LWV

February 23, 2005

Butch Lindley, Chair
Monterey County Board of Supervisors
240 Church Street
Salinas, CA 93901

Dear Chair Lindley and Members of the Board of Supervisors:

The League of Women Voters of the Monterey Peninsula submits the following comments on the Final Environmental Impact Report (EIR) and the Pebble Beach Company's Del Monte Forest Preservation and Development Plan:

  1. Forest Habitat: The project includes removal of 130 acres (p.3.3-22) to 150 acres (Summary) of Monterey Pines, approximately 7% of the remaining undeveloped Monterey Pine forest in the Del Monte Forest and 1.6% of the remaining known undeveloped pine forests in the Monterey region. Cumulative development would result in the loss of 1,600 acres or 17% of the extant forest in the Monterey region. The Final EIR finds the loss of native pine forests to be significant at the project level and cumulatively but that mitigation measures would reduce the impacts to less than significant. Proposed mitigation calls for retaining the remaining native stands and replanting areas with native pines which would take decades to mature. Further, there is no assurance that the proposed regional forest conservation plan to mitigate cumulative impacts would be implemented given the history of prior implementation of measures for development in the Del Monte Forest, e.g., measures related to the Spanish Bay project. We think that project level and cumulative impacts on the Monterey Pine Forest would be significant even with mitigation.

    The significant loss of Monterey Pines is also inconsistent with the policies included in the Natural Resource and Visual Resource Elements of the current Local Coastal Plan (LCP) as listed below. We note that these policies were not revised by Measure A and that consistency is required by the Coastal Act:

    1. Preservation of the unique forests for their esthetic value is a concern to both residents and visitors to the area;
    2. Preservation of the unusual habitats for their botanical value to the scientific community is of paramount importance (Note, this predates the present threat of pitch canker);
    3. Further development in the Del Monte Forest must be responsive to the delicate balance of climate, soils and vegetation which has developed over the centuries;
    4. Significant "tree removal" is inappropriate in such areas;
    5. The natural forested character of the Del Monte Forest shall to the maximum extent feasible be retained;
    6. Where LCP objectives conflict, preference should be given to long-term protections of forest resources.

    The California Coastal Commission staff has recently recommended measures to more adequately protect the Monterey Pine forest by restoring its designation as environmentally sensitive habitat and restricting wholesale cutting of the trees in the Del Monte Forest. These recommendations should be addressed.

  2. Water: The FEIR recommends that the applicant complete the upgrade of the Reclamation Project prior to development and that the maximum amount of water to be transferred to other uses stays within the remaining entitlement total. The Company intends to finance the upgrade through the private sale of 120 AF of its "entitlement water", leaving 235 AF for new development. However, projected demand is 286.8 AF, creating a deficit of 50 AF. Proposed mitigation measures would affect the feasibility of the overall development and would require project redesign.

  3. Construction activity: Removal of trees and construction of new roads and buildings would significantly affect the existing residential community, i.e., major dislocation of travel, increases in noise levels and air pollution during construction.

  4. Future Environment: Aside from the environmental costs associated with construction of this magnitude, the transformation of the Lodge and Spanish Bay areas would be significant. In lieu of the prevailing rural ambience, the substantial increase in visitor units, building and parking structures would result in two vastly enlarged resort hubs, generating major increases in traffic congestion and noise. A new 18 hole golf course, the eighth in the Forest, would replace the equestrian center and the remaining contiguous forest requiring major realignment of Stevenson Road. The 24 "golf cottages" would intrude into the remnant sand dunes which are identified as environmentally sensitive habitat and protected under the LCP. While the economic benefits to the Company are addressed, no account is taken of potential negative impacts of increased commercialism on residential property values nor of the irreplaceable loss of the environmental quality of life through the degradation of the forest habitat.

  5. Prior Mitigation: The development would require rescinding the easement held by the Coastal Commission protecting the forest bounded by Huckleberry Hill, Morris Exist Drive and Highway 68. This was mitigation for the Spanish Bay project. Removal of this easement would significantly undermine the planning process as envisioned under the Coastal Act.

Finally, the League is on record as opposing the decision to complete the hearing process on the Development Plan before submitting Measure A to the Coastal Commission for certification. The County's refusal to comply with the Commission's repeated requests to honor the process is not in the interest of the general public and could invite more costly litigation in the near future.

Thank you for your consideration.

Sincerely,
               Nancy Green, Copresident