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Addendum Artful Dodger
The San Anselmo Flood Risk Reduction (SAFRR) project stopped being about flood control years ago. This has become a scandal over money and power, and if you carry flood insurance, one you cannot ignore.
The money is a grant from a 2006 bond measure passed by CA voters as Prop.1, Integrated Regional Water Management (IRWM) Grants. While intended for Stormwater Flood Management, the County Flood District (CFD) has transformed its use from removal of a flood obstruction into a proposal for demolition and rebuilding a flood obstruction. Can the CA Department of Water Resources, charged with administration of these grants, justly allow public funds intended for flood remediation to be used for creating a flow obstruction?
The obstruction transformation, a proposed concrete barrier across the creek bed, comes with a demolition cost of $4-10M. The new constriction construction, a 'baffle’ by name, has not yet been revealed to the public: the 100% design and construction drawings are not accessible to residents.
Repeated requests to view them remain unanswered by the CFD, Marin Department of Public Works, and Supervisor Rice. Presumably, baffle is not free-standing, but connects at the creek banks to other concrete structures. That does not fit the description of "laid back, reinforced, bio-engineered, revegetated banks" described in the 2018 EIR certification. Nor does a 'temporary concrete baffle' fit FEMA’s requirement that permitted modifications in the floodway be permanent structures.
The ability of elected representatives to abuse the power of their office to advance personal goals is malfeasance. From statements made June 26, 2023, to the Zone 9 Flood Advisory Board, it appears that Jared Huffman and Katie Rice coerced FEMA representatives to meet with the Marin County FCD manager for the purpose of crafting evasions to formerly endorsed design and funding of mitigation for homes that will be flooded as a result of the SAFRR project. Notably, flood managers for the affected towns of San Anselmo and Ross were not included in this meeting with FEMA.
Further, to divert focus from the controversial fencing-off and proposed demolition of BB2 (the pre-baffle, beloved plaza in central San Anselmo), the Marin County flood district has issued an Addendum to the 2018 SAFRR EIR.
Readers are misled by publication on the CEQA site wherein a compensatory mitigation planting west of Fairfax is described as the subject of the SAFRR Addendum: https://ceqanet.opr.ca.gov/Project/2017042041. Fairfax residents left with a $1M shortfall in cleanup at the site of the Sunnyside Detention Basin might have enjoyed that revegetation, but nope: San Geronimo gets the trees.
The proffered Addendum is part of the County’s heedless scramble to protect access to the Department of Water Resources bond funding, a grant for which the project no longer qualifies. Section 15162 of CEQA Guidelines lists criteria for a recirculating a full EIR and the current county proposal meets every one of them. However, instead, the county has prepared an abbreviated Addendum.
EIR recirculation is a legal necessity due to changes in creek bed conditions that will increase both flood flows and impacted areas, requiring new hydraulic analysis and computer models to secure federal permits. Bridges and culverts previously considered replaced now remain in place. Inclusion of measures to prevent flood remediation altogether are new project elements. Outdated claims that 480 homes will benefit from SAFRR are as deceitful as the deflection to tree-planting in San Geronimo.
The county admits in public meetings that additional, increased flooding will occur, but hides the new and substantial impact in the Addendum appendices. Not until page 83 is the true nature of SAFRR’s substantive impacts revealed. Appendix A, Mitigation Measure 4.9-4 strikes out the "fund" in the “develop/fund” mitigation protection of the 2018 SAFRR EIR. Parcels potentially impacted have skyrocketed from 3 to 57. Worst of all, substituted measures skirt FEMA’s Regulations 44 CFR § 60.3 through 65.12, threatening the federal protections FEMA provides impacted homeowners.
That the CEQA process intended to inform the public of potential substantial impacts of the proposed SAFRR project has been warped into a vehicle to advance special interests, not flood remediation, is a violation of public trust. This is a dissembler extraordinaire, Addendum Artful Dodger objectified. Comment deadline on this EIR Addendum is 4 PM on July 10, 2023 [comments to Envplanning@marincounty.org].
Anyone with flood insurance administered by FEMA should be concerned because after asserting that risking our good standing with FEMA’s National Flood Insurance Program is something she would never do the county flood administrator inexplicably reversed course by proposing to do exactly that. Skipping FEMA’s CLOMR (Conditional Letter Of Map Revision) and substituting a LOMR (Letter Of Map Revision) enables demolition of BB2, and risks loss of both FEMA’s NFIP andFEMA’s annual Community Rating System discounts on homeowners' flood insurance.
Your opinions are important.
For greatest impact, please, cc FEMA [michael.nakagaki@fema.dhs.gov, serena.cheung@fema.dhs.gov, brian.koper@ fema.dhs.gov, michael.j.bishop@fema.dhs.gov], Department of Water Resources [Karla Nemeth, Karla.nemeth@water.ca.gov], Jared Huffman, Marin Supervisors [BOS@marincounty.org], Marin Flood District [B.Davidson@marincountyorg, RGaglione@marincounty.org], sburdo@townofsananselmo.org, rsimonitch@townofross.org.