LWV

March 29, 2006

Alana Knaster, Interim Director
Monterey County Planning and Building Inspection Department
168 West Alisal St., 2nd Floor
Salinas, CA 93901

Subject: Re-circulated Portion of the Draft REIR for the September Ranch Subdivision Project

Dear Ms. Knaster:

The League of Women Voters of the Monterey Peninsula appreciates the opportunity to comment on the
re-circulated portion of the draft Revised Environmental Impact Report (REIR) for the September Ranch Subdivision Project. This project is for 109 residential units, including 15 inclusionary units in Carmel Valley.

  1. The REIR does not respond to the following comments made by the League on the RDEIR in a letter dated February 4, 2005:

    • 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 overlaid on photographs of the project. (Note: The issue of the project's impact on the viewshed from Carmel Valley Road was a matter of significant debate during the site visit of the CVLUA and Planning Commission.)

    • 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 affordable housing dispersed throughout the project. (Note: While some of the alternatives address dispersion of inclusionary housing throughout the project, no alternative in the REIR addresses clustered development outside of the Monterey Pine forest.)

    • The project's traffic impacts would in part be mitigated by the payment of impact fees to several significant highway 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.

  2. The REIR does not address whether or not the farm house is historic and, if so, the requirements for its preservation.

  3. The Water Supply and Availability analysis is not conclusive. The findings of this section are based on uncertain data and information, particularly in reference to the connectivity between the September Ranch and Carmel Valley aquifers. The data do not support the finding that the project will not have a significant impact on water supply in the Carmel Valley.

  4. The Biological Resources analysis is confusing. References to the Forest Management Plan are inconsistent, i.e., in some cases the Plan is referred to as final; in other cases the REIR indicates the Plan will be submitted later; in other cases the Plan is referenced as a Forest Mitigation and Monitoring Plan. The Forest Management Plan, the Open Space Management Plan, and the Grassland Habitat Management Plan are not included in the REIR. Since these plans are integral to mitigating the project's impacts on biological resources, their deferral to a later date is not consistent with CEQA requirements. These plans should be circulated for public review prior to the project's consideration by the Planning Commission and other decision- making bodies.

  5. The Requirements of the Oak Woodlands Conservation Act (PRC Section 21083.4) should be addressed.

  6. Finally, we understand that the REIR will not be sent to the Carmel Valley Land Use Advisory Committee (CVLUAC) for consideration. We strongly recommend that residents of Carmel Valley be given the opportunity to comment at a local hearing before the CVLUAC.

Thank you for your consideration.

Sincerely,
     Marilyn Maxner, President
     League of Women Voters of the Monterey Peninsula