LandWatch submits impressive letter on GPU 5 Final EIR

The final environmental impact report (FEIR) on the general plan update (GPU 5) was released in March 2010. LandWatch immediately went to work studying the massive document and preparing our comment letter. We submitted our letter on May 25th for the Planning Commission to review. There will be more Planning Commission hearings on GPU 5 through the summer, and then the plan goes to the Board of Supervisors. Our main concerns are: erosion and sedimentation, the water supply of the Salinas Valley, the Agriculture Winery Corridor, and traffic.

Here is a summery of our concerns:

1. EROSION AND SEDIMENTATION
   The county seeks to weaken their current slope policy by allowing increased cultivation on steep slopes which causes erosion, sedimentation, and water quality issues. LandWatch submitted extensive comments on erosion and sedimentation on the draft environmental impact report for GPU 5. The county fails to adequately address our concerns in the final EIR. We are concerned because the county does not describe baseline conditions and these existing conditions already constitute significant impacts.
   
   
2. SALINAS VALLEY WATER SUPPLY
   The draft EIR for GPU 5 fails to meet the California Environmental Quality Act (CEQA) requirement to evaluate the adequacy of a basin’s water supply. The county did offer some data in the final EIR for urban and agricultural usage projections, but the data is deeply flawed. It is primarily retrieved from the 2001 Salinas Valley Water Project’s EIR. This EIR uses baseline pumping assumptions from 1995 which understates actual pumping in the Salinas Valley by 44,268 acre feet (one acre foot is ~320,000 gallons) based on the county’s Water Resources Agency data. Furthermore, the Salinas Valley Water Project EIR assumes a net decrease of 1,849 acres of ag land while GPU 5 assumes a net increase of 7,682 acres. The county claims the basin with be in balance by 2030, but the huge increase of acres in ag production will put the basin in severe over-draft.
   
   
3. WINERY CORRIDOR
   Initially the County wanted all development in the Agriculture Winery Corridor (AWC), both agriculture and winery related structures, to be exempt from CEQA review. The County claimed GPU 5’s EIR could be used as the over-arching EIR for myriad future projects in the AWC. The county finally acknowledged in the final EIR for GPU 5 that development in the AWC is subject to CEQA review because the projects are not yet defined and therefore could not be reviewed in GPU 5’s EIR. Because a general plan must be internally consistent, the County may no longer characterize any of the AWC permits as ministerial or exempt from CEQA.
   
   
4. TRAFFIC
   Both the draft EIR and the final EIR for GPU 5 offer incoherent analyses of traffic impacts in Monterey County that will happen as a result of future development. The County relies on traffic impact fee mitigation as the primary way to deal with traffic impacts from future development, but the County fails to address existing deficiencies in service standards which impact fees cannot address. Finally, numerous traffic policies are incomplete and inconsistent.

If you’d like to review the entire LandWatch letter on the final EIR for GPU 5, click on the link below.

052410LWcommentsFinalEIRtoPC.pdf (658K PDF file)

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posted 06.01.10