On March 29th, through a Freedom of Information Act request, I received a copy of correspondence from HomeCA/Native Directions and El Dorado County. One of the requirements for the State Grants funding these proposed facilities in Rescue is a letter of support from the county. What follows is the correspondence from HomeCA/Native Directions and El Dorado County Supervisor Parlin. Following these articles is a copy of the email response I sent to Supervisor Parlin regarding these letters. I encourage you to add your voice to my response. You can email Supervisor Parlin at bosfour@edcgov.us.
HomeCA/Native Direction Request for Support to El Dorado County
Supervisor Parlin Response to HomeCA/Native Directions “Request for Support”
HomeCA/Native Directions “Fact Sheet”
Chris Silva Email Response to Supervisor Parlin RE: Letter of Support
From: Chris Silva <redacted>
Date: Fri, Mar 29, 2024 at 10:10 PM
Subject: Re: Native Directions HomeCA correspondence
To: BOS-District IV <bosfour@edcgov.us>
A couple points about their “fact sheet” – they got a bunch of “facts” wrong, and they are significantly posturing on some other items that are less “facts” and more “definitions.” It is unbelievable that they believe that these two 24×7 SUD facilities, with up to 45 patients (+up to 24 offspring), staff, etc won’t impact local EDC resources, shouldn’t be considered commercial, and are appropriate for these two parcels in Rescue. As you know we have a complete list of arguments against these facilities, but let me reply to a few of the statements made in the “Fact Sheet” provided by HomeCA/Native Directions.
- The first paragraph – “AB 172 (2021) established two key programs: the Behavioral Health Continuum Infrastructure Program (BHCIP) and the Community Care Expansion (CCE) Program.”
- Actually, in Oct 2021 bill AB 172 established only the Community Care Expansion Program. The BHCIP program was established through a budget bill in 2021 with a different set of legal requirements. The grant HomeCA/Native Directions (NDI) received was jointly funded by both of these programs. See details of legislative text through this link.
- https://rescuedeervalley.com/grant-bill-legislation-details/
- “These facilities are residential, not commercial, and not designed for providing medical treatment ”
- The definition of this facility, per the state grant application, is a “Perinatal SUD (Substance Abuse Disorder) Facility” (see copy below). Webster’s dictionary defines a medical facility as “a place where sick or injured people are given care or treatment.” From my research there are different types of “Perinatal SUD Facilities” in California definitions, and I expect this one is a “Residential Perinatal SUD Facility, and as such, this facility will provide basic resident care, but will not provide “medical” care, per se. The patients will need to be transported for any medical care (which is another issue with this location). At the base level these are 90-120 day Substance Use Disorder (SUD) facilities. These facilities are expected to provide “treatment” care. They provide “programs” that are “treatment.” These programs will vary based on each facility, but the goals are to change patient behavior, and help them overcome their SUD. Child care will also be provided on site at 3335 Deer Valley Ct. Since the purpose of these facilities is to collect income from Medical and other insurance providers, they are “commercial” by definition. To try to characterize these facilities as “residential” is ludicrous. Is an apartment building commercial? It exists to provide a residence, but of course it is commercial.
https://rescuedeervalley.com/wp-content/uploads/2024/01/native_directions_r4_application_redacted-1.pdf
- The definition of this facility, per the state grant application, is a “Perinatal SUD (Substance Abuse Disorder) Facility” (see copy below). Webster’s dictionary defines a medical facility as “a place where sick or injured people are given care or treatment.” From my research there are different types of “Perinatal SUD Facilities” in California definitions, and I expect this one is a “Residential Perinatal SUD Facility, and as such, this facility will provide basic resident care, but will not provide “medical” care, per se. The patients will need to be transported for any medical care (which is another issue with this location). At the base level these are 90-120 day Substance Use Disorder (SUD) facilities. These facilities are expected to provide “treatment” care. They provide “programs” that are “treatment.” These programs will vary based on each facility, but the goals are to change patient behavior, and help them overcome their SUD. Child care will also be provided on site at 3335 Deer Valley Ct. Since the purpose of these facilities is to collect income from Medical and other insurance providers, they are “commercial” by definition. To try to characterize these facilities as “residential” is ludicrous. Is an apartment building commercial? It exists to provide a residence, but of course it is commercial.
- 3840 Deer Valley Court – This facility is funded by the Bridge Housing Behavioral Health program (a different legislation – AB 179). The description of what this program is designed for is to “address the immediate housing needs of people experiencing homelessness who have serious behavioral health conditions, including serious mental illness (SMI) and/or substance use disorder (SUD).” This facility will be providing substance abuse treatment to patients that may have serious mental illness. Native Directions will be transporting these patients into Rescue for housing and treatment.
- 30 beds (patients) + Staff + deliveries + visitors + daily comings/goings. How does this scale of commercial facility NOT impact traffic? How does this scale of facility NOT impact fire risk, water availability, etc?
- 3335 Deer Valley Ct – as stated above, this is a Substance Abuse Disorder facility. It will offer 90-120 day treatment “programs” as well as full time child care services.
- Again, clearly a treatment facility generating income for Native Directions/HomeCA. How is this NOT a commercial enterprise?
- Up to 40 patients/children + Staff + deliveries + visitors + daily comings/goings. How does this scale of facility NOT impact traffic? How does this scale of facility NOT impact fire risk, water availability, etc?
- These facilities must be considered together as El Dorado County assesses environmental and community impacts. Although their development schedules may not perfectly overlap, the impact of these two facilities directly impacts the shared resources of this community, as they are separated by one parcel.
- San Joaquin County – Press releases from HomeCA/NDI clearly state the patients will “predominantly be from San Joaquin County.” Although these facilities may accept patients from “all around California,” including likely non-Native Americans, NDI has decades of experience in San Joaquin County and likely will be serving the community they know, and have supported, for many years. NDI has been based in Manteca for those decades of operating their existing small adult SUD facility.
https://www.mtdemocrat.com/news/53-million-awarded-to-create-housing-options/article_c1db9f08-c1c8-5677-a0ba-68e5d4408e0e.html - Traffic – HomeCA/NDI continues to tell EDC there will be minimal impact to traffic. Ask them to prove it with a comprehensive Environmental Impact Report. Our simple calculation shows 40-120 additional cars driving down Deer Valley Road to/from in ONE DAY. As EDC has informed other parties on Deer Valley Road, any new development would require improvements to this road prior to development. Hold these commercial facilities to the same standard as other residents in this area.
https://rescuedeervalley.com/deer-valley-road-traffic-analysis-data/ - Local Resources – ” these facilities receive funding from the state and will not impinge on or compete for local resources.” How can these facilities NOT put a strain on local resources? Is HomeCA/NDI funding additional police officers to cover these facilities which are housing homeless, substance abuse, and serious mental illness patients? Is HomeCA/NDI funding additional fire resources as these facilities are being developed in California’s highest severity fire risk zone?
Please feel free to reach out to me at any time if you have questions, or want to understand the community position on these proposed developments. Help us get them stopped, and hopefully moved to a more appropriate location. All our arguments and documents supporting the “facts” we quote are available at https://rescuedeervalley.com.
Thanks,
Chris Silva
Spokesperson for Rescue Deer Valley
3330 Deer Valley Ct, Rescue
(916) (redacted)
Rescue Deer Valley! 