SUBJECT: Revised Draft EIR on the September Ranch Project
February 3, 2005
Alana Knaster
Monterey County Planning and Building Inspection Department
2620 First Avenue
Marina, CA 93933
Dear Ms. Knaster:
The League of Women Voters of the Monterey Peninsula submits the following comments on the Revised Draft EIR (RDEIR) on the September Ranch project for your consideration:
The RDEIR does not address the moratorium on new subdivisions in Carmel Valley nor Carmel Valley Master Plan Policy 39.1.6 which requires the Board to limit further development until the Hatton Canyon Freeway is under construction. The EIR should be revised to address these policies.
The RDEIR finds that the project would reduce overall water demand because the current 99 acre feet per year used to irrigate the pasture would be offset by using reclaimed water. However, the amount of wastewater available for reclamation is only 39 acre feet per year. his discrepancy should be addressed. Additionally, no wastewater for reclamation would be available for on-site use if the project is required to hook-up to the Carmel Valley Waste Treatment Plant.
The project's traffic impacts would in part be mitigated by the payment of impacts fees to several significant projects. Several of the projects are not on the 1995 or current list of Carmel Valley Road Improvements. If the projects are not on the mitigation fee list or the timing for project implementation is greater than five years, contribution of mitigation fees cannot be considered adequate mitigation for traffic impacts. Additionally, while several intersections are projected to operate at unacceptable levels under the cumulative impact analysis for 2025, the RDEIR finds that the project would not have a significant cumulative traffic impact. The document should be revised to show a significant cumulative impact on traffic.
The project would result in the removal of 890 coast live oaks and 2,692 Monterey pines through roadway development. These numbers do not include damage to trees from mechanical clearing or those which would be removed through lot development. One of the proposed mitigation measures would require replacement of Monterey pine forest and coast live oak forest acreage on a 3-1 ratio, based on size of trees removed. This mitigation measure requires clarification in terms of defining "based on size of trees removed" and the availability of replacement acreage--up to 162 acres.
The removal of over 3,000 mature trees should be identified as a significant impact. Additionally, proposed project tree removal along with the removal of over 25,000 additional trees throughout Monterey County should be identified as a significant cumulative impact.
The RDEIR states that fragmentation of the Monterey pine forest will increase the potential for pitch canker and other diseases and that there are no proven methods available to address this problem. Yet, the document finds that after mitigation, the impacts would be reduced to less than significant. Based on the findings regarding the lack of methods to address this problem, the impact on forest fragmentation should be found to be significant.
The RDEIR finds that the 15 inclusionary housing units to be located along Carmel Valley Road would not adversely affect the viewshed due to proposed design features and topography. This finding should be substantiated with drawings of the proposed project overlayed on photographs of the project site.
An Alternative that addresses the current inclusionary housing ordinance, work force housing and the significant impact on vegetation should be included in the final environmental document. Specifically, inclusionary housing should be increased to 20%. The alternative should include higher density, clustered development outside of the Monterey Pine forest with the affordable housing dispersed throughout the project.
Thank you for your consideration.
Sincerely,
Nancy Green
Copresident, League of Women Voters of the Monterey Peninsula
