SPECIFIC COMMENTS SUBMITTED BY THE LEAGUES OF WOMEN VOTERS OF THE MONTEREY PENINSULA AND THE SALINAS VALLEY

1. Page 4. The plan states that the County is committing to control unplanned growth and in exchange will ask for public support to make necessary improvements to correct current infrastructure deficiencies. We hope that this does not imply that the County will support unplanned growth in the event that current deficiencies are not corrected.
2. Page 4. The proposal to establish a two year Plan amendment cycle and require that amendments can only be made if there is agreement that the proposed change is consistent with the overall Plan and Area vision statements provides greater assurance to the public that the Plan will not be eroded by frequent amendments.
3. Page 9. Correcting the existing jobs/housing imbalance is critical to addressing existing traffic congestion and affordable housing needs. We support proposed action items related to this issue.
4. Page 9 and Policy H-4.4. We strongly support increasing the Inclusionary Housing Requirement from 15 to 20%. Additionally, we recommend that all in lieu fees collected to construct off-site affordable housing be used for housing projects and that none of these fees be used to administer the program. Wording should be added to make it clear that affordability of inclusionary units is to be maintained for the long term by recorded deed or developer agreement.
5. Page 9. We support the recommendations regarding minimum density levels and community-wide densities. Increasing density is one important way of providing affordable housing within designated communities.
6. Page 9. We support the provision to seek major industries and employers and cities assistance to building housing for their workers.
7. Page 10 and Policy LU-7.24. Policies related to meeting infrastructure requirements for the proposed Winery Corridors should be proposed.
8. Page I-6. We support the addition of the recommended two additional Guiding Objectives:
   1. Create multi-modal transportation networks within communities and between employment centers that allow major road users (trucks, visitors, and residents) to reach destinations as efficiently and as safely as possible.
   2. Protect public health and safety by minimizing risks related to natural hazards and manmade hazards (hazardous materials, noise, aircraft hazards).
9. Page I-11 and Action LU-3.a. The Plan envisions the annexation of approximately 3,000 new acres directly adjacent to existing cities within the Salinas Valley. The Draft Plan states that this new land is more than sufficient to provide housing units for the next twenty years (e.g., 30,000 units or more). 30,000 units translates to 94,200 people assuming 3.14 pers/du. This population would be in addition to development on existing vacant parcels within current city limits. Data supporting the need for an additional 3,000 acres to meet AMBAG's forecast for city growth of 111,302 by 2020 should be provided.
10. Page I-18. Community Areas for immediate growth include the redevelopment areas of Castroville, Pajaro and Boronda and unincorporated former Fort Ord and Rancho San Juan. These areas are of sufficient size to accommodate more than 10,000 units (p. H-2). Currently, unincorporated areas have approximately 8,000 vacant lots of record within residential zoning categories which will continue to be developed at the current zoning levels if water is available (p. H-3). The County shall assure that the proportional distribution of population located within the unincorporated areas does not increase above the current level of 22% of the total county population Page LU-5. Policy LU-1.1). The AMBAG 2020 forecast for Monterey County is 519,609 excludes Soledad Prison population). The unincorporated s hare (22%) would be 114,314 an increase of 14,062 persons from 2000. The accommodation of 18,000 units for a total population of 56,520 people (3.14 pers/du) far exceeds the 22% share. The County should address this discrepancy.
11. Pages AD-1, 4, 5 & 14. The Plan gives Land Use Advisory Committees (LUACs) additional responsibilities, e.g., reviewing General Plan amendments and discretionary permits and determining when area residents are interested in participating in the Community Plan development process. We applaud the effort to increase opportunities for citizen participation in the process both on and through the LUACs. These Committees are close to the communities they serve and because of their meeting times and locations, afford greater opportunities for the public to participate in land use decisions. To further facilitate citizen participation, we urge an action item that addresses appeal fees. Current fees are a real disincentive to meaningful citizen participation and should be lowered.
12. Page AD-10. Policy AD-4.5. We strongly support this policy which would require the County to ensure that a Capital Improvement Program is adopted and in place and that all required public improvements are adequately funded prior to construction of a new project that is reliant on the planned improvements.
13. Page AD-11. Policy AD-5.1.We recommend that this policy be expanded to include the publication either annually or semi-annually GIS maps that show the changes to the uses of the land, including zoning and physical changes.
14. Page AD-16. Policy AD-10.1. We strongly support the policy requiring requests for subdivisions and significant projects to prepare a fiscal impact report to determine the impacts that additional residential units will have on the surrounding area and the county as a whole and an identification of the associated fees to offset the costs of the impacts.
15. Page LU-5. Goal LU-1. This policy would maintain long range (20 year) and short range (5 year) population growth goals for Monterey County that limit the County's growth rate to a fair share of the State's population growth and ensure that future growth and development adheres to the limits and carrying capacity of the infrastructure and environment. We strongly support the provision requiring population forecasts to adhere to the carrying capacity of an area and urge the County to work with AMBAG to incorporate this provision in the forecasts for the County.
16. Page LU-17, LU-5.9. Rural Centers are identified for many unincorporated areas. Integral to the Rural Centers concept is that prior to intensification, voters within these centers would be required to fund infrastructure needs. To address both traffic and water infrastructure deficiencies in Carmel Valley, the Highway 68 Corridor, Del Monte Forest and North Monterey County requires action by agencies outside the Rural Centers, e.g., MPWMD and the County. We do not see that the Rural Centers concept is viable for areas where infrastructure problems cannot be solved locally, and we recommend that it be deleted for the Planning Areas described above.
17. Page C-7. The Circulation Concept Corridor Table describes numerous capacity increasing projects that are not in TAMC's regional transportation plan, e.g., Salinas Westside Bypass, Fort Ord Bypass, Espinosa Road Expressway, San Juan Road Expressway, Salinas Eastside Bypass, etc. The proposed project list should be reconsidered given the fact that the current plan is underfunded by $1.4 billion without these projects. Three of the proposed projects, i.e., Espinosa Road, San Juan Road and Salinas Eastside Bypass expressways, are explicitly linked with the Prunedale Bypass. The costs of the Prunedale Bypass (over $200 million above available funding) bring into question the viability of that project. Does the County propose to adopt these three expressways should the unfunded Prunedale Bypass fail to be constructed? Additionally, the Bypass is said to be "linked with an eastern bypass around the City of Salinas that ties to Highway 68" (p. C-5). Clarify how the proposed eastern bypass around Salinas is preferable to the existing, more direct route via Highway 101 to Highway 68 and South County. Additionally, the Plan should discuss how an eastern route is preferable to a more direct western route for a Salinas bypass and compare the environmental justice of each route. Finally, it should be explained how, even with the Prunedale Bypass, the longer East Salinas Bypass could attract future traffic away from Highway 101.
18. Pages C-5, 15, 17, 18, 22, 31, 41 & 42. The Plan includes numerous policies and programs related to developing and encouraging alternative forms of transportation. We strongly support these measures as ways to address traffic congestion and improve air quality. In particular, we strongly support Policy C-13.2 which requires that strategies to reduce demand on County roads and highways be considered prior to strategies to increase capacity. We recommend that this policy be strengthened by requiring that these strategies be implemented, just not considered, prior to supporting capacity increasing projects such as those described in item 16 above.
19. Page ER-11. Policy ER-3.1. The following are defined as native vegetation and endangered plant communities: coastal strand, maritime chaparral, chaparral, Monterey pine and cypress forests, redwood forests, perennial native grasslands, oak woodlands and savannas, sycamore alluvial woodland, wetlands, marshes, vernal pools, riparian forests, willow seeps and wet meadows. We strongly support the inclusion of this complete list in the General Plan.
20. Pages ER-11 & 12, Policy ER-3.4 and Policy ER-3.5. We support these policies which address replacement of native oaks and other native tree species and permit requirements.
21. Page ER-27 and Page LU-17. We support Policy ER-10.3 which addresses ridgeline development within critical viewsheds and Policy LU-5.11 which prohibits development or conversion of uncultivated land on slopes greater than 25% in high soil erosion hazard areas and 30% in all other areas.
22. Page HS-5. Policies HS-2.4 and 2.5 regarding flood plain development appear to conflict.
23. Page PS-9. We strongly support Policy PS-3.12 which requires environmental review for private well construction in overdrafted and water quality problem areas and Policy PS-3.13 which requires that prior to the time of discretionary or ministerial project approval, the County shall require verification of long-term water supply, including sufficient supply during drought years.
24. Page PS-23. We recommend that Policy PS-9.d be more inclusive of all services that are in need by adding "but not limited to" after "including".
25. Pages H-2 and H-3. The first of the Key Concept outlined is the Land Area to be utilized to provide more affordable housing near three major employment centers in the county. The related Land Use policy decisions, actions, and definitions which are proposed should be more coherently explained and references to relevant sections in the Land Use and Agriculture Elements added.
26. Page H-2. The estimated capacity in each of the Community Areas for new housing development should be given with acreage and proposed densities and existing resource constraints noted.
27. Page H-3. More information is needed about the 8,000 existing approved lots of record in residential areas, including their geographic distribution.
28. Page H-16, Policies, Actions and Programs. These items are all important in furthering the comprehensive Housing Program which the County has undertaken in recent years, and we support them.
29. Page H-16, Action H-6a. When the Regional Housing Need allocation has been approved and these numbers changed, it should be explained that this share of regional housing is for 2000-07, not the entire 20 years covered by the General Plan and that the total is for unincorporated areas only.
30. Page H-9. We recommend that policy H-2.7 be strengthened to state that the County shall ensure new housing production be phased to match existing job-based housing needs and new job creation.
31. The Plan includes a table describing the schedule for implementing 415 programs and action items. Since 28% of these items are the responsibility of the County Planning Department which has historically had difficulty in addressing its workload, we recommend that the Final Plan identify the staffing level and funding resources needed to implement the programs and action items.

Comment from the League of Women Voters of the Monterey Peninsula:

1. Page 10 and Policy LU-5.14. We recommend that the provisions of Measure A (Del Monte Forest) be submitted to the California Coastal Commission for certification prior to their inclusion in the General Plan since some of the provisions may be inconsistent with the Coastal Act.