LWV

October 6, 2004

Mike Novo
Monterey County Planning and Building Inspection
2620 1st Avenue
Monterey, CA 93933

RE: East Garrison Specific Plan and Draft Subsequent EIR

Dear Mr. Novo:

The League of Women Voters of the Monterey Peninsula appreciates the opportunity to comment on the two documents. Our specific comments follow:

Draft Subsequent EIR

  1. The DSEIR fails to respond to the Water Code and Subdivision Map Act (SB 221 and SB 610) which require that the environmental document for a project of 500 residential units or more include a water supply assessment prepared by the water supplier. This is the second major document where the County has not addressed the requirements, the first being the Rancho San Juan EIR. Under SB 610, the assessment must be completed prior to the issuance of a draft EIR. Specifically, the Government Code requires among other things that the agency responsible for the water system verify a sufficient water supply for the project which is defined as "total water supplies available during normal, single-dry, and multiple-dry years within a 20-year projection that will meet the projected demand associated with the proposed subdivision, in addition to existing and planned future uses, including, but not limited to, agricultural and industrial uses...". (See California Department of Water Resources Guidebook for Senate Bills 610 and 221).
     
  2. The project would have a water demand of 470 acre-feet per year. According to the DSEIR (p.4.11-16), "New facilities must be constructed within and outside the project site in order to provide potable water service and water for fire protection... if MCWD proceeds with implementation of its Water Master Plan within the time frame identified in their Capital Improvement Program..., there would be sufficient water storage capacity to meet both residential and commercial fire flow/fire suppression requirements for project buildout...". A proposed mitigation measure (p. 4.11-19) would require "...Prior to issuance of the first building permit for commercial development..., the project applicant shall be required to obtain written verification from MCWD that sufficient excess storage in Zone C...is available to accommodate the commercial fire flow suppression requirements associated with commercial development...". Under this measure residential development could be constructed without the accompanying commercial development and other mixed uses which are central to the project's objectives, resulting in unaccounted for environmental impacts.
     
  3. The DSEIR states (p. 2-2) that the development would remove 53 acres of oak woodland and 38 acres of oak savannah. On p. 4.7-23 it states the project would result in removal of about 44 acres of oak woodland, 41 acres of oak savanna, 40 acres of grassland, 2 acres of coastal scrub in addition to 5,100 oak trees in varying sizes spread throughout the habitat. These discrepancies should be addressed.
     
  4. The DSEIR finds that removal of these resources is insignificant because it would be offset by equivalent or better gains in kind at Parker Flats - preservation of about 249 acres of oak woodland, 196 acres of maritime chaparral and 18 acres of grassland habitats that were previously slated for development in the HMP, i.e., "Implementation of all of the conditions in the LSA (Land Swap Assessment), including designation of habitat reserve areas at Parker Flats, effectively mitigates for habitat losses that will occur with development at East Garrison" (p. 4.7-24).
     
    CEQA requires that the impact be compared to the existing environment, not to something which might or could have happened. Meeting requirements of the HMP or LSA does not meet CEQA requirements. By any measure, removal of 5,100 oaks trees and the other identified resources is a significant impact, and all feasible mitigation measures must be addressed.
     
  5. As identified in the DSEIR, the project would have a significant impact on regional air quality. However, all feasible mitigation measures have not been addressed including mitigating off-site sources, purchasing clean school buses, etc.

Specific Plan

  1. In its study of the reuse of Fort Ord in 1992, the League supported, among other policies, development adjacent to existing urban areas. The project would not be adjacent to an existing urban area and would result in leap-frog development exacerbating urban sprawl, traffic congestion, and air pollution. While many of the proposed land uses are consistent with "smart growth" and sustainable communities, (e.g., all residences would be located within a quarter-mile of a bus stop and mixed-uses would encourage use of alternative forms of transportation), these benefits are substantially negated by the project's location outside an existing urban area.
     
  2. The project would generate approximately 14,000 daily vehicle trips which will create or add to existing unacceptable levels of service at some intersections (i.e., Reservation Road/Davis Road) and roadways (i.e., Portola Drive and SR 68, and SR 183 between Cooper Road and Espinosa Road). The Cumulative Traffic Impacts analysis (p. 5-17) shows the roadway segments listed below are expected to continue to operate at unacceptable levels of service.
     
    • Blanco Road between Salinas River Bridge and Reservation Road
    • Blanco Road between Salinas River Bridge and Davis Road
    • David Road between Ambrose and Central Avenue
    • David Road between Reservation Road and Salinas Ribder Bridge
    • Reservation Road between Main Project access and Watkins Gate
    • SR 1 between Light Fighter Interchange and Fremont Interchange
    • Inter-Garrison Road between Abrams and 7th Avenue
    • Inter-Garrison Road between West Camp Road and Abrams.

    The DSEIR states construction of an additional roadway lane would mitigate impacts to these roadways; however, as stated in the document there are no funds in the foreseeable future to address these significant and unavoidable impacts.

  3. Twenty percent of the residential units would be dedicated to inclusionary housing. We think that 40 percent of the residential units should be available to meet inclusionary housing requirements as well as the housing needs of the local work force. Providing up to 40 percent affordable housing units is economically viable for the developer. The opportunity to address some of Monterey County's housing needs at Fort Ord should not be lost.
     
  4. The project includes proposed revisions to County's Title 21-Standards for Ridgeline Development. It is proposed that the following wording be added to Ridgeline development criteria: "This policy shall not apply in areas governed by Specific Plans. Each Specific Plan shall address viewshed issues as part of the plan's regulations." (p. 3-29). This project should not be allowed to violate a long established policy that has helped protect the county's viewshed over the years.
     
  5. Finally, the impacts identified above support the need for an alternative that is adjacent to and integrated into an existing urban area where urban services are more readily available, travel can be reduced, air quality mitigated and biological resources protected.

Thank you for your consideration.

Sincerely,

Sandy Smith, Secretary
League of Women Voters of the Monterey Peninsula