With height knocked down from 53' to 35'


Lok Guernewood Park Development PLP18-0012
17155 Hwy 116, Guerneville
APNs 072-130-005, -007 and -009


Thursday, February 24, 2022, 1pm
Board of Zoning Adjustments Zoom Meeting

Click here to join Zoom Meeting from the BZA webpage:

Project BZA documents including written public comments:

Impact to Emergency Fire Evacuation

According to, and excerpted from, the project's Mitigate Negative Declaration
dated Aug 27, 2021, pgs 84,85:

If located in or near state responsibility areas or lands classified as very high fire severity zones, would the project: 1) Substantially impair an adopted emergency response plan or emergency evacuation plan; (Apparently they believe that the project can't impact emergency evacuation because there is no plan!)

Comment: According to the Safety Element of the General Plan, the project site is not located in a high wildland fire hazard area.

There is no separate emergency evacuation plan for the County. Furthermore, the
project would not cause an interference with emergency evacuations.

Significance Level: Less Than Significant Impact.

Directly across Hwy 116 from the proposed hotel are the side by side ingress/egress roads of Old Monte Rio Rd and Lovers Lane. This is already a difficult intersection to exit from our residential area on busy weekends:
Closest escape route for the nearest residents to the Lok Resort
Click HERE for map enlargement pdf file. Just because the situs lots are zoned for Visitor Serving doesn't mean a hotel
of this size is appropriate for this location!

Legal actions are starting to be taken against County Agencies across California for allowing developments/commercial projects in high fire risk/poor access areas:

Judge overturns approval of major Lake County resort:
"Markham’s ruling states that the findings primarily addressed whether the project’s residents could safely leave the site in during a fire. However, the EIR didn’t focus on “whether evacuation of the residents in the nearby area would be affected by the evacuation of the Project’s residents during a wildfire.”"

Wildfires, CEQA, Climate Change & the Courts:

Fire Experts Warn:

In the Flood Plain:

FEMA FLOOD PLAIN MAP:Lok Hotel in the flood plain
Click HERE for an enlargement of this FEMA floodplain map.

2019 Guerneville flood photo, entrance to Lover's Lane, directly across 116 from the proposed hotel site:2019 Guerneville flood Kirk Lok hotel

02/`7/22 - Lower Russian River MAC Meeting with the Sonoma Water Agency. The video starts (1:02:39 - 1:06:49) at the Q&A section that discusses Sanitary Sewer Overflows during floods, goes into the age of our system and how mounting upgrade and repair needs to this infrastructure aren't being met:

To view Sonoma Water's entire presentation go to 43:39.

Residents looking across flooded 116 at the location of this proposed Resort/Emergency Shelter from Old Monte Rio Rd:
Kirkman Lok

Biological Assessment?

Lok hired Kjeldsen Biological Consulting to prepare a biological assessment report of the site in July 2008 for the County Planners.

Field observations were done on September 29 and December 14, 2006 and September 28 and December 14, 2007 (pg 6 of report).

From pages 6 and 7 of the report: "The area was surveyed to determine whether occupied raptor nests were present within the proximity of the project site (i.e., within a minimum 500 feet of the areas to be disturbed). Surveys consisted of scanning the trees on the project site (500 ft +) with binoculars searching for nest or bird activity. Our search was conducted from the project area looking for droppings or nest scatter from nests that may be present that were not observable by binoculars."

Nesting season typically starts in February and goes through August for Ospreys. Both parents incubate the eggs — about 36-42 days from when they are laid until they hatch. Osprey chicks spend a very long time in the nest after hatching. Their first flights usually occur about 55 days after hatching. Ospreys have a high nest-site fidelity and return to previously existing nest structures each year. 

According to the Kjeldsen report (pg 23):
"We did not observe any rookeries, nesting sites or breeding habitat for wildlife of the area associated with the project. Raptor (Osprey) nesting is common along the Russian River but no nests were observed on the property or near vicinity." Perhaps this was due to their choice of field dates being so late in the year?

The ONLY fauna species they reported seeing were Scrub Jays and Common Mergansers. Perhaps our local birders should have been hired independently instead: Other species observed at site location: https://imbirdingrightnow.com/2020/12/07/sit-spot-russian-river/

There is now an Osprey nest directly across the river, a short distance from the building site:
osprey nest Guerneville

Link to 08/27/21 UPDATE:
Initial Study / Mitigated Negative Declaration documents provided by the developer and county.

The Russian River Corridor Design Guidelines were adopted by the Sonoma County Board of Supervisors on December 14, 2010.
Efren Carrillo, the Lok project's supporter and paid consultant, was our District 5 Supervisor at the time but it's not known how he voted on the guidelines. Developers are SUPPOSE to be following these guidelines.

10/28/21 MEMO - Changes to the Mitigated Negative Declaration - pdf
10/28/21 BZA Staff Report - pdf

Please review our concerns and all of the provided documentation so you can send Informed Public Commentary via USPS to:
Attn: Georgia McDaniel, Project Planner

2550 Ventura Ave.
Santa Rosa, 95403-2859

Or via e-mail to:
- Board of Zoning Adjustments, Project Planner.

To get county BZA updates: Request that Georgia McDaniel add you to the project's PLP18-0012 Interested Parties List.

District 5 Representatives on the Board of Zoning Adjustments:
Eric Koenigshofer - e-mail

Lodge at Russian River
Click HERE for enlargement. More project illustrations from this version can be found HERE.

Oct 22, 2021 Eric Koenigshofer from the BZA Meets with MAC Land use Ad Hoc Committee to discuss The proposed Loc Hotel and the size of the project:

June 17, 2021 Lower Russian River Municipal Advisory Committee meeting with project developers; Kirkman Lok, Efren Carrillo, Doug Demers and Jean Kapolchok:

Kirkman Lok
Click HERE for more documents.

The various idealized 4 story renderings of the hotel that have been published don't illustrate the additional stories that will be required to raise the hotel out of the flood plain. They show the hotel at ground level with the redwood trees. This size of hotel will not be as nicely snuggled down in the redwoods as the developers would have you believe.

The project was started back in 2018, at least with the county. This was before Covid, our local mega wildfire evacuations and a statewide mega drought and water restrictions. Then, as now, there has been very little public outreach or meaningful consideration of how this relative behemoth will negatively impact our community's fragile, failing and poorly maintained infrastructure.

Things to consider:

• Our ability to effectively evacuate a wild fire is already compromised by residential road closures from landslides and failing narrow roads that the county has no intention of fixing for lack of funds. Our current options for emergency escape routes are already too few and inadequate for our current population of residents and visitors. The Guernewood Park area alone is estimated to have approximately 800 residences. Most people on the lower Russian river rely on Hwy 116 / River Road as our single escape route.

Area roads connecting to Hwy 116 are generally in Poor to Very Poor Condition: Click HERE. and zoom in on map to our area to view condition of our residential roads.

• We are sorely lacking in financial resources and support for fire mitigation from local and federal levels. Our area has steep forested terrain with numerous neglected, un built, and unsupervised privately owned lots where the homeless are being driven by development, tourist serving businesses and a lack of support resources. Every year the number of fires getting out of control in the woods is escalating. Fire mitigation is far more costly for us because of our terrain and most residents are on low fixed incomes.

• Our aging Guerneville sewer system: A sewer main broke and dumped 100k gallons of raw sewage into the Russian River on Feb 16, 2014

• This project is MUCH larger than any other local visitor serving amenity. Our largest local hotels and lodges have between 12-35 available units.The developers describe their planned restaurant/bar as being "small": 3,334 sq ft!

• There isn't enough affordable housing in our area for our existing low wage service workers and we are in the middle of an escalating homelessness crisis.

• The property has ongoing, unresolved, violations.

Just two things noted in the documents of the IS/MND after a quick examination of the IS/MND documents provided by the county:

1. The nearest traffic impact study was done at Guernewood Lane, a short through road with few homes, NOT the more critical intersection in an emergency evacuation for hundreds of people directly across from the hotel. In fact, their map, below, doesn't match up to the GIS zoning map. or the Sonoma County ESRI map. It has the project site in misalignment with the nearby intersections and ignores the existence of Lovers Lane right beside Old Monte Rio Rd:
Bogus traffic study map

Kirkman Lok
Click HERE for enlargement of the Esri map.

inexplicably, there was a traffic study done at Armstrong Woods Rd but NOT between Rio Nido and Armstrong Woods Rd in Guerneville! This is an area well known as a traffic congestion nightmare and I remember residents of Rio Nido were quite outspoken about their concern with it being made even worse with the addition of this large hotel. Local residents arrange their outings with this in mind and pray that they don't get a migraine and run out of aspirin at the Wrong Time.

2. The study of recommended parking spaces states that many hotel employees will be taking public transportation to and from work, suggesting they don't need the recommended number of parking spaces? Clearly no one involved with this project has looked at the schedule for the route 20 bus that only runs every hour or so.

Interesting article from Nov 2018: Two designs confuse river hotel hearing
Lodge on the Russian River - Web page apparently updated in 2019
Guernewood Park Resort - Facebook page from 2014
Another interesting article from 2013 by Frank Robertson.



Supposed Benefits to the community according to the developers with bullet point commentary, below:

• Not sure that this will really stimulate our local economy: Their definition of "local" is fuzzy. They compare the benefits of this hotel to our area with hotels in Sebastopol and Petaluma. Hardly an equitable comparison.

• Their guests will be traveling in their cars out spending "day trippers", contributing to traffic congestion.

• Again, what is considered" local" jobs?

• 221k is only a drop in the bucket for affordable housing. This money will be spread out across the county with no guarantee it will help with our affordable housing problem.

• Same problem with the locally generated TOT taxes: No guarantee that these fund will serve our area except to advertise the lower Russian River as a Tourist Destination.

• A natural emergency shelter? When this location is in the floodplain? Do they plan on providing ferry service?What would be useful would be an emergency homeless shelter!

• Suggesting that this resort "will eliminate unsupervised and unlawful use" of the (undeveloped) site brings attention to a couple of glaring FACTS:
That as property owners they have done nothing to prevent their property from being an attractive nuisance and that current homeless campers there will move higher up the hill and deeper into the woods to areas that more difficult to access once the hotel breaks ground for construction. Whatever happened to the concept that With Ownership Comes Responsibility?

•There is already Public Access to the river from this property. Drawing more attention to this small beach access will attract more visitors and 25 parking spaces won't be enough. The developers fenced off the property so close to 116 that visitors using that beach access have had to park all along 116 AND up on Old Monte Rio Rd.This will undoubtedly continue with inadequate parking provided.


FUN FACTS & Smoking Guns:

PERMIT HISTORY LOOKUP: Searching by address seems to pull up the records for the 3 lots involved with the hotel project: 17155 Highway 116
Check out the still active violations! The word from local homeless services provider (who wishes to remain anonymous) is that the Lok Group gave permission to homeless campers to stay as unpaid site security. Local residents attempting to access the river have driven off by surly campers claiming to own the property. The developers have shown little interest in being responsible for the property they own, the environment or the safety of the community... at least until they can make money from the property.

The Lok Group of Companies headquarters is a private residence that's for sale. This is the contact address on the current permit:
5050 Petaluma Hill Rd
Santa Rosa CA 95404

http://www.thelokgroup.com/ The Lok group website, originally given to the community as a link to project plans, no longer exists.

Covid Bailout loans:
$416,788: Approved April 27, 2020 Loan statue: Forgiven

$650,174: Approved Jan 31, 2021Loan status: Not Disclosed

Our former District 5 Supervisor, Efren Carrillo: was hired by the Lok Group of Companies(Kirkman Lok) as some kind of liaison to the public. The same Efren Carrillo who neglected to tell his constituents that there was a small window open to apply for a Vacation Rental Exclusion Zone in their surrounding area for free instead of $8,400. Residents have to pay this fee even if the Exclusion Zone is needed for public safety reasons such as poor road conditions for emergency vehicle access and high fire risk terrain. Thanks to Efren, there are zero VR X Zones in District 5.

One can't help but wonder if Mr. Carrillo was one of the beneficiaries of the above Federal Covid Paycheck Bailout "loans"...

Kirkman Lok, head of the Lok Group of Companies: