Amador County Planning Department Chuck Beatty, Planning Director Mr. Beatty, Having reviewed the application to the County for the proposed Putnam Ranch development, also known as Tentative Subdivision Map No. 186 and General Plan Amendment-22, the Foothill Conservancy makes the following requests regarding its upcoming environmental review, high-lighting potential areas of concern and requesting that a General Plan consistent alternative be fully analyzed in the Environmental Impact Report (EIR). Our review of the proposed project reveals that it conflicts with a number of Amador County General Plan’s policies and goals. We have detailed those conflicts, which include development location, groundwater and circulation, and adequacy of services in an attachment to this letter. The DEIR should disclose and evaluate potential impacts of approving the project in spite of these conflicts, such as increased demand on emergency services, increasing their costs, reducing response times and thus affecting public safety. This project is also subject to provisions of the Amador County Zone Code Chapter 19.50 Design Standards And Findings, which we also detail in the attachment, including farmland conversion and impact to biological resources. In reviewing the initial study included in the project materials, we support the County staff on their identification of potentially significant environmental impacts of the project. We request that the the following potentially significant additional environmental concerns be analyzed in the DEIR: Chapter 10 b) The project is occurring in an area that faces particular difficulties with regard to groundwater supplies. Earlier this year, the Amador County Board of Supervisors voted down on a unanimous vote the proposed Allswell Ranch Estates subdivision, located just a mile south of the proposed Putnam Ranch, due to the impact of the six-lot development on existing home’s wells. The adjacent city of Plymouth faced major supply issues for its City-run groundwater wells, including a decades-long building moratorium, before switching away from groundwater entirely. The DEIR should disclose results of studies that demonstrate if sufficient groundwater is available to support the development proposed, and what impact such groundwater withdrawal would have on existing wells in the area. The DEIR should disclose how addition of 53 new private wells and the coverage of many acres with impermeable surface due to roads, buildings and driveways will impact groundwater recharge. Chapter 11 b) Despite being immediately adjacent to the City of Plymouth and its water system, the project apparently choses to not connect to city services. . Since there are no geographical or physical obstacles to connecting to city service, an alternative that does connect to those existing services should be analyzed. Chapter 14 a) Not only does the project add population in an area it was not planned for, the type of housing proposed, single-family homes on large ranchette-style lots, ensures none of the development will help meet the County’s goals of providing housing for moderate or low income levels as outlined in the General Plan Housing Element. Chapter 17 d) The proposed subdivision’s only road connection to the outside world in normal conditions is a gated road at the Highway 49-Highway 16 intersection. This provides only a single evacuation route in a development that will lie on the wildland-urban interface for the foreseeable future. While the project does include a secondary access point for emergencies, it is just a few hundred feet from the main entrance and also relies on Highway 16 for access. As a result, the highway remains a single point of failure in the event of a wildfire that approaches from the south or the west. There is no route to evacuate the subdivision to the north or east, and no way for emergency responders to enter from those directions, despite the nearest fire station being located in the City of Plymouth to the north. By limiting all traffic through the Highway 49/16 intersection, the development will add traffic impacts to an important intersection These are a significant adverse impact on public safety in need of mitigation in the DEIR. Project Alternative Consistent with General Plan Pursuant to CEQA requirements that lead agencies evaluate reasonable alternatives to the proposed action, we request that the following General Plan Consistent Alternative project alternative be included and evaluated in the DEIR. Under this alternative, the approximately 80 acres with the existing higher density Rural Residential General Plan designation would be annexed to the City of Plymouth and connected fully to the array of City services available, including water supply, sewer treatment, fire and police services, and road and trail network. Paying City taxes would help fund Plymouth fire house improvements and increasing Sheriff contract costs as the new residents would rely on these services. The remainder of the 453 acres could be designated Agricultural General for land use, and either remain as rangeland or be put to other productive agricultural uses. This alternative could provide the same 53 homes while reducing impacts to groundwater and local agriculture, increase public safety through additional road connections and fire hydrant service, provide tax revenue to Plymouth so emergency service providers can afford to maintain safe levels of fire, police and health emergency service, improve circulation and reduce traffic impacts to the highway 16/49 intersection, and comply with the policy and goals of the General Plan on building in existing urban areas, increasing connections within communities and ensuring proper provision of water and emergency services. We request that this reasonable alternative be given a detailed analysis and its impacts in all categories compared with the proposed action so the level of impact of both alternatives can be disclosed and inform decision makers. Thank you for time and consideration Craig Baracco Executive Director Foothill Conservancy