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Community Venture Partners comments on the RFEIR for the proposed Corte Madera Inn Rebuild

The following letter has been sent to the Corte Madera Planning Commission and Planning Department, regarding the public hearing to discuss the Recirculated Final Environmental Impact Report ("RFEIR") for the proposed Corte Madera Inn rebuild project.

Dear Corte Madera Planning Commissioners:

You have before you a great deal of complex documentation, research, commentary and other information, regarding the proposed Corte Madera Rebuilt. However, the question you need to resolve is relatively simple:

Has the applicant provided sufficient evidence that their proposal’s mitigation measures are legally adequate and that no other practicable, less environmentally destructive alternatives exist?

The simple answer to those questions is “no.” That considered, why is the Town of Corte Madera continuing to process this proposal?

In our opinion, the Staff Reports for this project have failed to highlight the following critical information:

Details on status of the application with regional and federal agencies

The Army Corps has placed the application on “inactive” status, since October of 2016, because the Applicant failed to provide a required analysis of alternatives, and because the Applicant failed to gain comments and approval from the National Marine Fisheries Service (NOAA) or federal departments involved with “sacred lands.”[1]

The SF RWQCB has rejected the application as “incomplete,” because they found that the Applicant’s mitigation proposal (Burdell Ranch) is legally inadequate (not “apples to apples” mitigation as required under the 401 regulations), because the site is in fact, a “special aquatic site” and must be treated as such, and because the Applicant failed to provide an acceptable “alternatives analysis” (both on-site or off site), or evidence that no other less environmentally destructive practicable alternatives exist.

The Region 9 Office of the federal Environmental Protection Agency, which has the authority to over-ride any decision by either the Army Corps or RWQCB, has also rejected the Applicant’s mitigation proposal (Burdell Ranch) as inadequate (not “apples to apples” mitigation).

This raises important questions

The aforementioned considered, why is the Planning Staff continuing to bring this flawed proposal before you at this time?

Why is the Town of Corte Madera continuing to waste the public’s time and money on a proposal that at present has no chance of ever being permitted to build?

And, why is the Planning Staff showing demonstrable favoritism toward this particular project and this particular developer applicant? It is highly unlikely Planning Staff would afford this level of accommodation and leniency to an average citizen coming before you for a room addition on their house.

This project, as proposed, has gone essentially unchanged since it was first submitted, years ago. The Applicant has steadfastly refused to consider any less impactful alternatives, made up fictitious reasons why alternatives will not be approvable by the Town, and provided fallacious “financial feasibility” studies, which have gone uncontested by the Town in spite of ample argument and evidence that the Applicant’s studies are self-serving to the point of being nonsensical.

These are the facts of the application process for this project:

The developer’s attempts to obtain approval have been less than transparent. However, it is the developer’s right to do everything they can to obtain approval, even if some feel their actions have been ethically questionable.

However, the more important question is why is the Town of Corte Madera being complicit throughout all of this? Why is the Town continuing to process this application when, as of this time, it has no chance of ever being built?

If you vote to recommend certification of the RFEIR, you are directly contesting the opinions of three superior state and federal agencies positions.

On what grounds are you prepared to do that?

Thank you for your consideration and this opportunity to submit our comments.


Bob Silvestri


Cc: Adam Wolff

Corte Madera Town Council

[1] Roberta Morgenstern, Army Corps, November 9, 2016