Goose Hill RV Park Comment Letter

Amador County has started the environmental review for the Goose Hill RV park. Here is the Conservancy’s comment letter on the project.

2/29/2024

Chuck Beatty

Planning Director

Amador County Planning 

 

Mr. Beatty,

The Foothill Conservancy makes the following requests for issues and content to be included in the DEIR pursuant to the Goose Hill RV Park (Applications Z-19, GPA-19, UP-19) scoping session for the project’s upcoming environmental review.

Our primary concern we want addressed in the DEIR for the proposed action is the identification, disclosure, and full mitigation of impacts of the proposed project to the Jackson Creek watershed, its riparian and aquatic habitat and its exposure to erosion and sedimentation impacts. Streambed alteration, earth moving, road building, and other project activities in proximity to maximum high water floodplain of Jackson Creek need to be avoided or fully mitigated in compliance with all local, State and Federal regulations and best engineering and management proactive. These concerns extend also to the impacts of the SMARA-regulated surface mining project that the applicant once operated on the site. This should be covered in the Existing Environment section of the DEIR that should be prepared, and full mitigation of impacts should be included as required mitigation of the proposed project in the DEIR. 

With respect to the mining operation on the Goose Hill site, the project application and project description describe the site being closed down, yet the Reclamation Plan closure requirements have not been implemented as required by SMARA. 

If the mining operation is still active and the Reclamation requirements not implemented, it will expose the residents of the proposed RV Park to a number of hazards and environmental impacts that need to be disclosed and mitigated under CEQA. Continuing operation would expose the RV residents to loud noises and vibrations from mining equipment and operations, as well as possible air pollution exposure from particulates, toxins and heavy metals. An RV Park and its associated recreation facilities is likely to attract sensitive receptors such as young children and the elderly. 

An unreclaimed mining site, where heavy mining equipment and piles of waste material are still present is likely to attract the attention of children staying adjacent to the RV Park, presents an obvious safety risk. Under the Amador County Code, a use permit cannot be issued if the public’s health and safety can not be ensured. 

If the RV Park is allowed to proceed without the site being fully reclaimed, the result will be a number of potential impacts under CEQA, including erosion and sedimentation, ground and surface water pollution. These in turn, could lead to habitat destruction for fish and other wildlife.

So as to avoid these conflicts and environmental impacts, we recommend that as both a mitigation measure and condition of approval, no permit be issued for work on the RV park until the SMARA permit reclamation process is completed in full.

In addition to the mining operations concerns, the Foothill Conservancy would also like to highlight the following issues to be addressed in the EIR document:

The project lies in the 100-year flood plain. People living in the RVs and using the rest of the proposed facility will need to be protected from flooding and contaminants from the RV Park should be prevented from flowing into Jackson Creek during flood episodes. 

The plan calls for an onsite wastewater treatment plant. Measures must be taken for the plant will not affect water quality in the nearby stream including potential overflow pollution in the event the treatment plant is subject to flood waters. Additional information on the design and construction of the water facility is needed.

The site should be surveyed for endangered species, such as tiger salamander, red-legged frog, and rare plants.

Thank you for your time and consideration,

 

Craig Baracco

Executive Director

Foothill Conservancy

Add Impact To Your Inbox

Get our emails to stay in the know
Scroll to Top

Sign up for notifications

Leslie Smith, Sutter Creek, CA: Raised in Washington State, Leslie is a happy California transplant having moved to Sunny Sutter Creek full time in 2020. As a nascent fly fisher and lifelong skier, she is committed to the natural environment and brings extensive organizational and finance experience to the board from a nearly 40 year career in banking.