LWV

October 11, 2004

Taven M. Kinison Brown, Project Planner
Monterey County Planning & Building Inspection Department
2620 1st Avenue
Marina, CA 93933

Re:  Mitigated Negative Declaration
        of Crossroads Shopping Village Remodel and Expansion

Dear Mr. Kinison Brown:

The League of Women Voters of the Monterey Peninsula has reviewed the Initial Study and Mitigated Negative Declaration (MND) for the Crossroads Shopping Village Remodel and recommends that an environmental impact report be prepared. The project has the potential to have significant impacts on traffic, flooding, air quality, and the levee and conflicts with policies in the Carmel Valley Master Plan. These issues require preparation of an EIR. Additionally, since the MND does not include all mitigation measures needed to address impacts, a MND is an inappropriate document under CEQA Guidelines for this project. Our specific comments follow:

  1. Regarding traffic, there is a conflict between traffic reports prepared for this project and those for the affordable housing project proposed by the Lombardo Land Group (i.e., LOS differs for the intersection at Carmel Rancho Blvd. and Rio Road).
     
  2. Regarding flood control, there are conflicting expert reports on mitigation measures needed to address potential flood control problems (i.e., reports prepared for CSA #50 and the proposed project).
     
  3. The project would require 2,500 to 3,000 daily heavy duty truck trips for bringing in the fill and hauling out the demolition material. The impact on traffic and of diesel exhaust on surrounding neighbors has not been evaluated.
     
  4. The project would require excavating portions of the levee. The excavation could unstablize the levee with potential significant impacts.
     
  5. The project is inconsistent with the following Carmel Valley Master Plan policies:
    • Policy 7.2.1.3 - landscaping to soften the visual impact of new development
    • Policy 7.2.2.5 - the removal of native trees
    • Policy 16.2.3.1 - development within 200 feet of the nominal Carmel River bank
    • Policy 16.2.11 - Flood Mitigation Project for the Lower Carmel River and restriction of development within area until a project has been developed
    • Policy 26.1.26 - visual compatibility
    • Policy 28.1.12 - landscaping of commercial projects
    • Policy 39.1.6 - construction of the Hatton Canyon Freeway
    • Policy 39.3.2.1 - adequate streets and highways
       
  6. Finally, all the mitigation measures needed to address project impacts have not been identified (i.e., the document includes requests of the Department of Fish and Game, the Army Corps of Engineers and the Coastal Commission for recommendations regarding mitigation measures). This is inconsistent with CEQA Guidelines which require that all mitigation measures be agreed to by the applicant prior to the publication of a MND.

Thank you for your consideration.

Sincerely,

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