LWV

Monterey County ERP
General Plan Update Team
230 Church Street, Building 3
Salinas, CA 93901

Comments on the Draft EIR for the General Plan Update

Dear Staff:

The League of Women Voters of the Monterey Peninsula would like to take this opportunity to comment on the Draft EIR (DEIR) for the General Plan Update (GPU).

  1. The DEIR is identified as a Program EIR with the notation that future projects may be tiered from this document. Because the DEIR identifies significant and unavoidable environmental impacts (i.e., air quality, loss of farm land, land use designations, traffic and transportation, acoustic environment, soil erosion, hydrology, water quality, biological resources, geologic resources and hazards, historic and archaeological resources, water supply and demand, visual resources, waste water services and community services), all future projects approved under the GPU and tiered from the DEIR will require preparation of environmental impact reports rather than (mitigated) negative declarations. This will further encumber the permitting process and should be addressed by reducing significant and unavoidable impacts where possible.

  2. The population forecasts used in the GPU are obscured. As noted above, there is a suggestion in the GPU that AMBAG population forecasts are used. However, the DEIR, Footnote 3, p. 5.3-12 states, "The countywide projection assumes that combined County and city growth will not exceed the State DOF total population projection of 590,700." This suggests that the DOF forecasts are used for the GPU. The DEIR states, p. 5.3-13, "This magnitude of projected growth is clearly inconsistent with the population growth projections that underlie the AQMP."

    We do not understand why the County uses forecasts that do not reflect local decision making and subarea allocations (DOF does not forecast city populations). Updated AMBAG forecasts were adopted by the AMBAG Board in February 2004 with County Board of Supervisor members in support.

     2020
    Countywide    		2020
    Unincorporated    		%
    Countywide    		Unincorpated
    Increase
    from 2000    		Dwelling
    Units
    DOF590,700N/A   
    GPU167,417 *  28%67,16521,666
    AMBAG (2004 forecasts)528,312124,06723%23,8157,682
    Difference62,38843,3505%43,35013,984
                   *  Historical share is 25% (Chapter III, p. 45)

    An independent analysis prepared for LandWatch Monterey County and based on parcel level analysis shows that 7,399 dwelling units (DUs) could be built on unincorporated legal lots of record and 3,175 DUs for projects in the "pipeline". These forecasts added to those for unincorporated Fort Ord of 3,000 DUs total 13,574, 5,892 DUs in excess of the AMBAG forecasts for unincorporated areas.

    The GPU includes a policy allowing only one single family unit on existing legal lots of record (p. 201). If this policy is adopted, the DU total would be reduced by 4,263 DUs for a total of 9,311 DUs, over the estimate based on AMBAG's forecasts by 1,629 DUs. Note, these numbers do not include Rancho San Juan or development in the flood plains of Castroville and Pajaro. The GPU provides for significant overdevelopment, which will have significant impacts on those resources identified above. These impacts clearly could be reduced or eliminated by using AMBAG's forecasts while still meeting housing needs with an overage.

  3. The DEIR does not address the impacts allowing agricultural grading on 30% or greater slopes rather than 25% or greater slopes.

  4. Mitigation measures for traffic impacts (p. 5.2-32) are limited to one measure - implementation of a traffic monitoring program. Monitoring is not a legitimate mitigation measure under CEQA. All feasible measures should be addressed and their feasibility determined.

  5. Monitoring is a mitigation measure used throughout the DEIR to address significant impacts. As noted above, it is not a mitigation measures and should be replaced by measures that actually mitigate impacts.

  6. Page 6.1 includes a table identifying "proposed city growth". These forecasts show city growth from 2000 to 2020 of 141,450 while the 2004 AMBAG forecasts show growth for the same period of 103,182. Table 6.1 should be updated to reflect current AMBAG forecasts.

  7. Addressing the cumulative impact of the winery corridors is recommended to be delayed for five years based on the difficulty to accurately predict the number and location of wineries (GPU, p. 266). This is not consistent with CEQA which requires an analysis of a "worst-case" scenario (locations and uses permitted under the general plan), if specific information is not available.

  8. Finally, the GPU provides for Rancho San Juan but does not address its environmental impacts. CEQA does not permit the deferral of analysis to a later day. This omission is a major deficiency in the DEIR.

Thank you for the opportunity to review the document.

Sincerely,
Beverly G. Bean, President