition 26 and 218, An Implementation Guide”, May 2017. • Press Democrat, “Santa Rosa board quits over hiked development fees for historic properties.” August 28, 2024.
• February 4, 2025, Santa Rosa City Council Minutes; also, YouTube Video, “City of Santa Rosa Meeting February 4, 2025”, Time: 04:55:00.
• Press Democrat, “Santa Rosa Overhauls Permits, Fees.” February 7, 2025. • City Council Meeting of Santa Rosa, March 13, 2024, Item 16.1, Exhibit A, Santa Rosa Fee Study.
• City Council Meeting of Petaluma, May 6, 2024, Item 11, Exhibit B- Comprehensive User Fee Study Report.
• Rohnert Park Municipal, Chapter 3.32.
• City Council Meeting of Rohnert Park, April 23, 2024, Item 9D, Public Safety Fee Increase Proposal.

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Animal Servicesin Sonoma County
Separate and Not Equal
The Costs and Consequences of Decentralization

SUMMARY
In addition to approximately 480,000 residents, Sonoma County households include an estimated 113,000 dogs and 100,000 cats. Feral cats and other domestic and wild species add to the animal population. State law mandates that county and city governments provide humane care for animals and operate animal control programs to protect public health and safety. Because the entire state of California is a declared Rabies Area, every dog owner is required to maintain current rabies vaccination and licensing of their pet. Every county and city government must implement a Rabies Control Plan that includes ensuring availability of low-cost rabies vaccination, quarantine of dangerous animals, enforcement of licensing, and submission of dog licensing data to the state.

Spay/neuter programs for population control are strongly recommended.

A citizen complaint prompted the 2024-2025 Civil Grand Jury (Grand Jury) to investigate the Petaluma-based North Bay Animal Services (NBAS). This led to a broader study of county-wide animal services. The work was guided, in part, by a 2012 study of animal services and subsequent updates undertaken for the Board of Supervisors by the Department of Health Services (DHS). The initial report mapped existing services, identified best practices, and explored alternative governance models to provide consistent, cost-effective animal services. It called for a task force to establish shared standards and resources and explore alternative governance models to provide consistent, cost-effective animal services. The task force members failed to agree on recommendations for a governance model, oversight, shared resources, or standards. One respondent told the Jurors that after two years of sporadic work, the only agreement was on a logo. While the task force was ultimately disbanded, the Grand Jury found a high level of voluntary compliance with industry standards during visits to the Humane Society of Sonoma County (HSSC) and the Rohnert Park Animal Shelter (RPAS). Report updates have documented the continuous improvement of Sonoma County Animal Services (SCAS). This public agency serves the 66% of county residents who reside in the unincorporated areas, the City of Healdsburg, and the City of Santa Rosa.

A discussion of animal services in the remaining third of the county is largely absent from recent county DHS reports. Mapping and evaluating agencies serving this area became a focus of the Grand Jury investigation. Jurors learned that Rohnert Park’s municipal shelter also serves Cotati in cooperation with the cities’ police departments. The City of Sonoma Police Department manages that city’s dog licensing and sends animals to SCAS or Pets Lifeline when needed. NBAS is responsible for providing animal services to more than 20% of the county through contracts with the Cities of Cloverdale, Windsor, Sebastopol, and Petaluma.

Evidence collected by the Jurors confirmed the complainant’s allegation that a lack of city oversight is allowing NBAS to operate in violation of applicable laws and other terms of its contracts. The Grand Jury also confirmed the absence of oversight by the organization’s board of directors. Its dog licensing rates are approximately half of the national average of 23% and are far below those reported by SCAS. It is placing animals in foster-to-adopt homes without prior, or timely scheduling of sterilization. It fails consistently to report dog bites to the county health officer. It lacks an established role in the county’s Animals in Disaster Response Plan. Shelter maintenance and operation fall short of industry standards specified in its contracts. Staff are over-burdened and Agenda Item Number: 19 Agenda Item Number: 19
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under-qualified. Given the extensive reach of NBAS, these shortcomings are a matter of concern for public health and safety and are a source of potential liability for the cities it serves. The governments contracting with NBAS have failed to exercise their right and responsibility to ensure that NBAS is providing the services it has contracted to perform and that animals are getting services that are legally required.

More than a decade has passed since Sonoma County convened public and private partners in an animal services task force to identify a governance model conducive to uniform and cost-efficient provision of animal control and shelter. Shortcomings and inefficiencies in the current system include the inability to ensure county-wide compliance with state laws or to mount a fully coordinated emergency animal evacuation. Uneven license rates undermine rabies control and fail to secure funds needed for animal services.

Based on these findings, the Grand Jury strongly recommends that county and city governments and their non-governmental partners renew efforts to coordinate and standardize animal services throughout Sonoma County and adopt an effective system of oversight.

GLOSSARY
• Animal Control includes field calls by certified Animal Control Officers (ACO) and implementation of programs to comply with state law and local ordinances that require rabies vaccination, licensing of dogs, and provision of spay/neuter programs. • Animal Control Officer/Animal Regulation Officer (ACO) certification requires completion of the 40-hour PC 832 Arrest and Firearms Course and three months of field training. • Shelter Care includes the housing, feeding, tracking and care of animals, provision of veterinary care, and management of adoption programs.
• Foster-to-Adopt Programs enlist volunteers to care for and socialize animals to prepare them for adoption.
• Fear Free Shelter Certification is a program designed to minimize stress and optimize the safe handling of shelter animals. https://fearfreepets.com/fear-free-certification-overview/ • Community/feral cats are cats with no acknowledged owner. Government agencies are responsible for managing the cat population through accessible, free spay/neuter programs. • TNR is the acronym for Trap/Neuter/Return, a program in which cats in feral cat communities are trapped, sterilized and vaccinated, and then returned to the community. • Rabies Area means any area determined by the California Public Health and Safety Director where the existence of rabies constitutes a public health hazard. As a rabies area, Sonoma County and its city governments must comply with California’s Health and Safety Code. • NGO is the acronym for a non-government organization. • Memorandum of Understanding (MOU) is a legal agreement that specifies responsibilities, obligations, and privileges between entities.
• A Joint Powers Agreement (JPA) is a legal contract between two or more public agencies, like cities or counties, that allows them to cooperate on shared services or powers. These agreements enable agencies to combine resources and expertise to achieve goals that might be difficult or impossible for a single agency to accomplish alone.

Agenda Item Number: 19 Agenda Item Number: 19
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METHODOLOGY
The Grand Jury visited the shelters, reviewed animal data, budgets, websites, service contracts, city council minutes and memoranda and coverage provided by print and social media. The Grand Jury researched industry standards for animal care and shelter design and interviewed the complainant, other NBAS clients, and representatives from the following organizations:
• Sonoma County Animal Services (SCAS)
• Humane Society of Sonoma County (HSSC)
• North Bay Animal Services (NBAS)
• Rohnert Park Animal Shelter (RPAS)
• The Cities of Cloverdale, Windsor, Healdsburg, Rohnert Park, Sonoma, Sebastopol, Petaluma, and Santa Rosa
• The Sonoma County Board of Supervisors

BACKGROUND
A citizen complaint regarding North Bay Animal Shelter (NBAS) prompted this investigation by the 2024-2025 Civil Grand Jury. Among the alleged shortcomings were unacceptable shelter conditions and failure to comply with state laws that mandate humane care, vaccination and licensing of dogs, quarantine and tracking of dangerous animals, and spay/neuter surgery of animals prior to placement in foster or adoptive homes. NBAS provides animal control and shelter services to four of Sonoma County’s nine cities comprising more than 20% of its residents. Its contracts with three cities require that it comply with all relevant laws and that the Petaluma shelter shall be maintained in compliance with U.C. Davis Standards of Care for Shelter Animals. The current industry guidelines for standards of care (now used by U.C. Davis) are published by the Association of Shelter Veterinarians.
1 The fourth city requires that it perform at the highest industry standards. The complaint alleged multiple violations of these terms and an absence of city oversight to ensure compliance.

The Grand Jury broadened its focus to explore how Sonoma County and its nine city governments provide legally mandated animal control and care. Its approach was guided, in part, by a 2012 study of animal services and subsequent updates undertaken for the Board of Supervisors by the Department of Health Services (DHS).2 These studies map existing services, identify best practices, and explore alternative governance models to provide consistent, cost-effective animal services. In exploring alternative forms of governance, the 2012 study suggested either a joint powers agreement (JPA) or a county-wide public/private partnership. It noted that without a mechanism for oversight, there would be risks of inconsistent service. The current situation with NBAS is evidence that this was a valid concern.

Subsequent reports have documented the continuous improvement of SCAS, the public agency that serves the 66% of county residents who reside in the unincorporated areas, the City of Healdsburg, and the City of Santa Rosa.3 Conspicuously absent from these reports was a discussion of what happens in the remaining third of the county. This omission became the focus of extensive research by the Grand Jury.
1 https://jsmcah.org/index.php/jasv/issue/view/2
2 https://sonoma-county.legistar.com/LegislationDetail.aspx?ID=5646253&GUID=DF621026-2216-4648-87CE0C61C0A20014&Options=&Search= 3 https://sonoma-county.legistar.com/LegislationDetail.aspx?ID=5646253&GUID=DF621026-2216-4648-87CE0C61C0A20014&Options=&Search= Agenda Item Number: 19 Agenda Item Number: 19
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The Grand Jury also revisited recommendations that were made by the 2017-2018 Sonoma County Civil Grand Jury in its report titled: The Evacuation and Sheltering of Animals During the Firestorm of October 2017.
4 Through interviews and public documents, the Grand Jury determined that the recommended actions have been largely accomplished. The Director of Animal Services now serves as the animal liaison for emergency operations planning. An Animals in Disaster Response Plan has been annexed to the Sonoma County Emergency Operations Plan. 5 Several MOUs have been
adopted, and others are pending with NGOs to specify their roles as emergency responders. Work is underway to establish a regional partnership encompassing Sonoma, Marin, Napa, Lake, and Mendocino Counties. Agreements are in place with Code 3 Associates6 and the American Association of Prevention of Cruelty to Animals. Regrettably, not all cities have developed municipal emergency response plans and NBAS has no defined role as the agency responsible for animal control for four of the County’s nine cities.

Provision of animal care and compliance with state and local animal regulations is a large and growing challenge for city and county governments. A Forbes report of pet ownership found that some 66% of U.S. households now include a pet. About a third of U.S. households have more than one pet.7
Based on the Pet Ownership Calculator provided by the California Department of Food and Agriculture, Sonoma County is home to approximately 113,000 dogs and 100,000 pet cats.8 Feral cats and other domestic and wild animals add to this population.

A study by Pew Research found that 51% of respondents consider their companion animals to be members of the family, but along with the benefits of companionship and comfort come responsibilities both for owners and for county and city governments. These responsibilities are codified in state, county, and municipal codes that require humane treatment of animals and address risks that dogs pose for public health and safety (See Appendix A). County and city governments are responsible for enforcement of these laws through their designated Animal Control Officers.

Since 1987, detection of endemic rabies among bats and small mammals has caused every California county to be declared a Rabies Area. In 2024, the virus was detected in Sonoma County bat and fox populations. In a Rabies Area, dog owners and county and city governments are required to comply with legal obligations set forth in the Food and Agricultural section of California Government Codes, the Penal Code, Civil Code, the Corporations Code, and Health and Safety Code.

Laws Governing Animal Services
Penal Code §597 requires each county and city government to ensure that all animals in its jurisdiction are treated in a humane manner.

Health and Safety §121690 (a) requires pet owners to maintain current rabies vaccinations for dogs over three months of age and license dogs over the age of four months. Licensing is the mechanism to ensure timely rabies vaccination. Animal control agencies enforce this law. The county health officer is required to collect county-wide data and submit reports to the state to document the level of county-wide licensing compliance. A Sonoma County Ordinance also requires vaccination of cats although licensing is optional except for the City of Rohnert Park. 4 https://sonoma.courts.ca.gov/system/files/grandjuryanimalservicesreport5-30-18.pdf 5 https://sonomacounty.ca.gov/administrative-support-and-fiscal-services/emergency-management/plans 6 https://code3associates.org/ 7 https://www.forbes.com/advisor/pet-insurance/pet-ownership-statistics 8 https://www.cdfa.ca.gov/AHFSS/Animal_Health/eprs/docs/pet_ownership_calculator.pdf Agenda Item Number: 19 Agenda Item Number: 19
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Health and Safety §121690 (f) (1) requires each county or city government to provide dog vaccination clinics or arrange for dog vaccination at clinics operated by veterinary groups or associations for a charge not to exceed the actual cost.

California Code of Regulation §2606.4 sets forth vaccination and licensing procedures and reporting requirements for any city or county government in a declared rabies area.

Food and Ag §30503 mandates that no public animal control agency or shelter, Society for the Prevention of Cruelty to Animals shelter, humane society shelter, or rescue group shall sell or give away to a new owner any dog or cat that has not been spayed or neutered. (A veterinarian may approve a temporary delay when required by the dog’s health.) While not required by the state mandated rabies control plan, Sonoma County recognizes the role of spay/neuter programs to reduce the population of unowned and stray animals that are less likely to be vaccinated and more likely to roam, fight or bite, potentially spreading rabies. The county mandates sterilization of pit bull breeds and of dogs running at large.9 SCAS supports spay/neuter for low-income pet owners and partners with Forgotten Felines to spay/neuter Community Cats through its Trap/Neuter/Return program.
10 A table is provided in Appendix A that summarizes animal-related regulations referenced in this report.

Industry Standards for Shelter Facilities and Care of Shelter Animals The Association of Shelter Veterinarians publishes Guidelines for Standards of Care in Animal Shelters which are widely accepted as industry standards. Best Practices cited in the Sonoma County 2012 Animal Services Report are based on the first edition of this document which was produced with input from U.C. Davis shelter veterinarians.

In making assessments of animal care and shelter management and maintenance during shelter visits, Jurors referenced the 2022 Second Edition of the guidelines11 and a 2023 Checklist of Key Statements.
12 Each of the 553 actionable statements made in this 64-page document is presented as unacceptable, must, should, or ideal. The statements are presented in 13 sections covering all aspects of shelter care. The Grand Jury focused on statements where compliance could be assessed based on physical inspection, interviews, or document review.

An over-arching admonition made throughout the shelter standards is that “…Operating beyond an organization’s capacity for care is unacceptable.” Certain other statements, paraphrased below, are included in multiple sections of the guidelines:

Animal Care
• A formal relationship with a veterinarian must be in place to ensure oversight of medical and surgical care in the shelter.
9 https://library.municode.com/ca/sonoma_county/codes/code_of_ordinances?nodeId=CH5SOCOANREOR_ARTXIVMASPNEALD ORULAALPIBU_S5-
170MASPNEALDOLA#:~:text=Article%20XIV.%20%2D%20Mandatory%20Spay%20and%20Neutering,Running%20At%20Large %20and%20All%20Pit%20Bulls.
10 https://sonomacounty.ca.gov/health-and-human-services/health-services/divisions/public-health/animal-services/spay-and-neuter 11 https: https://sonomacounty.ca.gov/health-and-human-services/health-services/divisions/public-health/animal-services/spay-andneuter//www.aspcapro.org/sites/default/files/2023-05/asvguidelinessecondedition-2022.pdf 12 https://www.sheltervet.org/assets/docs/2022-ASV-GL-Checklist.pdf Agenda Item Number: 19 Agenda Item Number: 19
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• Veterinarians should be integrally involved with development of the shelter’s development and updates to written policies and protocols for animal care. • Each animal must receive at least a cursory health assessment by trained personnel at intake to check for signs of infectious disease or problems that require emergency care. • Medical, surgical, and behavioral services for foster animals must be provided in a manner that promotes animal welfare and minimizes length of stay (at the shelter). • Shelters must have comprehensive protocols in place for recognizing and mitigating stress and associated negative emotions including fear, anxiety, and frustration. • Foster care providers should be given clear instructions about how and when to access emergency and after-hours care.
• Shelters should sterilize all animals before adoption or ensure that they will be sterilized after their outcome. [NOTE: In California this is mandated by Food and Ag §30503.] Shelter Staffing
• Shelters must have adequate, qualified personnel.
• Shelters must provide training for each shelter task and continuing education must be provided for all personnel to improve skills and maintain credentials. • Continuing education must be provided for all personnel to improve skills and maintain credentials.

Shelter Maintenance
• Written protocols for animal care and shelter sanitation must be developed and documented in sufficient detail to achieve and maintain accepted industry standards. • Ventilation must be maintained at a high enough rate to ensure adequate air quality in all areas of the shelter including in the primary enclosure.
• Noise must be minimized in animal housing areas.
• All food must be protected from wildlife, rodents and insects. • Shelters responding to disasters as part of a coordinated response should draft memoranda of understanding (MOUs) with their governmental and nongovernmental response partners.

DISCUSSION
Decentralization and Fragmentation of Animal Services
As dictated by California state law, Sonoma County, and each of its nine cities determines how it will meet California’s animal-related regulations. The county and each city government is responsible for implementing its own Rabies Control Plan. Central to rabies control is legally mandated vaccination and licensing. The ten governments have set different license and service fees and fee concessions for animals within their jurisdictions. These fees are presented in Appendix B.

The resulting patchwork of fees and concessions is confusing to the public. It complicates efficient, cost-effective license enforcement and collection of license fees. It’s confusing to pay one fee when a friend in a nearby city pays another. Agreement among the county and city governments on a common fee schedule and online license management vendor would resolve these issues.

Agenda Item Number: 19 Agenda Item Number: 19
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SCAS provides animal control and animal shelter services to 66% of Sonoma County’s population.

NBAS serves 21%. The remaining 13% receive animal control services through local police departments and shelter care through the Rohnert Park Animal Shelter, the Humane Society of Sonoma County and numerous private and non-profit organizations that provide shelter, adoption, and spay/neuter programs for Sonoma County pets. Among these, the privately funded Pets Lifeline, Dogwood, and Forgotten Felines stand out for their adoption programs and Trap/Neuter/Return (TNR) work to reduce community/feral cat populations.
• Sonoma County Animal Services (SCAS) operates within DHS to provide animal control to the 66% of county residents who reside in the unincorporated areas, and the Cities of Healdsburg and Santa Rosa. It also shelters pets from the City of Sonoma and is responsible for the full range of domestic and wild animals. It has overall responsibility for implementing the rabies control plan and emergency animal evacuations.
• North Bay Animal Services (NBAS) contracts with the Cities of Cloverdale, Windsor, Sebastopol, and Petaluma to provides animal control field services and shelter to more than 20% of Sonoma County.
• Rohnert Park Animal Shelter (RPAS) is owned and managed by the City of Rohnert Park. The shelter serves both Rohnert Park and Cotati in cooperation with the cities’ police departments.

Municipal funding is augmented by a non-profit foundation. • The Humane Society of Sonoma County (HSSC) cares for animals from Healdsburg, citizen surrendered animals from throughout the county, and transfers from other shelters. It operates a veterinary hospital that provides pet care for low-income owners, including low-cost spay/neuter surgery and routine vaccinations (but not rabies vaccinations). HSSC currently outsources animal control for Healdsburg to SCAS. It is primarily funded by private contributions and grants and is overseen by its board of directors. An MOU with the county for emergency response is pending. • The City of Sonoma Police Department provides residents with animal control, including licensing. Shelter care is provided as needed by SCAS and Pets Lifeline.

Common Challenges to Animal Service Providers
This investigation and a review of Civil Grand Jury reports from nearby counties revealed animal services to be a costly, labor and facilities intensive endeavor. Several issues were mentioned repeatedly and were observed, to a greater or lesser degree, in Sonoma County facilities.

Collaboration among the county and cities could ameliorate many of these challenges, which include:
• Underfunding: Animal services compete with other compelling needs for public tax dollars.

Limited county and city funds are augmented by license and service fees and fines. Collection of these fees can be difficult and time consuming for staff. • License Enforcement: License compliance is important, both for rabies control, and because it generates needed income, but agencies struggle to achieve high rates of compliance. A study conducted by the on-line license management vendor, DocuPet, found an average nationwide compliance rate of only 23%. The highest rate found by the Grand Jury was 50%. In Sonoma County, 2024 rates range from 12% to 31% as shown in Appendix C. Among the obstacles to improved licensing compliance that were identified by DocuPet was a lack of public outreach to explain: 1) the importance of vaccination and licensing for rabies control; 2) the legal Agenda Item Number: 19 Agenda Item Number: 19
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requirement for owners to license their dogs; and 3) the benefit of returning a lost pet regardless of where it has wandered.
• Aging Facilities: Constant maintenance and costly upgrades are required to ensure that aging facilities meet the health and safety needs of animals, staff, and visitors. Operating in aging, outgrown facilities makes daily operations more difficult. • Insufficient Veterinary Services: A nationwide veterinarian shortage limits access to needed professional care, including affordable rabies vaccination and spay/neuter clinics that are mandated for public safety and population control. Demand has driven up costs and reduced availability of pro bono services.
• Insufficient Staffing and Personnel Turnover: Shelter staff are stretched to accomplish a wide range of duties, ranging from animal care to data entry, website management, license management, and interaction with the public. Understaffing and turnover of experienced staff and volunteers requires effective recruitment, supervision, and training and professional development programs that can exceed organizational capacity. • Public Demands for “No Kill” Outcomes: Public sentiment can fail to recognize differences between private agencies that can limit acceptance to adoptable animals and public shelters that are obligated to accept animals regardless of medical or behavioral issues that may preclude live outcomes. The resulting negative impact on public perception can undermine needed support. • A Lack of Centralized Communication and Data Sharing: Without the means to communicate and coordinate activities, agencies are hampered in meeting regularly occurring needs such as rehoming lost pets, coordinating responses to calls for animal control, and sharing knowledge and resources. It impairs the ability to prepare accurate state-mandated licensing reports, track dangerous animals, or mount a fully coordinated, county-wide disaster response.

Tax-Supported Agencies Providing Animal Control and/or Shelter Sonoma County Animal Services (SCAS) operates within the Department of Health Services to provide animal services to the 66% of county residents who reside in the unincorporated areas and the Cities of Santa Rosa and Healdsburg. It also has an MOU to shelter companion animals from the City of Sonoma.

Scope of Service: In addition to companion animals, SCAS is responsible for farm animals, livestock and wild animals. As a government agency it is required to accept and manage animals regardless of their physical condition or adoptability. It enforces local, state, and federal laws that pertain to animal care and public safety. SCAS administers the state-mandated rabies control program which includes facilitating rabies vaccinations and managing bite reports and quarantine of dangerous animals. It engages legal services to handle cases involving animal bites and incidents of neglect and abuse cases. It collects and compiles license compliance data from all jurisdictions and submits county-wide reports to the state. SCAS is also the lead agency for animal emergency evacuation planning and coordination of emergency response.

Facilities: Demand for pet sheltering sometimes exceeds capacity of the 100-kennel shelter that was built in the late 1980s and was last renovated in 2001. It must also provide housing for a full range of domestic and wild animals. On October 6, 2015, the BOS approved funds for an assessment of the facility and design of needed improvements. After being interrupted by Covid, the design process is funded and underway. Projects will be done in phases starting with Agenda Item Number: 19 Agenda Item Number: 19
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ventilation improvement and noise reduction in the kennels and upgrades to the entry area to enhance interactions with the public.

Staffing: Thirty-two full-time positions include certified veterinary technicians, ten licensed animal control officers, other specialists, and public service and operations staff. It has a contract veterinarian six hours/day, five days a week and hires extra veterinary services at times. It also has a network of veterinarians who volunteer in emergencies. Volunteers provide essential support for animal and shelter care. Volunteers, shelter staff and animal control officers have access to extensive training and continuing education.

Veterinarians, assisted by vet techs conduct intake examinations, care for sheltered and fostered animals and perform spay/neuter surgery. Animals are vaccinated at intake and are sterilized prior to placement in foster or adoptive homes. Low cost spay/neuter services are provided to community members though limited resources create long lead times for surgeries.

Revenue and Cost of Service: Seventy-five to eighty percent of the SCAS $6.7 million budget comes from Sonoma County, Santa Rosa, and Healdsburg taxes. This is supplemented by collection of license and service fees and tax-deductible donations. Collection rates for service fees are low. Follow up is staff intensive. The SCAS Director estimated an outstanding balance of as much as $2 million in service fees and penalties. As a county agency, SCAS is required to pay county salaries and benefits.

SCAS is nearing the end of a three-year contract with DocuPet for online license management. A $25,000 annual payment covers collection of license fees and fines and all correspondence, including sending timely renewal notices. The SCAS Director reported that service has been so efficient that it allowed a reduction to license fees while achieving the highest licensing rates in the county.

The SCAS budget of $6.7 million dollars provides an extensive range of animal control and shelter services for approximately 305,000 residents of Santa Rosa, Healdsburg, and unincorporated Sonoma County. Santa Rosa’s $3,346,000 contract accounts for about 40% of animal control and shelter budget, or about $191,000 per 10,000 residents.

Rohnert Park Animal Shelter is owned and managed by the City of Rohnert Park through its Community Services Department.

Scope of Service: RPAS provides shelter care for companion animals for both Rohnert Park and Cotati. The two cities’ Police Departments provide animal control. RPAS has recently assumed licensing responsibility from the Rohnert Park Finance Department. It outsources license management to DocuPet and shares data with SCAS. DocuPet retains a small fee for each license. It maintains records and sends renewal reminders. Rohnert Park is the only city that requires cat licensing. Cotati offers a one-time voluntary cat license.

Facilities: Like other shelters, RPAS was built in the 1990s, but it underwent a major renovation in 2005 and has had many smaller upgrades. It is immaculately maintained with 35 dog runs, “flexible capacity” for cats, rabbits, and other small mammals. Designated areas for surgeries, food preparation, and laundry are clean and well-organized.

RPAS has earned certification as a Fear Free Shelter by implementing facility improvements and animal management practices that minimize stress and optimize safety for pets and humans.

These include using sound baffles for noise control and minimizing unnecessary disruption that can lead to loud outbursts. Potential adopters view videos of available pets and meet those they wish to interview in a pleasant, private space away from other animals. Positive animal behaviors Agenda Item Number: 19 Agenda Item Number: 19
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are reinforced with small treats. Instead of the frantic barking Jurors experienced in other shelters, they were met with calm, friendly, and noticeably more “adoptable” animals.

Staffing: Staffing includes the supervisor, who holds animal control, vet tech, and euthanasia certifications; a second vet tech; and a community service assistant. A contract veterinarian visits twice a week to provide animal care and perform surgeries. Every animal of required age or size is spayed/neutered and fully vaccinated prior to placement in a foster or adoptive home.

Microchipping is free for Rohnert Park and Cotati residents. While the shelter offers low-cost spay/neuter services to its community members, the wait time for an appointment can be long.

Fifteen to 20 of the 100 volunteers schedule regular shifts to assist staff with animal care and shelter maintenance. Many more assist with special projects and activities such as adoption events.

Revenue and Cost of Services: The RPAS budget of $565,000 provides a high standard of shelter care to a population of 44,000 at a cost of $128,409 per 10,000. In addition to its municipal funding, the shelter benefits from an independent foundation that raises funds for shelter improvements and to support a variety of programs that support the community of pet owners. These include pet collars and leashes for newly adopted pets and Silver Paws funding to offset the cost of pet ownership for low-income seniors.

The Humane Society of Sonoma County (HSSC) is included in this list of key agencies because of the limited tax revenue it receives through a contract with the City of Healdsburg to oversee animal control and shelter care. HSSC provides the shelter care and sub-contracts animal control. A $104,000 animal control sub-contract with NBAS, that was near expiration, was terminated and a new $114,000 contract with SCAS took effect on March 1, 2025.

Scope of Service: HSSC cares for animals from Healdsburg, citizen surrendered pets, and transfers from other shelters. Because it is not a government agency HSSC can be selective in its admission and focuses on adoptable animals.

Facilities: HSSC operates in an immaculate, well-maintained facility purposely built to a high standard of shelter design with donated funds. An adjacent building houses a veterinary hospital that provides pet care for low-income owners and offers low-cost spay/neuter surgery and routine vaccinations. It does not offer rabies clinics and does not manage licensing.

Staffing: HSSC staff includes veterinary professionals and development and communication professionals who manage its fundraising, community relations, and a website that provides a wealth of information on animal care and services throughout the county. Other staff provide maintenance, cleaning, and sanitation. Multiple well-trained volunteers are on site at any given time, interacting as team members with animals and staff. Training and continuing education are provided at all levels.

Funding: HSSC is primarily funded by private contributions and grants and is overseen by its board of directors. The Grand Jury did not pursue detailed budget information because of its focus on the county and municipal agencies.

The City of Sonoma Police Department provides residents with animal control, including licensing which is done on an in-person, walk-in basis. The licensing rate in 2024 was ~15%. Shelter care is provided as needed by SCAS and Pets Lifeline.

Agenda Item Number: 19 Agenda Item Number: 19
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North Bay Animal Services (NBAS) was incorporated as a 501-(c)-3 organization in 2018 to operate the city-owned Petaluma shelter and provide the city with animal control services. It succeeded Petaluma Animal Services in this role.

Scope of Service: NBAS currently provides animal control and shelter services to more than 20% of the county’s residents through contracts with the Cities of Cloverdale, Windsor, Sebastopol, and Petaluma. It also contracts with Calistoga and operates the Clearlake shelter.

Responsibilities include responding to field calls for domestic and wild animals, providing shelter and veterinary care for companion and small farm animals in compliance with industry standards, managing pet licensing and reporting data to the county, and complying with all animal-related laws on behalf of the cities it serves.

Facilities: NBAS rents the city-owned Petaluma shelter for $1/year. The facility is aging and suffering from deferred maintenance. Shelter capacity was described as 40-50 dogs and up to 100 cats. The NBAS contract with Petaluma requires the non-profit to provide routine maintenance. The city is responsible for major repairs and improvements. In recent years, these have included roof work.

Staffing: The Director and eight staff serve the four Sonoma County cities from the Petaluma shelter and a storefront in Windsor. One Animal Control Officer is assigned to Windsor and Cloverdale. A second ACO works from Petaluma. The Executive Director is also an ACO who reported that calls are monitored 24/7. Shelter staff also include shelter technicians for cleaning and basic animal care, customer service, a social media position, one “coordinator” each for dogs and cats. No specific qualifications for shelter care of animals were listed either on the staff list provided to the Grand Jury, or on the bios that appear on the agency website.

Revenue and Cost of Service: Annual contract revenue totals $1,233,000 from the four Sonoma County cities, with a combined population of 100,000. At only $123,300 per 10,000, this is even less than the RPAS budget that does not include the cost of animal control field operations.

Grand Jury Observations about NBAS Performance
NBAS’s city contracts require it to comply with all applicable laws for animal shelters, including quarantine and tracking of dangerous animals, sterilization of animals placed in foster or adoptive homes, and enforcement of licensing/vaccination for rabies control. The Grand Jury identified significant failures to comply with these laws and other terms of its city contracts:
• Multiple professionals and private citizens stated that NBAS places unaltered animals in foster and “foster-to-adopt” homes and that appointments for legally mandated spay/neuter surgery can be delayed for many months. The Grand Jury obtained an email which confirmed that NBAS was aware of multiple similar complaints about delays in sterilization and vaccination. • NBAS doesn’t facilitate rabies vaccination. State law assigns responsibility for vaccination and licensing both to dog owners and every government jurisdiction. Cities are responsible for enforcing these laws through their designated Animal Control Officers, which is NBAS in the case of Petaluma, Cloverdale, Windsor and Sebastopol.
• Jurors were told that NBAS received 350 to 370 bite calls a year, but the Jurors were unable to secure evidence that legally mandated bite reports had been filed or that potentially dangerous animals were being quarantined as required by state law. This is a matter of concern for public safety and poses the potential for city liability resulting from dog bites.

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• NBAS does a poor job of facilitating dog licensure and license renewal. NBAS licensing data for 2024 showed only 12% compliance across NBAS cities compared with 23% in Santa Rosa and 31% in unincorporated Sonoma County. (See Appendix C for licensing rates as estimated based on a state methodology.)
• NBAS advised the Grand Jury that animals are taken to one of several veterinarians when in need of emergency or routine care, so there is no supervising veterinarian in charge of animal medicine. The shelter has no single veterinarian contracted to consult on written protocols for physical, conditions, sanitation, or general animal care at the shelter. • No NBAS staff member is identified as having had the training and oversight by a veterinarian that is required to conduct physical and behavioral assessment of incoming animals. • Employees serving in the key positions of Dog Coordinator and Cat Coordinator were described as “experienced,” but without any specific veterinary certifications included in their bios on the NBAS website.
• There is no documentation of training or continuing education of staff or volunteers. • The workspace for food preparation observed by the Grand Jury is cramped and cluttered; open bags of pet food, some stacked on the floor, are accessible to rodents and other pests, in violation of shelter standards.
• During visits to the shelter, the Grand Jury experienced an overpowering foul odor that suggests that the ventilation system is unlikely to be providing air quality consistent with the health and safety of both animals and humans.
• NBAS does not have a written plan for emergency response. Nor does it have an MOU with the county to specify its role as an emergency responder.

NBAS is contractually required to maintain its facility either “in compliance with industry standards,” or U.C. Davis Guidelines for Standards of Care in Animal Shelters. The list above demonstrates that it fails to comply with industry standards for animal care, shelter management, and maintenance.

The NBAS Executive Director has an extraordinary—and unrealistic—range of responsibilities. The Director manages staff at the Sonoma County locations, the City of Calistoga, and a second shelter in Clearlake. Although NBAS reports 24/7 call monitoring, multiple sources noted that reaching the shelter and securing a response to messages is extremely difficult.

The Director manages the organization’s operations, its finances and shelter data. The Director is responsible for negotiating and fulfilling the city contracts, which include complying with all applicable laws and maintaining the shelter in compliance with industry standards.

The Director also maintains the agency website where essential information, including online pet licensing, is absent, out-of-date, or inaccessible due to broken links. License renewal notices are not currently being sent, reportedly because of the cost and staff time. Data provided to the Grand Jury showed that the number of license renewals fell from 1,816 in 2023 to 733 in 2024 resulting in a loss of revenue and undermining rabies vaccination enforcement. (See Appendix C for License Compliance data.)
Two or three of an estimated 40-60 volunteers assist staff during each of the morning and afternoon shifts. Unlike other shelters, the number of volunteers has reportedly not recovered since it dropped during COVID.

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In short, the Grand Jury concluded that NBAS is extended beyond its financial and organizational capacity to comply with either its contracts or applicable laws, a circumstance which, according to shelter standards, is unacceptable. It is surviving despite a perfect storm of underfunding, an aging facility, insufficient use of veterinary services, and a staff that is too small, lacking in continuing education and relevant certification, and wearing too many hats.

City Oversight of Animal Services is Inadequate
Each of the four cities that contract with NBAS have failed to adequately monitor or evaluate the quality of service being provided by NBAS. None of these four cities can be sure they are fulfilling their legal responsibility to facilitate vaccinations, report dog bites to the State of California, ensure that dogs are licensed, or require that sheltered animals be spayed or neutered prior to release for adoption.

Since NBAS has been the animal services contractor, only one city official reported ever visiting the Petaluma shelter, and that was just once. Without periodic inspections, how can these cities be sure they are getting the service they are contracted to receive? None of the city contracts require NBAS to submit reports that contain quantifiable performance criteria in order to evaluate compliance. How are the cities evaluating contract compliance without any reporting? Only Petaluma requires reporting (annually) to the City Council, and in the 7 years that NBAS has been the animal services contractor, only 3 reports have been submitted—the last one was filed in 2022. Some contracts specify an acceptable response time for calls for animal control, but NBAS does not track response time, and the cities are not requiring it.

Jurors questioned how contracts were awarded. It became clear that NBAS proposals offered a full range of services for prices below those of competitors. Most of the multi-year contracts, including one for 10 years, are for flat annual payments without escalation clauses to accommodate increased costs.

It is unsurprising that the cities did not question whether NBAS bids were sufficient to provide contract services. The low cost would be desirable if the terms of the contracts were being fulfilled.

However, they are not. What the Jurors did not anticipate was the uniform lack of oversight and outright denial about NBAS shortcomings that was revealed in every city interview.

Each city official interviewed by the Grand Jury stated that they weren’t aware of significant issues with NBAS. Based on multiple interviews, the Grand Jury confirmed the original complaint, that NBAS is operating with insufficient oversight by its board of directors or the cities with which it contracts.

CONCLUSIONS
• Most Sonoma County residents are receiving animal services that approach, achieve, or even exceed industry standards. However, this is not the case for the over 20% affected by city contracts with NBAS.
• The existing decentralization of animal control and shelter services and the lack of oversight by the county, the four Sonoma County cities with NBAS contracts, or by the agency’s board of directors, has allowed unacceptable performance by NBAS to persist without intervention. • The NBAS proposals on which its contracts are based promise an extensive range of services for a cost that is far below the budgeted costs of either SCAS or RPAS. The result is that NBAS is inadequately funded to fulfill its responsibilities.

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• In recent years, as an underfunded and underperforming non-profit agency, NBAS has failed to provide animal services which are compliant with state mandates and contract provisions. The 2012 DHS report cautioned that insufficient oversight could lead to this situation. • The existing fragmentation of services is inefficient and confusing for members of the public. It makes it difficult to know where to call in an emergency, or how to access needed services. Fees for licensing and services vary, as does the range and quality of information available on websites and the ability to contact a shelter or animal control officer. • The lack of shared data and communication channels poses unique challenges for animal control agencies, the County Department of Health Services, and the Office of Emergency Management.

It hampers compliance with legally mandated management and reporting of licensing data and the quarantine and tracking of potentially dangerous animals. It makes it more difficult for owners to locate lost pets. It can delay or disrupt response to emergency situations. • Following a series of disastrous fires and floods, the County appointed the SCAS Director as animal liaison to participate in development of the Sonoma County Emergency Operations Plan.

In 2018, it added an animal disaster response plan with defined procedures and established MOUs to define roles for key NGOs. NBAS is not among these partners and not all cities have developed such plans.
• Funding constraints and a lack of coordination among agencies leaves most municipal and nonprofit shelters struggling to accomplish support functions that are essential to all such as timely license renewals and invoicing for fees, staff and volunteer training, and maintenance of websites to provide effective public outreach. Thoughtful centralization of some or all these functions could lead to improved, cost-efficient solutions, and increased revenue collection. • Rabies control efforts are undermined by failure to achieve high levels of pet licensing and implement spay/neuter programs for population control. Failure to collect license and shelter service fees results in the loss of revenue to support animal services.

COMMENDATIONS
The Grand Jury recognized the steady progress achieved by SCAS to comply with best practices, and other recommendations contained in the 2012 DHS report. This progress is acknowledged in subsequent reports to the Board of Supervisors and is, in part, due to the Board’s on-going oversight and support of improved animal services.

The exceptional volunteer and financial support provided to the Rohnert Park Animal Shelter by its community is testimony to the value of well-run, conveniently located facilities. At the Humane Society of Sonoma County, we experienced an independent non-profit shelter with minimal public funding whose public engagement and service on behalf of animals extends across city and county boundaries.

While our investigation did not extend to the dozens of private and non-profit programs caring for Sonoma County animals, we would be remiss not to call out the outstanding shelter and adoption services provided by Pets Lifeline and Dogwood and the exemplary work of Forgotten Felines to control populations of pet and feral cats. These non-profit organizations depend on the generosity and volunteer support of the community. Our hats are off to all those who care for the county’s companion animals.

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FINDINGS
The Sonoma County Civil Grand Jury determined that:

F1. Failure by the county and its nine cities to adopt recommendations in the 2012 DHS Animal Services Report has left Sonoma County animal service agencies operating without shared standards, communication channels, data sharing or oversight.

F2. Services provided to the four Sonoma County cities by North Bay Animal Services are noncompliant either with state laws or industry standards for the care of shelter animals as specified in its contracts.

F3. A lack of coordination between SCAS and NBAS is an obstacle to a fully coordinated implementation of the county-wide disaster response plan for animal evacuations.

F4. Insufficient funding and staffing make it difficult for some agencies to provide effective training for staff and volunteers.

F5. Insufficient funding and staffing make it difficult for agencies to maintain websites and social media content required for effective public relations.

F6. Having multiple different fee structures for animal licenses and services is confusing to the public and complicates billing and collection of license fees and fines.

F7. Failure to achieve high levels of licensing in all government jurisdictions and provide access to shared information undermines mandated rabies control, makes it more difficult to return lost pets, and results in a loss of revenue.

F8. Based on SCAS data, uniform adoption of online licensing management through DocuPet (or a comparable vendor) would increase county-wide licensing rates and enhance compliance with state law.

F9. Failure to promote the benefits and legal requirement to license dogs, and failing consistently to send license renewal reminders, contribute to low license compliance and loss of revenue.

F10. Making centralized training resources available could enhance performance of animal services employees and volunteers.

F11. Insufficient oversight either by the cities or by the organization’s board of directors has allowed NBAS to be non-compliant with state law and the terms of its contracts by: failing to effectively manage licensing and renewals; failing to offer legally mandated rabies vaccination clinics; failing to perform legally mandated spay/neuter of animals prior to placement; failing to consistently submit bite reports to the county health officer (through SCAS); failing to maintain the Petaluma animal shelter in compliance with industry standards; and failing to collect accurate data and provide reports that demonstrate compliance with contract terms.

F12. A lack of responsiveness to phone calls has eroded public confidence in the ability of NBAS to respond in a timely manner to calls for service or follow-up.

F13. While NBAS is responsible for general maintenance of the shelter, the City of Petaluma is not exercising due diligence with regard to facilities maintenance and repair, which may include an adequate ventilation system based upon the Grand Jury’s observations during its visits.

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RECOMMENDATIONS
The Sonoma County Civil Grand Jury recommends that:

R1. By November 1, 2025, the Board of Supervisors will direct DHS to establish an Animal Services Task Force comprising county, city, and shelter representatives to revisit the 2012 DHS Animal Services Report and recommend a governance structure for animal services that will: 1) provide county-wide oversight to ensure compliance with State Law; 2) standardize fees and engage a common licensing vendor to enhance public health and safety, licensing rates and revenue, and; 3) achieve economic efficiencies through shared resources. (F1, F3, F4- F6 and F9-F10)
R2. By January 1, 2026, each of Sonoma County’s 9 cities will delegate one or more representatives to participate in the county-wide Animal Services Task Force convened by DHS. (F1)
R3. By January 1, 2026, the director or supervisor of SCAS, HSSC, RPAS, and NBAS will commit to participating in the county-wide Animal Services Task Force. (F1) R4. By May 1, 2026, the Board of Supervisors will direct DHS to launch a county-wide public information campaign in cooperation with the cities to explain the legal imperative and benefits of licensing pets. The campaign will commence no later than July 1, 2026. (F7-F9) R5. By November 1, 2025, each city contracting with North Bay Animal Services will inspect and evaluate the shelter condition, and evaluate the shelter operation and animal control services, to determine whether NBAS is complying with legal mandates and other terms of its contract. (F2, F11-F12)
R6. By September 30, 2025, each of the cities that contracts with NBAS will require quarterly reports that include data and performance criteria sufficient to evaluate compliance with its contract and all relevant laws. (F2, F11)
R7. By November 1, 2025, the Petaluma City Council will direct staff to implement a facilities assessment of the city-owned shelter and submit a report of findings related to the adequacy of the HVAC system and any improvements that may be required for the health and safety of animals and humans. (F13)
R8. By June 1, 2026, the City of Petaluma will correct any identified ventilation and/or other defects that put animal and/or human health and safety at risk. (F13)

REQUIRED RESPONSES
Pursuant to Penal Code §§ 933 and 933.05, the grand jury requires responses as follows:
• Sonoma County Board of Supervisors (R1, R4, and F1, F3-F10) • Department of Health Services Director (R1, R4, and F1, F3-F10) • The Cloverdale City Council (R1-R2, R4-6, F1-F3, F6-F11) • The Cotati City Council (R1-R2, R4-R5, and F1 and F3-F10) • The Healdsburg City Council (R1-R2, R4-7, F1-F3, F6-F11) • The Petaluma City Council (R1-R2, R4-8, F1-F3, F6-F13) • The Rohnert Park City Council (R1-R2, R4-R5, F1, F3-F10) Agenda Item Number: 19 Agenda Item Number: 19
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• The Santa Rosa City Council (R1-R2, R4-R5, F1, F3-F10) • The Sebastopol City Council (R1-R2, R4-6, F1-F3, F6-F11) • The Sonoma City Council (R1-R2, R4-R5, F1, F3-F10)
• The Windsor City Council (R1-R2, R4-6, F1-F3, F6-F11)

INVITED RESPONSES
The Grand Jury invites the following to respond:
• Sonoma County Animal Services Director (R1, R4, R5, F1, F3-F10) • The Petaluma City Manager (R1-R2, R4-8, F1-F3, F6-F13) • Humane Society of Sonoma County (R1, R3-5, F1, F3-12) • North Bay Animal Shelter Executive Director (R1, R4-R8, F1-F13) • Rohnert Park Animal Shelter Supervisor (R1, R3-5, and F1, F3-12)

BIBLIOGRAPHY
• The Association of Shelter Veterinarians, Guidelines for Standards of Care in Animal Shelters.

Second Edition, December 2022.
https://www.aspcapro.org/sites/default/files/2023-05/asvguidelinessecondedition-2022.pdf • The Association of Shelter Veterinarians, Sanitation in Animal Shelters. September 1, 2023. https://www.sheltervet.org/assets/docs/5 Sanitation_Final_06AUG2024.pdf • County of Sonoma—Department of Health Services, Sonoma County Animal Care and Control Governance Model Review and Best Practices, August 2012. https://sonoma-county.granicus.com/MetaViewer.php?view_id=2&clip_id=243&meta_id=94249 • Animal Services Facility Needs Assessment Report to the Board of Supervisors, September 12, 2023
https://sonoma-county.legistar.com/gateway.aspx?m=l&id=/matter.aspx?key=12398 • County of Sonoma – Animal Services, Sonoma County Animals in Disaster Response Plan, December 2018
https://sonomacounty.ca.gov/Main%20County%20Site/Administrative%20Support%20%26%20Fiscal% 20Services/Emergency%20Management/Documents/Archive/Administration/Services/2147553654/SCA SAnimalAnnex%20FINAL%202018%20DEC.pdf
• State of California Department of Finance, Population and Housing Estimates for Cities, Counties, and the State—January 1, 2023, and 2024, May 2024. https://dof.ca.gov/forecasting/demographics/estimates-e1/ • California Department of Food and Agriculture, Pet Ownership Calculator https://www.cdfa.ca.gov/AHFSS/Animal_Health/eprs/docs/pet_ownership_calculator.pdf • 2017-2018 Sonoma County Civil Grand Jury, The Evacuation and Sheltering of Animals During the Firestorm of October 2017.
https://sonoma.courts.ca.gov/system/files/grand-jury/gj-2017-2018-finalreport.pdf Agenda Item Number: 19 Agenda Item Number: 19
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Sonoma County Emergency Evacuation Plans
Are We Ready for the Next Major Evacuation?
Sonoma County has endured four major wildfires and several severe floods in eight years. Each incident exposed the same weaknesses: narrow highways with inadequate capacity, sparse alternate routes, patchy communications capability, and limited shelter planning. The County still lacks detailed, scenario-based evacuation plans and has not met new state mandates that require them.

California’s Emergency Services Act makes local governments responsible for disaster planning, evacuation planning, and emergency plan execution. Three recent statutes enhance the requirements:

Assembly Bill AB 747 (2019) mandates evaluation of evacuation route capacity, safety, and viability; SB 99 (2019) requires counties to map every neighborhood with only one way in or out and propose remedies; and AB 1409 (2021) requires advance designation of evacuation shelters and refuge areas.

Sonoma County has not yet fully complied with these mandates. Updates to evacuation route definition, traffic capacity analysis and simulation, and shelter planning are not expected until 2030, far later than comparable jurisdictions. Other meaningful findings:
• Infrastructure is the biggest vulnerability. Many roads and bridges cannot carry simultaneous outbound traffic and inbound emergency vehicles; choke points repeat fire after fire. • Planning is “ad hoc.” Unlike the City of Santa Rosa, which pre-assigns traffic control resources and shelter sites, the County relies on on-the-fly decisions during an incident. • Technology gaps hinder readiness: Sonoma County lacks modern evacuation modeling tools used by peer counties. Zone-specific evacuation planning isn’t possible without better tools. • Cell outages are common, especially during power failures, and alert systems SoCoAlert, WEA, and Nixle won’t work in rural areas without cell service. Radio repeaters that would improve public communication during widespread emergencies haven’t been completed. Community radio networks need stronger integration with the County’s Emergency Operations Center.

The Sonoma County Civil Grand Jury makes the following suggestions to Sonoma County leadership: accelerate compliance with state mandates by completing evacuation route assessments and other safety plan updates well before 2030; invest in modern simulation and planning tools to inform real-time evacuation decisions; upgrade key evacuation routes to support contraflow strategies and emergency traffic signal control systems; expand GMRS repeater coverage and integrate neighborhood nets into the EOC to ensure alerts reach remote areas reliably; and publish zone-specific plans with route options, evacuation destinations, and communication protocols that residents can follow during a disaster.

Sonoma County has foundational emergency planning infrastructure and a motivated volunteer community, but the County could be better prepared for a fast-moving disaster. Without accelerated investment in planning, communications, and road improvements—and full compliance with California’s legal standards—the risk of chaotic, life-threatening evacuations remains high.

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METHODOLOGY
• Reviewed Sonoma County’s existing emergency plans, hazard analyses, and organizational charts.
• Interviewed county emergency managers, police and fire chiefs, and public works officials about evacuation procedures and capabilities.
• Examined reports of past incidents affecting Sonoma County and nearby areas. • Compared Sonoma County’s plans and resources against state/federal emergency management guidelines (NIMS, FEMA best practices) and lessons learned from other communities. • Consulted scholarly studies and after-action reviews on evacuation logistics, communication systems, and community preparedness.

GLOSSARY
• Emergency Operations Plan (EOP): A written plan that describes how local officials prepare for, respond to, and recover from emergencies.
• Emergency Operations Center (EOC): A central coordination hub activated during major incidents; it supports on-scene responders and manages multiagency efforts. • Incident Command System (ICS): A standard framework for organizing on-scene response. It defines roles and a chain of command so police, fire, EMS, and other responders can work together smoothly.
• National Incident Management System (NIMS): A national framework that ensures all levels of government (local, state, federal) use common terminology and procedures during any incident.
• Voluntary Organizations Active in Disaster (VOAD): A coalition of nonprofits and faith-based groups (such as the Red Cross and CERT) that provide coordinated relief and recovery support alongside government agencies.

BACKGROUND
Tubbs, Kincade, LNU Lightning, and Glass—the wildfires that plagued Sonoma County during the past eight years—forced thousands of evacuations. When nature’s fury is at your doorstep, getting away is the only safe option. Will you be able to?
Highway 12 was the only route away from the 2017 Tubbs Fire for many residents on the east side of the county. Two years after the Tubbs fire, the Kincade fire threatened Healdsburg and Windsor prompting evacuation of almost 190,000 people. A year later, the Glass Fire again threatened Sonoma, Rincon and Bennett Valleys. Highway 12, the primary evacuation route, once again proved inadequate to handle the surge in traffic. Many residents were stuck in traffic for hours as the fire approached. The Sonoma County Civil Grand Jury (Grand Jury) decided to explore this question:
“How well are city and Sonoma County resources prepared for future emergency evacuations?” Each of the county’s four major wildfires has caused significant traffic jams, largely because many Sonoma County roads cannot simultaneously accommodate incoming emergency vehicles and outgoing evacuees. Sonoma County has also experienced an increase in the number and severity of "atmospheric rivers", which bring excessive rainfall, flooding, and debris flows to lowlands, creeks, and rivers. Some motorists misjudge the depth of flooded roads and become stuck or submerged.

Others have been caught by rapidly rising creeks. Many low-lying areas in the county are served by Agenda Item Number: 19 Agenda Item Number: 19
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a single bridge or single-lane road, which presents significant evacuation challenges for both residents and emergency responders.1
The county’s geography means residents are spread out across mountains, valleys, and rural plains.

Thousands of residents live in remote canyons or along single lane roads, where reaching an exit route during a natural disaster can take hours. There are only a few main evacuation routes which can become bottlenecks. The entire western half of Sonoma County was told to evacuate proactively during the 2019 Kincade Fire because emergency management leadership realized that wind direction and fire spread could lead to thousands of residents being trapped with few outbound routes.

Most of Sonoma County is lightly populated and mountainous. Cell phone and internet coverage are inconsistent and frequently unavailable outside the towns, so many residents will not receive emergency alerts transmitted via digital networks. Long travel distances, limited road access, and communication gaps in remote areas are well-known constraints that significantly hinder evacuation planning.

Sonoma County also has several major earthquake fault lines, which will eventually pose entirely different evacuation challenges, but local geography and recent experience indicate that fires and flooding are the most pressing threats. This report is principally concerned with the challenges of safely evacuating residents during wildfire and flood emergencies.

Legal Authority for Emergency Management and Local Responsibilities:

State Law Mandates for Disaster Management and Preparedness California’s persistent threat from wildfires and floods has prompted a robust framework of state laws governing disaster management and preparedness. These laws contain state mandates for local authorities, assigning cities and counties clear responsibilities for both operational emergency response and advance planning to mitigate disaster impacts.

The California Emergency Services Act (CESA), codified as California Gov. Code (§8550 et seq.)2 ,
is foundational and recent legislative updates to the CESA strengthen the role of local entities in wildfire and flood preparedness. Key areas contained in the CESA include the legal structure for emergency response coordination, requirements for evacuation route planning and mapping, and the integration of modern technologies (GIS mapping, alert systems, evacuation software, etc.) in disaster preparation.

CESA defines California’s emergency management framework, establishing the hierarchy of disaster response and the duties of state and local governments. Under this framework, the Governor’s Office of Emergency Services (Cal OES) coordinates statewide efforts, but local governments are on the front lines of both planning and response. State law makes the State Emergency Plan operative within every city and county; it requires local governing bodies to implement that plan’s provisions. In practice, this means each county and city must maintain an emergency management organization and be ready to carry out the State Emergency Plan in disasters.

The CESA explicitly empowers “the chief executives and governing bodies of political subdivisions” (i.e. city leadership and county supervisors) with emergency authorities. Local 1 More lives would have been lost except for the bravery of first responders and neighbors in the chaos created by these rapidly moving fires, and water fatalities would be higher without the efforts of highly trained rescue teams, including the Santa Rosa Fire Department Swift Water Rescue Team, the Sonoma County Sheriff's Office Dive Team, and the Sonoma County Search and Rescue Team.
2 https://leginfo.legislature.ca.gov/faces/codes_displayexpandedbranch.xhtml?tocCode=GOV&division=1.&title=2.&part=&chapter=7 .&article=
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ordinances designate officials (such as county sheriffs, city managers, fire chiefs, etc.) who are vested with powers to proclaim local emergencies, deploy resources, and take extraordinary measures to protect life and property when disasters strike. By law, counties and cities may create local disaster councils via ordinance, which “shall develop plans for meeting any condition constituting a local [or state] emergency”.

Under the state’s Standardized Emergency Management System (SEMS), which is required by Government Code §8607(a)3, local governments must use standardized incident command and coordination structures during multi-agency emergencies.

Role of Local Agencies in Disaster Response
Local authorities have primary responsibility for on-the-ground disaster response in their communities. Each city and county has an emergency organization led by a director of emergency services who is statutorily empowered to implement emergency plans and direct resources. Three cities in Sonoma County (i.e., Santa Rosa, Healdsburg, and Petaluma) have their own Emergency Managers who act as "conduits" to the County's Department of Emergency Management. While most larger cities in the county are responsible for policing and traffic control during an emergency, advance planning for roads critical to mass evacuations rests with the County.

The process whereby local officials declare a “local emergency to activate extraordinary powers and mutual aid is defined in Gov. Code §8630; when a local emergency is declared, the governing body and its agencies have broad powers to control movement (including ordering evacuations), commandeer private property if needed for public use, and set curfew areas. Since Sonoma County is principally responsible for organizing and coordinating emergency evacuations, this Civil Grand Jury report is focused on evacuation planning and preparedness by County officials.

It’s worth noting that all public employees in California are considered Disaster Service Workers by law (Gov. Code §§3100–3102)
4 and can be called upon to perform emergency duties. This underscores the expectation that local agencies (schools, public works, etc.) will contribute to disaster response under local leadership. In summary, the legal framework imposes a dual obligation on local authorities: they must plan and prepare for foreseeable emergencies (through emergency plans, training, resource arrangements) and also lead the initial response when disasters occur, coordinating closely with state agencies and neighboring jurisdictions.

Role of Local Agencies in Disaster Planning and Preparedness: General Plan Safety Element Beyond real-time response, California statutes place heavy emphasis on advance planning to reduce disaster risks. This is primarily achieved through land use planning laws and hazard mitigation requirements that compel local governments to prepare for wildfires and floods before they happen.

The centerpiece is the General Plan Safety Element that every city and county must adopt as part of its general plan (the local long-term blueprint for development). State law requires this safety element to comprehensively address the community’s disaster risks and strategies to mitigate them.

Under Government Code §65302(g)5, the safety element must establish a set of goals, policies, and objectives, as well as implementation measures designed to carry out such goals, policies and objectives, to protect the community from “unreasonable risks” of various hazards, specifically including flooding and wildland and urban fires. The statute mandates inclusion of up-to-date 3 https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV&sectionNum=8607 4 https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=3100.&lawCode=GOV 5 https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV&sectionNum=65302.

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hazard mapping and policies for disaster prevention and response. For example, the law specifies that the safety element “shall include mapping of known seismic and other geologic hazards” and must “address evacuation routes …peak load water supply requirements, and minimum road widths and clearances around structures, as those items relate to identified fire and geologic hazards.” California law ensures that local disaster planning is an ongoing process by requiring regular evacuation plan updates and by requiring that planning take state and federal data into account.

Cities and counties must periodically revisit their safety elements to reflect new knowledge of wildfire behavior, floodplain changes, climate projections, and to incorporate lessons learned from recent disasters. Fundamentally, the law charges local officials with anticipating the worst– identifying where fires or floods are likely to occur, how evacuation and response will be handled, and what steps can lessen the danger–and embedding those considerations into their community’s long-term development policies.

Over the past 15 years, the Legislature has enacted further refinements to these planning requirements for both wildfire and flood hazards:
• Wildfire Planning (SB 1241 and successors6): In 2012, Senate Bill 1241 added new obligations for jurisdictions with State Responsibility Area (SRA) wildfire zones or locally designated Very High Fire Hazard Severity Zones (VHFHSZ). Cities and counties must update the safety element to address wildfire risks in these areas. • Flood Hazard Planning (AB 162 and related laws7): After Hurricane Katrina (2005) and California’s own levee concerns, the Legislature passed AB 162 (2007) and a suite of flood safety bills (SB 5, AB 70, etc.). These require local plans to address flood hazards with greater rigor.

Local Hazard Mitigation Plans
In parallel with state planning laws, federal law encourages each community to adopt a Local Hazard Mitigation Plan (LHMP) assessing risks and identifying projects to reduce them. California has strongly incentivized integrating the LHMP into the general plan. While not a direct mandate, this policy nudges local governments to proactively plan mitigation projects for wildfires, floods, earthquakes, etc., and embed those plans in general plan policy. Sonoma County’s local Hazard Mitigation Plan can be found online here8.

Evacuation Route Planning Statutes and Standards
One critical aspect of disaster preparation is planning how to get people out of harm’s way when a wildfire or flood emergency strikes. Recent California legislation has zeroed in on evacuation route planning, after several disasters revealed deadly shortcomings. The 2017 wine country fires and 2018 Camp Fire in Paradise, CA showed that communities with insufficient evacuation route planning led to chaotic evacuations. State lawmakers responded with new requirements to ensure local jurisdictions map out and evaluate evacuation routes in advance.

Even before these new laws, Government Code §653029 mandated that every safety element must address “evacuation routes related to identified fire and geologic hazards”. Considering evacuation 6 https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201120120SB1241 7 http://www.leginfo.ca.gov/pub/07-08/bill/asm/ab_0151-0200/ab_162_bill_20071010_chaptered.pdf 8 https://permitsonoma.org/hazard-mitigation 9 https://legiscan.com/CA/text/AB747/id/2056749#:~:text=certain%20mandatory%20elements%2C%20including%20a,identified%20f ire%20and%20geologic%20hazards
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needs in wildfire (and earthquake) scenarios has long been a part of general plan safety elements.

Subsequent statutes clarified the legal mandates as follows:

AB 747 (2019)–Evacuation Route Capacity, Safety, and Viability Analysis Assembly Bill 747 10(Levine, 2019) complements SB 99 by adding Government Code §65302.15, which focuses on qualitative analysis of evacuation routes. Under AB 747, the safety element must be reviewed and updated “as necessary to identify evacuation routes and their capacity, safety, and viability under a range of emergency scenarios.” In effect, this law requires a comprehensive evacuation analysis in local plans: not just mapping the routes but evaluating whether those roads can actually handle an evacuation and identifying potential problems.

Key facets of the AB 747 mandate: local governments should consider different emergency scenarios–for instance, a fast-moving wildfire on a windy day, or a major flood that cuts off certain roads–and for each scenario assess if the evacuation routes are viable. They must look at capacity (can the roads carry the volume of traffic needed to evacuate everyone? Might there be choke points?), safety (are the routes themselves safe from the hazard, e.g. will a wildfire likely overrun that road? are bridges seismically stable in a flood?), and viability (will the route remain usable, or could it be blocked by the hazard?).

Importantly, AB 747 allows that if a city or county already has done similar analysis in another document (like an Emergency Operations Plan or an LHMP), it can incorporate that by reference.

Some communities in California 11 have since conducted detailed evacuation modeling studies to comply with AB 747, using traffic simulation and GIS mapping to test different disaster scenarios.

SB 99 (2019)–Identifying At-Risk Developments with Single Access Senate Bill 99 12(Nielsen, 2019) was among the first bills to emerge from post-disaster scrutiny.

Effective in 2020, SB 99 requires each city and county to update the safety element to identify any residential developments in hazard areas that lack at least two evacuation routes. In plain terms, local planners must make a map or inventory of neighborhoods or communities that have only one road in and out in fire hazard zones or other high-risk areas. These could be mountain communities, canyon neighborhoods, or subdivisions at the end of long cul-de-sacs.

The law’s intent is to highlight these vulnerable areas so that local governments can then seek mitigation–for example, planning a secondary egress road, widening an existing road, or, at minimum, formulating special evacuation procedures for those communities. SB 99 requires jurisdictions to confront evacuation bottlenecks during the planning stage, rather than during the emergency itself. Notably, SB 99 came with an understanding that many existing communities have legacy road networks that are hard to change–but identifying them is a mandatory first step.

AB 1409 (2021)–Identifying Evacuation Locations
Building on the above, Assembly Bill 1409 13(Levine, 2021) added a further refinement: it requires that local governments must also identify evacuation locations. In other words, not only routes, but 10https://legiscan.com/CA/text/AB747/id/2056749#:~:text=This%20bill%2C%20upon%20the%20next,that%20information%20in%20 the%20safety
11https://www.watsonville.gov/DocumentCenter/View/15452/Appendix-D-Emergency-Evacuation-RouteAnalysis#:~:text=in%20accordance%20with%20AB%20747,D%20to%20the%20General%20Plan 12https://legiscan.com/CA/text/SB99/id/2051072
13https://legiscan.com/CA/text/AB1409/id/2435722#:~:text=a%20local%20hazard%20mitigation%20plan%2C,a%20range%20of%20 emergency%20scenarios
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the destinations or sites where evacuees can go (evacuation centers, shelters, temporary refuge areas) should be considered in the plan. Having multiple evacuation centers or refuge areas is especially crucial for wildfire evacuations, where evacuees might need to be directed to a safe zone if they cannot all leave the area quickly. Identifying these locations in advance–fairgrounds, schools, community centers, large parking lots, etc.–and evaluating their capacity is now part of the planning mandate. AB 1409’s addition ensures that local plans address the full spectrum of evacuation: from leaving the home (routes) to reaching safety (locations). As with the other bills, this imposes new duties on local planning officials but is considered a state-mandated local program in the interest of public safety.

In sum, California law requires every locality to identify its evacuation vulnerabilities and develop a plan to address them. This exemplifies the shift toward proactive disaster planning: hard lessons from recent wildfires have been translated into statutory duties for cities and counties to map, evaluate, and improve evacuation logistics for the safety of their residents.

Through AB 747, SB 99, and AB 1409 (all in the last 5 years), California has significantly tightened the expectations on local jurisdictions for evacuation preparedness. These laws were directly responsive to wildfire tragedies but apply broadly to any hazard that might require evacuation (floods, tsunamis on the coast, even industrial accidents). By writing these requirements into general plan law, the state ensures that evacuation planning isn’t just an operational afterthought but a core element of community development and public safety planning.

Statutes also require local governments to maintain up-to-date evacuation route maps in their general plans and show that they have thought through contingencies. Many counties have adopted formal “Evacuation Route Element” documents or incorporated extensive evacuation chapters in their safety elements to comply. This also dovetails with emergency response planning: an evacuation plan on paper is implemented through Evacuation Orders and Warnings during an incident, so having pre-designated routes and centers makes emergency alerts more effective.

Sonoma County Emergency Management
Emergency management in Sonoma County is led by the County Department of Emergency Management (DEM). The County maintains an Emergency Operations Plan14 (EOP) that follows NIMS/ICS principles. This EOP enumerates roles to local agencies–the Sheriff’s Office, fire districts, EMS, public health, public works, etc.–for disasters. An Emergency Operations Center 15(EOC) is activated during major events. The EOC serves as the central coordination hub: while onscene responders (police, firefighters) use ICS principles to fight the incident, the EOC collects information, requests resources, and helps manage the overall response. Regular first responders (firefighters, paramedics, police) use the standardized ICS structure for on-scene work and the EOC supports them with supplies, information, and logistics.

Sonoma County emergency management plans also involve external partners. Local chapters of the American Red Cross and other VOAD organizations prepare shelters and provide food, water and recovery assistance when needed. These groups have agreements to open emergency shelters along evacuation routes and to staff them with trained volunteers. Media coordination is in place:
public warnings are issued through multiple channels. The County has an automated text-message alert system for cell phones. It also uses NOAA Weather Radio broadcasts and outdoor sirens in 14https://sonomacounty.ca.gov/Main%20County%20Site/Administrative%20Support%20%26%20Fiscal%20Services/Emergency%20 Management/Documents/Plans/Sonoma-County-Emergency-Operations-Plan-English.pdf 15 https://sonomacounty.ca.gov/administrative-support-and-fiscal-services/emergency-management/organization/emergencyoperations-center Agenda Item Number: 19 Agenda Item Number: 19
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some areas. Social media (X (the entity formerly known as Twitter), Facebook) and a County emergency webpage provide updates. Multiple alert channels are important to reach different audiences.

DEM has some modern tools to support planning and response. Sonoma County has a capable GIS mapping department that has published an online evacuation zone map and could show the public evacuation routes and safe shelter locations once they are defined. Mobile apps help field units share real-time info with the EOC. Volunteer amateur radio teams stand by to assist if other communications fail. The County OES conducts training exercises to practice evacuations. However, constrained budgets and staffing mean large-scale drills are not frequent.

The Sonoma County Emergency Operations Plan (EOP) is the principal public-facing document that describes local preparedness for such emergencies; here's what the most recent version of the EOP says about its scope and substance:
“The EOP is intended to facilitate coordination between agencies and jurisdictions within Sonoma County while ensuring the protection of life, property, and the environment during disasters. In accordance with California’s Standardized Emergency Management System (SEMS), this Plan provides the framework for a coordinated effort between partners and provides stability and coordination during a disaster.

This EOP outlines the specific actions that the OA will carry out when an emergency exceeds or has the potential to exceed the capacity of a single agency or jurisdiction to respond. It sets forth the organizational framework and addresses steps needed to safeguard the whole community— especially those who are most at-risk, experience the most vulnerabilities, and/or have been historically underserved.”
In June of 2024, Permit Sonoma (the County agency charged with maintaining the County General Plan) conducted a Board of Supervisor workshop 16 to initiate the update of the Public Safety component of Sonoma County’s General Plan, including this reference to construction of the evacuation map mandated by state law. Here is the text of the proposed mapping process as described in the agenda materials:
“Evacuation-related assessments required by State law (Gov. Code §§ 65302(g)(1) and 65302.15) are still under development and expected to be available later this summer. These assessments will be high-level, data-oriented, and limited in scope. The assessments will be appended to the Safety Element as reference documents and may be used as informational tools for decision-making on evacuation related policy and program development at the Board’s discretion.

The assessments will provide limited information about areas of the County where evacuation conditions may be less efficient due to roadway conditions, such as the number of egress routes or roadway carrying capacity. The results of the assessments should be viewed as sources of information and not a complete picture of evacuation considerations within the county. The assessments will not provide a comprehensive status of evacuation accessibility for individual parcels in the unincorporated area nor specify the time it will take to evacuate any given area in any given emergency scenario.”
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In April of 2025, Permit Sonoma (in conjunction with DEM and Sonoma Public Infrastructure) issued an update to the evacuations annex of the Emergency Operations Plan.17 This General Plan update18 included many points of interest regarding evacuations. Goal SE2 of the update is titled “Support safe and efficient emergency response and evacuation through accessible and effective alerts, improved safety or evacuation routes, and emergency response planning.” Item SE-2J is also particularly significant and relevant to this report:
“Conduct a study to identify vulnerable areas for traffic signal improvements and contingency plans for loss of power and communications grids. Investigate adaptive signal control (ASC) systems that can adjust traffic signal timing to account for high volumes that occur during hazard events.” Sonoma County Department of Emergency Management is the responsible party; and this update isn’t currently expected to be completed until 2030.

Further, according to Goal SE2a of the update, DEM does not intend to fulfill the evacuation route mapping requirements established in AB747 until 2030.

Public Alert Systems for Community Awareness and Evacuation Coordination Rapidly notifying the public of impending danger is crucial for both wildfires and floods. After the 2017 firestorms, California passed SB 833 (2018)19 to push all counties toward modern, coordinated alert systems. Today, every county has an emergency mass notification system capable of pushing emergency messages to cell phones (via SMS text and Wireless Emergency Alerts), as well as to landline phones, email, and broadcast media.

The state OES has issued standardized Alert & Warning Guidelines to ensure consistent best practices–for instance, how quickly to issue alerts, using templates with clear language, and reaching vulnerable populations (including in multiple languages). SB 833 mandates that counties may not rely solely on opt-in systems and must also have the capability for opt-out alerts that otherwise reach everyone in an area. This was a direct response to Sonoma County’s experience 20 where many residents never got warnings because the system was opt-in. Now, wireless emergency alerts can be geo-targeted. For example, an evacuation order for a wildfire will trigger a loud notification on every compatible cell phone in the polygon of the evacuation zone, even if the user never signed up.

The County Sheriff is responsible for determining where and when evacuations will occur during declared emergencies. The county map has been divided into approximately 200 zones. During emergencies, the Sheriff announces which zone(s) are required to evacuate, with warnings to residents in nearby zones. The goal is to mitigate potential traffic congestion by prioritizing and phasing the addition of vehicles traveling on roads known to have limited capacity.

Communication tools are critical to the success of this approach to evacuation management: each household needs to know its designated evacuation zone and have access to at least one communication technology to receive status updates from the Sheriff.

The County uses a broad range of tools to (hopefully) ensure universal access to evacuation messages:
17https://sonomacounty.maps.arcgis.com/apps/webappviewer/index.html?id=69a0e54e9e2b48c086d122027b21c961 18https://permitsonoma.org/Microsites/Permit%20Sonoma/Documents/Long%20Range%20Plans/General%20Plan/Environmental%2 0Justice/Sonoma-County-Safety-Element-Public-Review-Draft-April-2025.pdf 19https://legiscan.com/CA/text/SB833/id/1820764 20https://www.govtech.com/public-safety/california-emergency-alert-standards-move-forward-inlegislature.html#:~:text=as%20radio%20and%20television Agenda Item Number: 19 Agenda Item Number: 19
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• SocoAlert is the County’s preferred method for broadcasting zone status and other emergency information since it can push messages and alerts to cellphones and other devices within specific zones rather than broadcasting unnecessarily to a larger region. SocoAlert uses a system named CodeRed, which is owned and operated by Onsolve, which in turn is operated by a company named Crisis24 which is a subsidiary of a conglomerate named Gardaworld.

For directed messaging to work via SocoAlerts one needs to provide information that includes their home address, phone numbers and emails after which one must agree to terms and conditions set by the CodeRed End User License Agreement. 21 • Nixle is owned and operated by Everbridge and informs residents about public safety messages, community events, and advisories. Like SocoAlert, Nixle broadcasts messages as SMS texts.

Nixle broadcasts to a zip code area so it is less specific to evacuation zones than SocoAlert. • NOAA Weather Radio (NWR) is a nationwide network of radio stations providing continuous broadcasts of weather information directly from the nearest National Weather Service office.

NWR broadcasts official weather warnings, watches, forecasts, and other hazard information 24 hours a day, seven days a week. It also serves as an "all-hazards" radio network, making it an essential source for comprehensive emergency information, including natural and environmental disasters, public safety alerts, and more. One must purchase a NOAA radio or a scanner which typically cost around $15-$30 to receive NOAA radio broadcasts. • Wireless Emergency Alerts (WEA) are emergency messages sent by authorized government alerting authorities through the local mobile carrier. They provide timely and critical information about a variety of imminent threats and emergencies, such as severe weather, public safety, and AMBER alerts. They typically appear as a text-like message on your mobile device, accompanied by a distinctive sound and vibration. One must have a cell phone to receive WEA messages.
• Emergency Alert System (EAS) is a national public warning system in the United States, designed to enable authorities to rapidly disseminate emergency information via multiple platforms including radio, television, and cable systems. Its primary purpose is to inform the public of urgent situations ranging from severe weather warnings to national security threats. • Hi-Lo Sirens: Patrol cars and public safety vehicles in the sheriff’s fleet are equipped with a specialized “Hi-Lo” siren which communicates an imminent emergency condition to all who hear it. Hi-Lo sirens are the last option to get the message out when all else fails, and do not require a device on the part of the resident. Per the Sonoma County Sheriff’s office website, if you hear the Hi-Lo siren “you are in immediate danger and must evacuate immediately”.

Other forms of emergency communications include:
• AM radios are the most ubiquitous method of receiving broadcast information. During the Tubbs fire AM radio became the only form of official information available to many of those directly impacted by the fire. KSRO, a Sonoma County radio station, played a crucial role in providing real-time emergency updates, evacuation notices, and critical information to residents.

As the fire spread, KSRO became a lifeline for the community, offering continuous coverage, helping thousands stay informed and safe during the crisis. 21 The Grand Jury reviewed the required terms and conditions and discovered that the user has to agree to allow the owners of the CodeRed system to use this information and share it as needed to provide the notification service. These conditions may discourage some households from choosing to register for potentially life-saving emergency alerts.

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• WatchDuty is a mobile application developed locally by Sonoma County resident John Mills.

The WatchDuty app keeps users informed about real-time fire incidents, integrating data from authorized sources such as fire departments, emergency services, and citizen reporters to provide timely alerts and updates. Users receive notifications about fire locations, containment efforts, road closures, and evacuation orders. The platform is a vital enhancement to community preparedness, a tool for both residents living in wildfire-prone regions and those interested in staying informed about fire-related emergencies. WatchDuty can be used for free and also has a paid subscription service. One must have a smartphone to use it, and that phone needs internet access to get WatchDuty updates.

All of the above forms of communications (except Hi-Lo sirens) require access to a cell phone and/or computer with an internet connection. But what does a household do when power is out, cell towers are down, and the public has lost access to the internet? Local grass roots organizations have created radio communications networks in the northern areas of the County and residents in the eastern and western parts of Sonoma County are actively trying to expand these organized communications networks to the entire county.

Grassroots Organizations - Key to County Emergency Prep and Response • CERT (Community Emergency Response Team) is a volunteer program that trains civilians in disaster preparedness, emergency response, and basic lifesaving skills. Sponsored by FEMA, CERT trains volunteers to assist their communities during natural disasters, fires, medical emergencies, and other crises when professional responders are overwhelmed. Members learn fire suppression, first aid, search and rescue, and disaster psychology, enabling them to provide crucial support before emergency services arrive.

There are two active CERT training hubs in Sonoma County, one organized by the Sonoma County Department of Emergency Management and the other instituted by Sonoma County fire and emergency services personnel. The Northern Sonoma County CERT organization has also been collaborating with the North Bay Communications Collective in training volunteers to use low-cost hand-held radio devices.
• The North Bay Communications Collective (NBCC) is a volunteer organization dedicated to providing reliable, community-based emergency communication throughout the North Bay region. Using ham radio, GMRS radios and other communication technologies, the Collective supports disaster response efforts by maintaining alternative communication networks when traditional systems fail, such as during wildfires or power outages. Their mission is to enhance disaster resilience by training volunteers and expanding emergency communication infrastructure.
• General Mobile Radio Service (GMRS) radio networks have been rapidly expanding in North and West Sonoma County. When power failures take down internet and cell phone service, this communication network can still be available because of county-operated GMRS repeater towers with onsite backup power.

The North Bay Communication Coalition is a key contributor to the distribution of GMRS radios to neighborhood groups who operate together as a neighborhood "net". NBCC provides GMRS radio training and provides users scripts based on HAM radio operator protocols compliant with FCC regulations.
• The Auxiliary Communications Service (ACS) in Sonoma County is a volunteer-based emergency communications program that supports county emergency operations. ACS provides Agenda Item Number: 19 Agenda Item Number: 19
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backup and supplemental radio communications for government agencies during disasters, ensuring reliable communication when conventional systems fail. The service plays a critical role in disaster preparedness and response by maintaining communication links between emergency responders, shelters, and other essential services.

The Civil Grand Jury has three observations related to county evacuation communications using GMRS and ACS:

1. ACS is not yet linked to all Neighborhood Nets and integrated in a formal and consistent manner into EOC operations.

2. GMRS radio network participants are not required or taught to use formal communication protocols (like the ones used by Ham radio operators). People can talk over each other or use the channel inappropriately without a structured approach to using these devices, potentially limiting channel usefulness.

3. Trained users of GMRS within a neighborhood net could provide traffic status through ACS to the EOC so that evacuation route information can be disseminated to the public. In all emergency evacuations, residents may find that the 911 system is overloaded. Trained GMRS radio users in a neighborhood net could also provide real time vital information regarding evacuation routes and rapidly changing fire/flood conditions, and direct emergency responders to residents in need of special assistance.

Technology to Support Wildfire and Flood Preparation & Coordination California’s laws don’t prescribe specific disaster preparedness technologies, but in practice state and local authorities have widely adopted advanced tools to meet legal mandates and improve emergency outcomes. Here are some key categories of technology that support wildfire and flood preparation and response coordination:
• Geographic Information Systems (GIS) and Hazard Mapping: GIS is foundational for hazard planning and situational awareness. Local agencies use GIS to map fire hazard zones, floodplains, evacuation routes, and critical infrastructure. During emergencies, GIS specialists from various agencies create real-time interactive maps showing wildfire perimeters, evacuation zones, and other critical data. CAL FIRE and Sonoma County Department of Emergency Management use Esri’s ArcGIS platform to maintain online “dashboard” maps22 of active incidents and evacuation orders, accessible to both responders and the public. In flood preparedness, GIS is used to model inundation areas and plan evacuation zones accordingly.

Many counties have produced story maps that combine flood scenarios with evacuation route overlays to educate residents. Sonoma County’s flood stage map can be found here23.

Overall, GIS tools fulfill a critical requirement of state law: they provide the evidence-based foundation that underpins evacuation plans. Sonoma County’s DEM maintains interactivelyupdated maps24 for winter weather, road closures, flood stages, and a “Five Year Burn Scar” map, along with a map showing all of the County evacuation zones. • Evacuation Management Platforms: Many California counties have turned to specialized evacuation management software to implement evacuation route planning mandates. One example is Zonehaven (now part of Genasys Protect), a platform that allows agencies to define 22 https://socoemergency-sonomacounty.hub.arcgis.com/apps/69a0e54e9e2b48c086d122027b21c961 23 https://sonomacounty.maps.arcgis.com/apps/webappviewer/index.html?id=b78edb375de6457f97869703bd368f35 24 https://socoemergency.org/emergency/maps/ Agenda Item Number: 19 Agenda Item Number: 19
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precise evacuation zones and run simulations of evacuation traffic25. Zonehaven provides a common operating picture for multi-agency coordination of evacuations. It offers access to “real-time weather, traffic and fire information, and models traffic and fire spread scenarios to plan and execute evacuations successfully”.

Using such tools, emergency managers can predict how quickly a wildfire might spread toward a community and how traffic would flow if everyone evacuated at once, enabling managers to designate phased evacuations or choose which areas to evacuate versus shelter in place. For example, Marin County implemented Zonehaven and highlighted that the tool can model potential traffic congestion26 during a wildfire evacuation and identify problem areas. When a wildfire ignites, the County can activate pre-drawn zones on Zonehaven’s map, and the public can see their zone status on a live map. Other tech solutions in this category include One Concern, which has offered AI-driven evacuation analytics (piloted by some California cities), and Google’s Waze Crisis Response partnership that shares road closure and traffic data with emergency ops centers.
• Monitoring Networks and Early Warning Sensors: Cutting-edge monitoring technology is improving early detection of wildfires and floods. ALERTCalifornia is a flagship effort: this advanced network of more than 1,000 cameras helps emergency managers monitor wildfires, floods, and landslides in real time. The cameras providing 360-degree live views that firefighters and emergency personnel can control remotely. Camera feeds have also been used to watch river levels and burn scar areas during heavy storms.
• Automated Weather Stations and Remote Sensors: Wind, humidity, and fuel moisture sensors are used in many areas, feeding data to prediction models like FIRIS (Fire Integrated Real-Time Intelligence System) and WIFIRE. FIRIS is a state-funded program that pairs infrared-equipped aircraft with a data platform to map fires and run spread projections within minutes of ignition.

WIFIRE uses supercomputers to model wildfire growth and was referenced in recent fires for rapid scenario planning. On the flood side, California has thousands of stream gauges and rain gauges that send real-time data to flood control agencies. These trigger alerts when river levels reach thresholds, enabling towns downstream to be warned or evacuated early. • Data and Communication Platforms: In emergency operations centers, technology like WebEOC (incident management software) is used to track resources and missions during a disaster. California has also developed SCOUT, a geospatial viewer that integrates data sources (fire perimeters, weather, traffic, shelter status, etc.) on one map for situational awareness.

DISCUSSION
The Civil Grand Jury identified several practical concerns regarding Sonoma County’s evacuation capability and opportunities for improvement of county-wide evacuation planning and implementation.

Evacuation Planning Constraints & Potential Mitigations Do you know where the next wildfire will be?
25 https://genasys.com/press-releases/genasys-inc-announces-zonehaven-launch-in-alameda-countyca/#:~:text=%E2%80%9COur%20Zonehaven%20SaaS%20solutions%20provide,%E2%80%9D 26 https://www.marincounty.gov/news-releases/new-evacuation-mapping-tool-unveiled-marincounty#:~:text=%E2%80%9CThe%20Zonehaven%20mapping%20tool%20allows,model%20traffic%20and%20fire Agenda Item Number: 19 Agenda Item Number: 19
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No, of course not; and that’s why local emergency planners say they haven’t developed detailed, zone-specific residential evacuation plans for wildfire or flood emergencies. Each of the major fires in Sonoma County has impacted different neighborhoods, and the people responsible for preparation in advance of the next emergency are quick to note that “maximum flexibility” in evacuation management is an absolute requirement.

But… there are some important things we know will impact the outcome of the next emergency:
• The roads we have today will be the roads available during the next evacuation until remedial action is taken.
• Many Sonoma County roads aren’t wide enough to support simultaneous resident evacuation and emergency vehicle ingress.
• Traffic jams happen at the same points over and over: the intersection of Petaluma Hill Road and Adobe Road, Route 12 at Farmer’s Lane, Westside Road at the Healdsburg circle, the entire Sebastopol downtown, and numerous other locations throughout the County. One common feature: all of these pinch points are along critical evacuation routes. • The areas that flood next are likely to be areas that have flooded previously. • Fires accelerate through canyons based on prevailing wind patterns, and these wind patterns are well known to weather analysts.
• Every residence in the County is already mapped in the County GIS system, and though the residential census at any moment in time is fluid, it could be known in real time if emergency planners had tools to query public status as the emergency unfolds. • There are only a handful of places that are sizeable enough for, and prepared to be, evacuation destinations.

Sonoma County emergency planning agencies should recognize the benefit of advance planning:
after all, this County probably has more experience with wildfire and flooding disasters than any other county in California. During Civil Grand Jury interviews, local officials repeatedly said, “We can’t make an evacuation plan in advance because we don’t know where the next emergency is going to be.” However, while emergency planners cannot predict the exact location of the next evacuation, they can identify in advance the specific obstacles likely to arise within each evacuation zone.

State law says that emergency operations plans must include detailed zone evacuation maps that reflect specific evacuation routes and shelter destinations for each likely emergency. State law says, and our research concludes, that advance preparation is not only possible but preferred. The City of Santa Rosa has actually already done this: its Emergency Operations Plan includes specific traffic management plans including remote traffic light controls, assignment of on-site traffic management personnel, and specific shelter destinations with permanent designation signage. In contrast, Sonoma County’s EOP is essentially ad hoc: the plan and practice (according to the entities in charge of emergency management) is to figure it out on the fly, depending on what the emergency is and how it seems likely to progress.

There are only a handful of options for getting out of Sonoma Valley between Middle Rincon Road and the City of Sonoma. Significant portions of State Route 12, the main highway, are single lanes in each direction, and administration of this highway vests with the State of California. The canyons crossing Highway 12 principally run east and west, so the most dangerous fire storms in the eastern Agenda Item Number: 19 Agenda Item Number: 19
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part of the County run perpendicular to this main evacuation route—leaving some room for safe zones between blazes. There are places along Highway 12 in the Sonoma Valley where temporary evacuation points could be used to mitigate the risk of an overcrowded road but, to date, none have been identified.

The western half of the County is not so fortunate: the main evacuation routes (West Side Road, Occidental Road, Highway 12 and Highway 116) all run roughly parallel to the predominant wind directions during fire season, and there are few places in the most dangerous areas where temporary evacuation points or traffic management buffers could be established.

Lessons from Recent Incidents
After-action reviews provide insight. The 2019 Kincade fire prompted one of the largest mass evacuations in the history of California. One crucial lesson: widespread power outages of the sort initiated by PG&E during this fire mean crucial communications infrastructure may not work—so advance preparation of evacuation routes and alternate communications plans are an absolute necessity.

The 2020 Glass fire, which burned across both Napa and Sonoma counties, resulted in the loss of almost 1,500 structures. The Glass fire's rapid progression underscored the necessity of defensible space around properties and the use of fire-resistant building materials.

Sonoma County has faced significant flooding in each of the past three heavy rainfall seasons. These events have highlighted the importance of comprehensive flood risk management, including the development of detailed floodplain maps, investment in infrastructure improvements, and community education on evacuation procedures. The County has worked to align its flood response strategies with lessons learned from wildfire evacuations, emphasizing the need for clear communication and accessible evacuation routes.

Evacuations during the 2024 flooding near Lake Sonoma were substantially impacted by cell tower outages and many evacuees had no updated route guidance. This points to the need for alternative notification (such as emergency radio broadcasts or amateur radio volunteers to relay new info) and advance distribution of evacuation route maps.

Communication Channels and Infrastructure Limitations
Sonoma County uses a variety of alert systems (NOAA radio, WEA cell alerts, social media, local news, and sirens) and has greatly improved its communications capabilities since 2017. However, a persistent problem is that some rural residents may be out of reach of certain channels. Rural and forest area residents won’t get alerts if the signal is weak. To compensate, Sonoma County uses outdoor sirens and roadway message signs as backups but these technologies have limited reach and effectiveness.

Messages sent via SocoAlert and Nixle use SMS texting which operates through cellular services and by internet connection via wifi. Both forms of messaging are limited to 160 characters. The Civil Grand Jury has found that the emergency messages can include additional access to more detailed information by adding a URL at the end of the message. However, this assumes that the user will take the time to look, and it also assumes that an internet connection is available to the device the user is operating.

Radios are the only communication technology that has a reasonable chance of working for many people in the rural parts of the County when power lines are down, or internet connections aren’t available. Going forward, Sonoma County could do more to support neighborhood safety networks:

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for example, appointing volunteer block captains or enhancing community organizations’ capabilities to spread warnings door-to-door and by radio. In past evacuations, neighbors often warned each other, which shows the value of grassroots communication. Having more people connected to emergency messaging networks will improve the odds that messages get through even if cell phones or internet fail.

Inter-Agency Coordination is a Challenge
In theory, Sonoma County uses the Incident Command System, but resource limits can hamper response. The County’s fire districts and EMS have far fewer personnel and trucks than a big-city department. In a fast-moving disaster, small volunteer crews might be stretched thin. The Civil Grand Jury found that clarifying roles ahead of time is important. The Sheriff’s Office will take command of issuing evacuation orders during a large wildfire, but the Emergency Operations Center will remain in control of communications management among all of the various emergency responders.

Infrastructure Vulnerabilities
Sonoma County’s main evacuation routes have been, and probably will continue to be, bottlenecks for future evacuations. Highway 12 and Highway 116 each have major intersections known to gridlock during heavy traffic. Even Highway 101 has been seen to shut down due to evacuation traffic exacerbated by wildfire adjacent to the highway. If flooding or landslides close a highway, evacuees could face life-threatening delays. Sonoma County plans note alternate routes, but these often involve longer, winding backroads. One strategy is contraflow (reversing lanes to double outbound flow) on key highways, but that takes pre-planning and traffic control. It also helps to have at least 3 lanes for major evacuation routes: that allows for outbound traffic to have two egress lanes, leaving one ingress lane for emergency responders.

Modeling Future Evacuations: Technology Exists to Improve Wildfire and Flood Preparation
Disaster preparedness agencies elsewhere in the state have adopted advanced tools to improve emergency outcomes. More comprehensive GIS mapping of hazards is supported by advanced simulation technology to enhance disaster preparation. The state often provides funding or frameworks for these technologies, but local agencies choose and operate the specific tools. The technologies are the means to an end: compliance with statutory requirements (like advance evacuation route planning) and the ultimate goal of saving lives and property when wildfires rage or floods rise.

Unfortunately, there has been little investment locally in the types of tools that could put an informed evacuation plan in place before the next emergency. The Sonoma County Department of Emergency Management has literally no advanced tools to conduct the specific evacuation route planning mandated by AB 747. Without simulation applications, it’s an impossible task: calculating wildfire risk for the County’s many canyons is a function of fuel, wind speed and direction, and every atmospheric river has the potential to unexpectedly deliver massive amounts of water to very specific flood zones, but without tools that incorporate NOAA and CAL OES weather data to simulate likely problems, and traffic modeling tools that estimate congestion based on evacuation traffic volume, there is no way for Sonoma County’s Department of Emergency Management to develop the detailed plans that would allow each neighborhood to know what its options are or when to initiate its best-case scenarios for public safety.

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The good news is that these tools exist. They aren’t cheap, and implementation would require both funding and expertise; but other counties have adopted them, and local funding sources (like 2024 Measure H) can make these tools available to all city and county emergency planners and the residents they protect.

Questions from the Floor
Public interest in (and questions about) emergency management is heightened during and after every evacuation emergency. The same questions keep being asked—and not answered:
• Why are most of the major evacuation routes in Sonoma County two-lane roads with inadequate capacity for major traffic events? Is anyone actively working to fix this problem? • Does Sonoma County have the most effective tools and technologies to assist emergency responders and residents during an evacuation-level emergency? The Civil Grand Jury asked senior County leaders to answer these questions, and the responses were somewhat disappointing. In short:
• The roads are the roads; improving them is expensive, complicated, and, in most cases, requires support from the State of California, and
• We would love to have tools to create scenario-specific evacuation plans, but they’re not in the budget.

It is disheartening to hear that there is no immediate effort to imagine comprehensive roadway solutions. How much money would it take? How long would our major evacuation routes take to fix if the money was at hand? Do we even know how many miles of highway enhancement construction are needed? If Highway 12 and 116, and major county routes like Westside Road and Dry Creek Road need significant public safety improvements, where do these enhancements fit in the long list of budget priorities?
According to the General Plan update published in April, they’re far down the list: Goal SE5 (a study to identify County transportation infrastructure critical for provision of emergency services such as evacuation or provide access to critical facilities located within high-risk wildfire, landslide, or flood hazard areas) isn’t scheduled to be started until 2030. In the meantime, should we all just hope there are no emergencies?
It is equally disappointing to learn that compliance with AB747 and other state mandates to develop and communicate zone-specific emergency evacuation plans are 2030 goals. Provision of critical services in highly impacted, systemically vulnerable communities during an emergency deserves a higher priority.

CONCLUSIONS
Sonoma County has the beginnings of a solid framework for evacuations: a written Emergency Operations Plan, an active Emergency Operations Center for coordination, multi-channel public alert systems, and a robust community of residents who recognize both the need for preparedness and the value of planning for emergencies. Collaboration with voluntary agencies provides organized shelter and aid during disasters. These foundations mean the County does not have to start from scratch during a crisis.

However, our analysis identifies areas needing attention. Communications stand out: evacuation orders and warnings must be localized, dynamic and include immediate instructions for specific Agenda Item Number: 19 Agenda Item Number: 19
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areas. The research evidence is clear that plain, specific alerts (especially mandatory orders when needed) save lives. Sonoma County emergency communications networks should be both hardened and capable of reaching everywhere in the county, whether through improvements in physical capacity or support for community organizations that can reach places with radio networks when cell service isn’t available.

Infrastructure and logistics are another focus. Limitations of the existing road network means contingency planning in advance is key to public safety. Funding to reinforce key bridges, install more emergency power generators at critical communications sites (to prevent cell tower failures), or add redundancy (like more river gauges and weather sensors) would increase resilience. The most impactful and consequential fact impacting evacuations is the inadequacy of the roads required for emergency evacuations. Highway 12 in the Sonoma Valley, Westside Road between Healdsburg and the Russian River, and River Road along the Russian River are the most obvious examples of roads that are critical for emergency evacuation, yet they are single lane each way, with some area having minimal shoulders and turn-outs. Upgrading these roads will reduce the likelihood of significant traffic problems during the next emergency evacuation.

Inadequate response to legal mandates for preparedness: California’s legal landscape for disaster and emergency management creates a comprehensive, multi-layered system with local authorities at its core. Statutes charge cities and counties with developing robust emergency plans, integrating wildfire and flood considerations into every facet of community planning, and continually updating those plans to reflect new risks and knowledge. The Legislature has reinforced these duties through targeted laws on evacuation planning, alerting standards, and climate resilience.

California’s state-local partnership strives to ensure that whether it’s a wildfire in the hills or a flood in the valleys, local authorities are prepared to lead a swift, organized, and life-saving response.

California has learned from hard experience that accountability for disaster readiness is clear: the state sets standards and provides support, but the operational responsibility lies with the local governments who know their communities best.

While the framework in place provides a strong foundation to safeguard County residents from the perils of wildfires and floods, Sonoma County’s approach to date is long on physical preparedness but short on anticipation. To date, Sonoma County has fallen short of state mandates for preparation of (and communication to residents about) advance preparation of evacuation routes and traffic management systems, identification of (and advance planning for) evacuation via roads that are challenges for emergency services access, and investment in technology that would enable the Department of Emergency Management to develop the detailed analysis needed to facilitate unified command and control during the next major evacuation.

Sonoma County local governments must not only respond to disasters but prepare in advance by mapping every flood zone and fire hazard and hardening infrastructure and development patterns against these threats. Readiness is not static. By sharpening communication protocols, shoring up critical infrastructure, fully utilizing analytic modeling technology and engaging citizens in preparedness, the County can move closer to being truly ready for the next major evacuation event.

And one is coming.

FINDINGS
The Sonoma County Civil Grand Jury determined that:

F1. Sonoma County’s Emergency Operations Plan, Hazard Mitigation Plan, and Department of Emergency Management are an excellent foundation for disaster preparation.

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