LWVMP and LWVSV

Subject: Comments on the 4th Update to the Monterey County General Plan (GPU#4), including the Greater Monterey Peninsula Area Plan

August 31, 2006

Philomene Smith, Chair
Greater Monterey Peninsula Land Use Advisory Committee
1314 Josselyn Canyon Road
Monterey, CA 93940

Dear Ms. Smith and Members of the GMPLUAC:

The League of Women Voters of the Monterey Peninsula has reviewed the 4th Update to the Monterey County General Plan (GPU#4), including the Greater Monterey Peninsula Area Plan. We would like to submit the following comments for your consideration:

  1. According to GPU#4, “The main vision of this [Land Use] Element is to create a general framework that encourages growth within or near developed/developing areas in order to reduce impacts to agricultural production, natural resources, or public services. Areas where development would be encouraged include incorporated cities and designated community areas where existing services are available...”. This vision is implemented through such Land Use Policies as LU-1.2 ( “Premature and scattered development shall be discouraged”) and LU-2.15 (“The majority of urban growth should be channeled into cities and their spheres of influence with an emphasis on redevelopment and infill”).

    However, proposed residential development adjacent to the City of Marina is inconsistent with this vision and many of the countywide policies. Property Owner Request #13 (POR #13) is for two parcels totaling 504 acres, with one parcel on the eastern boundary of the City of Marina and one parcel surrounding the Dole Plant area and adjacent to the Monterey Regional Waste Management facility. The parcels are currently designated Farmland with 1 unit per 40 acres and Permanent Grazing with 10 to 160 acres minimum. The proposed designation is Low Density Residential with 1-5 acres per unit with a recommendation of 2.5 acres per unit resulting in about 200 units. This development is clearly inconsistent with the vision statement, not only because it is not a Community Area nor adjacent to a city, but because it is clearly premature, represents scattered development, and undermines the City of Marina’s Urban Growth Boundary. Furthermore, it is an incompatible land use adjacent to a landfill. POR #13 should be deleted.

  2. The existing Area Plan includes maximum densities on the Area Plan maps. These maximum densities have been eliminated. Thus, allowed densities have been increased on thousands of acres.

    1. About 23,000 acres of Resource Conservation areas in the Santa Lucia range with a maximum density of one unit per 40 acres and 160 acres would be designated as Resource Conservation with no density range. Hundreds of acres of Permanent Grazing in the Santa Lucia range with a maximum density of one unit per 160 acres would have a density of one unit per 10 to 160 acres.

    2. About 5,000 additional acres of Resource Conservation are located throughout the Planning Area. As noted above, there is no density range for this category.


    The overall Plan should address whether or not previously approved Comprehensive Development Plans such as Monterra would be held to the approved densities or be allowed to increase density based on revised density ranges.

  3. Hundreds of acres are designated as Urban Reserve, but there is no description of this proposed land use in the text of the Plan. Areas north and east of Marina currently designated as Urban Reserve with a 40 acre minimum would be changed to Urban Reserve Permanent Grazing 10-160 acre minimum. Hundreds ofacres in the triangle between East Garrison and Reservation Road would also be changed from public/quasi-public (Fort Ord) to Urban Reserve. Large areas across from the Monterey Peninsula Airport currently designated as Urban Reserve allowing 1 unit per 10 acres would be designated Urban Reserve with a range of 1 unit per 5 to 40 acres. These changes would allow more low density, urban sprawl throughout the Planning Area and should be amended.

  4. Proposed Policy GMP-3.11 provides that “riding and hiking trails should be acquired and developed with the intent of creating a coordinated, area-wide trails system. In supporting a coordinated area-wide trails system, the highest priority should be given to establishing the following trails systems:

    1. a permanent riding and hiking trail from Roach Canyon to Jacks PeakPark;

    2. an easterly ridgeline trail from Jacks Peak Park to Laureles Grade;

    3. a major trail link which generally traverses in a southeasterly direction from Carmel Valley and forms a trail connection with the Los Padres National Forest trail system; and

    4. a connection trail from the Jacks Peak Park/Laureles Grade ridgeline trail to the entrance of Laguna Seca Recreation Area to be used as a point of departure to Toro Regional Park along Highway 68.”

    However, countywide Policy OS-1.10 (C/OS-4) would eliminate planning conditions on new trails requiring trail easement. This policy would adversely affect completion of the riding and hiking trails identified above and should be amended.

  5. Existing Policy 5.1.3 (GMP) has been excluded from the Area Plan. It provides that “Monterey County will encourage development projects to be served by water from public utilities or mutual water companies. If this is not possible, the County shall consider the cumulative effects of the development’s water use on wildlife, fish and plant communities and the supply available to existing users.” Presumably this policy was excluded because it is covered by PS-3.1 in the overall Plan which provides, ”No new development, except for the first single family dwelling and nonhabitable accessory uses on an existing lot of record, for which a discretionary permit is required shall be approved without proof, based on specific findings and supported by evidence, that there is a long term, sustainable water supply, both in quality and quantity, to serve the development.” PS-3.1 does not address cumulative impacts, does not define “long-term water supply,” and does not address if the supply must be available at the time of development. Either Existing Policy 5.1.3 (GMP) should be retained or PS-3.1 should be amended to address its deficiencies.

  6. GMP-3.3 excludes the following provision in current Policy 11.1.6 (GMP) which states, “Environmentally sensitive areas as shown on the Greater Monterey Peninsula Environmentally Sensitive Area Map should be preserved as open space. When an entire parcel cannot be developed because of this policy a low intensity, clustered development may be approved. However, the development should be located on those portions of the land least biologically significant.” We recommend that GMP-3.3 be amended to incorporate Policy 11.1.6 (GMP).

  7. The Indigenous Monterey Pine Forest is not protected in either the GMP Area Plan or the overall General Plan. We recommend that policy GMP-3.5 be amendedto protect this biological resource.

  8. Neither the overall Plan nor the Area Plan identifies additional road capacity improvements that are needed to accommodate the planned growth or a detailed program assuring that necessary improvements are completed concurrently with land use approvals. The Circulation Element should be revised to show needed road improvements and identify how these improvements will be funded.

  9. We note that a Rural Center is identified in the Del Monte Forest. This Rural Center should be deleted because the overall General Plan excludes land within the Coastal zone (P. 14).

  10. Finally, the overall Plan and Area Plan should identify the undeveloped slopes over 25% that could be built on or cultivated based on the new slope policy.

Thank you for your consideration.

Sincerely,
     Marilyn Maxner, President

Cc: Mike Novo, Interim Planning Director
     Monterey County Planning Commission