CORP Comments and Recommendations
with respect to the May 1999
Draft Outdoor Recreation Plan

CORP has prepared the following white paper commenting on the Draft ORP dated May 22, 1999. This white paper is being presented to county supervisors, the press, and other interested parties.


Board of Supervisors
575 Administration Dr.
Santa Rosa, CA 95403

Gentlemen of the Board of Supervisors:

The Coalition for the Outdoor Recreation Plan is an alliance of the county's major outdoor recreation, hiking, riding, trail and conservation organizations, with a combined membership in excess of 15,000 households. Throughout the Outdoor Recreation Plan process, CORP has been the primary voice on behalf of the public's strongly expressed desire for outdoor recreation opportunities. Our mission is "To advocate for an extensive, diverse and sensible system of trails throughout Sonoma County."

The majority of Sonoma County's cities have expressed support for CORP's efforts on behalf of trails, natural parklands, and open space access. Several of these resolutions are attached to this document.

Enclosed are CORP's comments and recommendations on the draft ORP as presented to you by the Citizens' Advisory Committee. These materials are divided into three broad areas:

We are concerned that trails which have been identified by the public in workshops as the county's most desirable alignments have been left off the draft plan, and that proposed trails policies are likely to have the effect of preventing actual acquisition and development of trails. Clearly, this would be counterproductive to the expressed intent of the plan. Policies should facilitate, rather than discourage development of trails.

We appreciate the Board's consideration of these comments and recommendations, and welcome questions regarding our proposed changes to the draft.

Cordially,

Coalition for the Outdoor Recreation Plan

Map of trail locations in the August 1998 Draft Outdoor Recreation Plan, plus CORP's proposed additions to that map. The maps (280 KB) are in Adobe .PDF format; to download the free Acrobat reader from the Adobe website, click here:

CORP Comments on Outdoor Recreation Plan
Recommended Policies

Our review of Section VI, "Recommended Policies," of the May 27, 1999 draft of the Outdoor Recreation Plan led us to the following comments and suggestions.

Current language:

Policy 1.3b: Where a trail alignment is not predetermined by a relationship to established publicly owned corridors such as abandoned railroad rights-of-way, flood control channels, or similar facilities, the Board of Supervisors may direct the preparation of a study or plan for the trail, taking into account, costs, a preliminary environmental assessment and any other factors it deems relevant to alignment and feasibility.

Issue/Concern:

This policy could slow or stop implementation of trails due to limited resources (staffing or budget) of the County to prepare a study or plan even though the proposed trail route already exists, but isn't in a publicly owned corridor.

Suggested Revision:

Policy 1.3b: Where a trail alignment is not predetermined by a relationship to existing or historical trail routes, established publicly owned corridors such as abandoned railroad rights-of-way, flood control channels, or similar facilities, the Board of Supervisors may direct the preparation of a study or plan for the trail, taking into account, costs, a preliminary environmental assessment and any other factors it deems relevant to alignment and feasibility.


Current language:

Policy 1.4: The Outdoor Recreation Plan Map . . .

iii) Consider requiring dedication in-fee or by easement for trails as a condition of approval of subdivisions. There must be a need identified on the Outdoor Recreation Plan Map or the project must block an existing access or result in the need for additional recreational opportunities. Locate and fence trails to minimize impacts on agricultural uses.

Issue/Concern:

1) The policy language "...a need identified on the Outdoor Recreation Plan Map..." emphasizes the importance of having a complete trail system illustrated on the ORP Map as well as adding a policy that allows opportunities to add trails when unanticipated opportunities arise.

2) The sentence "Locate and fence trails to minimize impacts on agricultural."

This sentence is (a) not related to the Objective 1.4 or Policy 1.4, (b) sets forth a specific and expensive trail implementation condition, (c) could actually be a negative impact on agricultural operations, (e.g., Bolinas Ridge, where trail fencing could restrict effective grazing patterns), and (d) is already covered under policy 2.1a, using more appropriate language.

Suggested revisions:

1) Add the trails identified in CORP's submittal, 2) add a policy to address the ability to take advantage of unexpected trail opportunities, and 3) strike the last sentence.


Current language:

Policy 2.1b: Prior to developing any new trail route for public use, prepare design and management plans that ensure provision of services necessary to provide for the safety and support of trail users and affected landowners.

Policy 2.1c: Develop design guidelines to ensure trails meet established safety standards and minimize user conflicts. Prior to developing new trail routes for public use, ensure that services and improvements necessary for safety and support of the public using the trail are provided. Such services and improvements should contain, at a minimum, adequate parking and sanitary facilities. Reasonable police and fire protection will be available.

Issues/Concern:

These policies could easily be used to stop implementation of trails by requiring these services and improvements be established when they may be met or addressed in other more cost-effective ways. These issues should be considered but not necessarily required. Reference other local agencies (MROSD, MCOSD, EBRP), that address these issues on a case by case (trail by trail) approach.

Suggested Revision:

Policy 2.1b: Develop design guidelines for trails to address safety issues and minimize user conflicts. Prior to developing any new trail route for public use, consider design and management issues to ensure provision of an appropriate level of service necessary to provide for the safety and support of trail users and affected landowners. Design and management issues to be considered include, at a minimum, police and fire protection.


Current language:

Policy 3.2: Properties acquired in-fee by the County or other agency for outdoor recreation may be land-banked and not open to public use until the park and recreation departments develop master plans and resource management plans pursuant to the California Environmental Quality Act and secure funding for development and operation and maintenance of the properties.

Issue/Concern:

This policy should be more flexible in allowing some public use while plans are being prepared.

Suggested Revision:

Policy 3.2: Properties acquired in-fee by the County or other agency for outdoor recreation may be land-banked and limit public use until the park and recreation departments develop master plans and resource management plans pursuant to the California Environmental Quality Act and secure funding for development and operation and maintenance of the properties.

CORP Comments on Proposed Parks
in the Draft Outdoor Recreation Plan

In our review of proposed parks and park policy in the May 27, 1999 draft of the Outdoor Recreation Plan, CORP found both good points and serious deficiencies, as described below.

Praise

CORP is encouraged by the following aspects of this draft ORP, as compared to earlier county planning documents.

  1. The older classification of "regional park" has been split in two. Highly developed parks, called "regional recreation areas (active)" are now properly differentiated from larger, natural parklands left undeveloped except for trail-oriented access, now called "regional open space (passive)."
  1. The current draft recognizes and clearly documents the public's overwhelming preference for new Regional Open Space (passive) parklands and associated trail-oriented activities. This preference is consistently demonstrated in surveys and workshops county-wide, and is aligned with statewide trends also documented in the draft. Encouragingly, the latest revision of the Draft ORP (printed 6/18/99) states unequivocally on page 56 that "Sonoma County Regional Parks Department's primary focus is to provide Regional Open Space Areas (Passive)."
  1. To be successful, trail-oriented recreation requires large, interconnected parcels, whereas currently our regional parks are small (only Shiloh and Hood Mountain surpass 300 acres) and unconnected to one another. The draft ORP makes some steps in the right direction, expanding some existing parks and proposing a few large new ones (e.g., a Taylor Mountain Park at 1000+ acres). In conjunction with the proposed county-wide trail system connecting them, these larger parks can begin to support a successful multi-use trail system in Sonoma County.
  1. The draft ORP took pains to address and research many of the concerns, including fire danger and trespassing, frequently voiced by prospective park and trail neighbors, particularly agriculturists. Ample documentation is provided showing that these concerns are unsupported by available evidence.

Concerns

CORP found the following serious shortcomings in the draft ORP with respect to parks and park policy.

  1. The most salient deficiency in the plan is its failure to create an inventory of Sonoma County's physical and environmental assets as a basis for park planning. How can we discuss where parks should be without first discussing what is available in our natural landscape? A passage by the National Recreational and Parks Association (NRPA) quoted in the draft ORP on page 37 states in part:

"It is recommended that a community inventory its land and water resource base, determine the pattern of these resources, their complexity and suitability for various levels of passive or ecological based leisure pursuits, then address the preservation and protection of such open lands from an environmental as well as a recreation policy driven program."

This critical omission was also noted by Frances Brigmann, in an open letter to CORP dated January 22, 1999 commenting on an earlier draft of the ORP. Ms. Brigmann, the General Manager of the Marin Open Space District and Director of Marin County's parks system (and a Sonoma County resident) asked:

"...where is the material which recognizes the physical features of Sonoma County that are both environmental resources and possibilities for public outdoor recreation facilities (for example, the coastline, the Bay shore, the Russian River, the mountains and ridges)? I believe it is important to highlight what assets Sonoma County has that are, or might become, meaningful opportunities for public outdoor recreation. These physical feature assets are key, as the issue is not providing outdoor recreation just anywhere in Sonoma County. People want to go to specific areas in Sonoma County. These assets then need to be considered together with information on where people live in Sonoma County and what outdoor recreation facilities they want." [See note 1.]

  1. The next step after identifying the county's physical and environmental assets must be the articulation of a coherent philosophy to guide the siting of new parks. No such philosophy is revealed in the current draft ORP. Should one of our goals, for example, echo Marin County OSD's goal of acquiring the remaining ridges and "upland greenbelt" near cities for open space parks? [See note 2.]

Successful parks and open space districts throughout the Bay Area take stock of where they are, then decide where they want to go in an open process, then plan how to get there. Sonoma County's draft ORP has skipped the first two critical steps. Instead, most of the justifications given for proposed parks in the "Recommendations" section are limited to grandfathering from earlier plans and expressions of support at a single workshop. This results in an unacceptably haphazard process for selecting proposed parks.

  1. The above shortcomings are exacerbated by the draft ORP's decision to drop quantitative standards and goals for the public's highest priority parkland type, the Regional Open Space Parks (Passive). This decision in and of itself may have been justified, as the drafters followed the lead of NRPA in this matter. But, as noted above, the draft ORP has not adopted the alternative approach recommended by NRPA (asset inventory), leaving a vacuum in the planning process. In addition, there are two compelling reasons why some sort of quantitative analysis needs to be carried forward for open space parks in Sonoma County:
  1. County and regional parks in general are intended to serve nearby populations. Sonoma County is large enough that we must look at whether individual areas are being underserved, particularly for the types of parkland the public overwhelmingly wants more of. Quantitative analysis of some kind is needed if our goals include addressing underserved areas of the county, as CORP believes they must. [See note 3.]
  1. County residents need to see how we have fared against the quantitative goals used in past plans, which are listed on page 36 of the draft ORP. Sonoma County's regional park acreage currently stands at less than half the goal of 20 acres per 1000 population proclaimed in the 1979 and 1989 General Plans. CORP's analysis shows that, even if all the proposed parklands in this draft ORP are acquired, we will still fall short of that goal and will remain in the bottom tier of Bay Area counties in terms of local parkland per capita. [See note 4.]
  1. In view of the foregoing, we must ask why the draft ORP's ambition level for new parklands is not higher. Sonoma County in 1999 enjoys a booming economy, abundant open space suitable for parklands, a fully-funded Open Space District empowered to purchase land for passive recreation, and a strong public consensus in favor of natural parkland and trail acquisition. Prime land for outdoor recreation will only become scarcer and more expensive in the future. Sonoma County will never have a better opportunity to leave a dramatic, lasting legacy to benefit the public, economic, and environmental health of all future generations.

For the same reasons, we would like a more ambitious stance in favor of new and expanded parks from non-county jurisdictions. Objective 3.1 and policy 3.1 do refer to interagency cooperation, but in a very general way. The only specific mention of a new state park is at Willow Creek (1000+ acres) near Monte Rio. Why are there not more new state parks, or significant expansions of Jack London, Sugarloaf, Austin Creek, Annadel, Fort Ross, etc.? Why not a national park in Sonoma County? It is true that recent decades have not been kind to state and national parkland acquisition, but there are many indications the climate may be changing for the better both in Sacramento and Washington D.C. It is high time to put Sonoma County on the planning horizon for state and national parks.

  1. Finally, we are deeply concerned with the apparent failure of the county agencies involved in the draft ORP to follow their own process for siting parks, as well as trail corridors. Inputs to the process, as listed on page 81, are supposed to include quantitative guidelines (for certain park types, as noted above), survey information, workshop suggestions, and trends. This process is to lead to proposed park and trail sites which are "schematic," meaning not parcel-specific. Ultimately, it is hoped that a willing landowner in the vicinity of the proposed site will choose to sell an easement or fee interest so the proposed facility can become a reality.

Quite properly, there is no provision in the stated process giving veto authority to current landowners who don't want parks or trails in their vicinity. Such landowners are free to choose not to sell their own land, but they should not be able to infringe on the rights of their current and future neighbors by sabotaging the planning process. Backroom power politics are not supposed to part of the process for siting parks and trails in this plan.

Yet the draft ORP has made a number of recommendations and has undergone a number of changes which cannot be explained in any other way. The case of the trail over Sonoma Mountain from the Petaluma Adobe to Jack London Park is the most glaring example. This trail was given the absolute highest score in the 1997 "needs evaluation," (Appendix 2d) and has consistently been the top trail requested by the public. Yet it mysteriously disappeared from draft ORP maps about a year ago, and is replaced in the current map by the "Petaluma to South Sonoma Mountain Trail," which inexplicably avoids the upper part of the mountain, connects to nothing, and ends nowhere.

As with trails, so with parks. In the 1989 general plan "Schematic Map of Designated Outdoor Recreation Areas", there are four proposed park symbols clustered around the summit of Sonoma Mountain. What became of these proposed parks in the 1999 draft ORP?

  1. One of these parks, shown at the location of Petaluma's Lafferty Ranch Park, has morphed into "Lafferty Ranch Preserve" (P4 on the "After" map, below). The ORP's definition of "preserve" suggests more limited public access than that described in Petaluma's management plan.
  2. A second, formerly on the southeastern side of Crane Creek Regional Park toward Sonoma Mountain, where it would have helped complete the proposed trail (AK) to Jack London Park, is now called the "Crane Creek Regional Park Expansion" (OS9) and has moved to the northwestern, downhill, side of the park -- away from Sonoma Mountain.
  3. A third, near the location of the Fairfield Osborne Preserve (which currently permits very limited public access) has disappeared without a trace.
  4. A fourth, closest to the summit and Jack London State Historic Park, is now unveiled as the "North Sonoma Mountain Park" (OS10), an 85-acre Regional Open Space Park. Eighty-five acres! And this despite the fact that this Regional Open Space category is supposed to be reserved for large parks of 300+ acres. [See note 5.]
Detail from 1989 General Plan map Detail from Draft ORP map, May 1999

Before: Close-up of Sonoma Mountain area from 1989 General Plan, "Schematic Map of Designated Outdoor Recreation Areas," Figure OS-4a. Dark circles are (schematic) proposed parks.

After: Close-up of Sonoma Mountain area from 1999 Draft Outdoor Recreation Plan, page 107. Dark triangles are proposed Regional Open Space Parks, light triangles are proposed Regional Preserves, and dark squares are proposed Regional Recreation Areas.

On what basis were these decisions made to move, delete, and truncate parks and trails on upper Sonoma Mountain? The facilities described in the current draft weren't grandfathered from previous plans, as such, and they certainly weren't requested in this form by the public. On the contrary, the top priority for south county residents is to "acquire and develop facilities on Sonoma Mountain as accessible open space" (page 72).

It is difficult to escape the conclusion that the ORP process has been unduly influenced by special interests with an agenda of keeping trails and parklands off the upper slopes and ridges of Sonoma Mountain. This is contrary to the open process espoused in the plan, and the people of Sonoma County deserve better.

Recommendations

CORP recommends that the park siting provisions of the Draft ORP be amended as follows:

  1. Create an inventory of Sonoma County's physical and environmental assets as a basis for park planning. Include this inventory in the final ORP, and review park siting recommendations in light of the inventory.
  2. Articulate a coherent philosophy to guide the siting of new parks. The vision of neighboring counties to acquire all remaining upland greenbelt near cities would seem an excellent example of such a philosophy for Sonoma County. Describe this philosophy in the final ORP, and review park siting recommendations in light of it.
  3. Carry forward quantitative measures for Regional Open Space Parks (Passive). Show how we fare in this crucial category against past plans and against other counties. Show the distribution of such parkland within areas of Sonoma County, so residents can determine whether they are adequately served.
  4. Consider increasing the natural parkland acreage in the plan, in view of abundant available funds from the Open Space District. Place more emphasis on working with state and federal agencies to dramatically increase parkland acreage in our county.
  5. Adhere to the stated ORP policies and public process. Rescind vetoes by individual landowners of non-parcel-specific park and trail sites. In particular, respect the public's clear wishes and the ORP's process by restoring the deleted trail over Sonoma Mountain, and planning a large park atop that mountain, in the final ORP.

Note 1. The complete Brigmann letter, along with related documents, can be seen on the CORP website at http://www.sonomatrails.org/docs/brigmann.htm

Note 2. Sonoma County needs a vision to guide its parkland acquisition, and as visions go, the Marin and Midpeninsula visions of acquiring upland greenbelt near cities is a very good one. As public open space, such ridges and uplands deliver an unmatched set of public, economic, and environmental benefits, as seen in parts of the South and East Bay as well as in Marin:

Such benefits, as has been amply documented, pay significant dividends (see the website of the Trust for Public Land, http://www.tpl.org for more on the economic benefits of parklands and open space):

Our Sonoma County cities, while not necessarily bounded by ridges on all sides, all have suitable upland greenbelt nearby.

Note 3. Based on statistics in the draft ORP itself, the southern third of Sonoma County is clearly the most underserved in terms of parkland of all jurisdictions.

The draft ORP divides the county into 6 "park planning areas," of which areas 5 and 6 correspond roughly with Supervisorial districts 2 and 1, respectively. Area 5 includes the Petaluma Valley plus Cotati and Rohnert Park, with a 1995 population of 111,200. Area 6 includes the Sonoma Valley, with a population of 38,500. Taken together, areas 5 and 6 have 36% of the county's population.

Areas 5 and 6 have the fewest acres of publicly accessible open space in the County, by a very wide margin, with only 1147 acres of state and county parkland combined, less than 3% of the county-wide total of 44,555 acres. Three percent of the parklands for 36% of the population!

It is not as though the region is devoid of natural beauty and suitable greenbelt. Residents of the Sonoma and Petaluma Valleys and the southern Santa Rosa plain look up every day at the region's most prominent landform, Sonoma Mountain, the upper reaches of which are still largely undeveloped. It is difficult to imagine a more obvious site for large open space parks in the southern half of the county than upper Sonoma Mountain, yet the ORP drafters seem to have overlooked it.

For more analysis of parkland distribution within Sonoma County, see the following documents on the CORP website:

http://www.sonomatrails.org/docs/orpparks.htm
http://www.sonomatrails.org/docs/drvtime.htm

Note 4. According to the draft ORP, Sonoma County currently has 3,503.1 acres of Open Space Parks (Passive), plus 622.2 acres of Regional Recreation Areas (Active), for a total of 4125.3 acres of what were formerly called simply "Regional Parks." Using the 1998 County population of 418,100, we have 9.87 acres of Regional Parks per 1000, less than half of the 1979 and 1989 goal of 20 acres of regional park per 1000 population.

We also must take issue with the draft ORP's assertion, on page 36-37 that, "[s]tate and federal lands were counted toward meeting some of this need." The wording of the 1989 General Plan directly contradicts this assertion on page 380:

"Federal Recreation Areas and State Parks provide recreation opportunities intended to serve national or statewide populations. Regional parks provide opportunities for a broad range of recreational activities generally within a 30-60 minute drive from urban areas at a rate of 20 acres per 1,000 persons."

If we meet the parkland acquisition goals in the draft ORP (a big "if," considering many of the proposed parks have languished in previous plans for decades), we would have 9769.3 acres of Regional Parks. That would meet the former NRPA standard with over 23 acres per 1000 assuming the 1998 population. But using the ABAG estimate of our county's population in the year 2010 of 508,200, we again fall just short at 19.22 acres per 1000.

Furthermore, it is important to realize that the 20 acres / 1000 guideline does not describe a "parklands-rich" region by area standards. CORP's analysis of locally administered public open space shows a Bay Area average of 35.7 acres / 1000 population, almost double the fomer NRPA standard and more than three times Sonoma County's current total. See http://www.sonomatrails.org/docs/openclsd.htm

Note 5. In addition, an active-use regional recreational area on the mountain's lower slopes is proposed, called "South Sonoma Mountain Park." Since CORP's focus, and the public's strong preference, is for passive open space and trails, active use parks such as this proposed facility are not considered further here.


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