LandWatch Monterey County is reviewing the latest draft of the General Plan

August 15, 2006

Cosme Padilla, Chair
Monterey County Planning Commission
168 West Alisal Street, 2nd Floor
Salinas, California 93001

Subject: Initial Comments on GPU4

Dear Chair Padilla and Member of the Planning Commission:

LandWatch Monterey County is reviewing the latest draft of the General Plan (GPU4). The purpose of this letter is to submit for your consideration our initial comments on GPU4. GPU4 will urbanize thousands of acres of unincorporated lands where growth is inappropriate. It is a plan for rampant suburban sprawl that will guarantee gridlock, water problems and undermine the County’s economic base. GPU4 fails to provide build-out data, a fundamental requirement in a general plan. This glaring omission results in a plan that fails to correlate the Land Use and Circulation Elements and makes it impossible to integrate meaningful coordination of water supply and demand data in the planning process. Not only does GPU fail to integrate important plan elements, important policies among the elements are dramatically inconsistent. In short, GPU4 is a planning disaster!

LandWatch Monterey County submits the following comments on GPU4:

OVERALL COMMENTS

The General Plan includes no guiding principles or objectives. This is a serious omission, leaving future decisions needed to implement the Plan bereft of guidance, e.g., development of criteria for subdivisions outside Community Areas.

LAND USE ELEMENT

Policy Issues

1. GPU4 is a plan for countywide sprawl. It would:
   
   

   Create seven Community Areas and 14 Rural Centers. Add new vaguely defined areas outside Rural Centers as Rural Center Transition Zones for additional low-density development. Allow 14 property owners to development outside of Community Areas and Rural Centers affecting almost 3,000 acres. Create 16 Special Treatment Areas with significant potential for development. We note this is a significant change from the first draft. Allow for subdivisions outside Community Areas and Rural Center with criteria for development to be determined later. Specifically, allow for major new residential development adjacent to Salinas, Marina and King City. Eliminate maximum parcel densities as shown on the 1982 Area Plan and Land Use maps. Allow commercial and industrial development to leapfrog throughout the county. Allow lot line adjustments smaller than minimum parcel size, thus increasing the potential for more legal lots of record (Policy LU-1.19).

   
   
   
2. GPU4 accommodates special interests by including 30 property owner requests for development and establishing vague and ill-defined regulations. Sixteen of these requests are now included in Special Treatment Areas.
   
   
3. GPU4 does not include any build-out numbers making it impossible to develop transportation and noise elements and address water demand. GPU4 contemplates piecemeal development and infrastructure improvements with no comprehensive approach to water supply or transportation planning.
   
   
4. GPU4 text and maps are inconsistent in their description and classification of land use.
   
   
5. GPU4 accommodates at the very least 27,000 new residential units which is 17,600 more than AMBAG growth forecasts between 2005 and 2030. This means almost 180,000 trips more than the AMBAG Transportation Model and Air Quality Management Plan accommodate. While the lack of available buildout numbers or definitions makes it impossible to estimate the number of additional subdivisions that will also occur in rural areas as a result of cluster subdivisions and minor subdivisions (4 or less lots), it is expected that these overall numbers will be far in excess of even the most inflated population projections.
   
   
6. GPU4 fails to ensure that infrastructure and public services are provided concurrent with new development. While some policies address concurrent provision of adequate roads, water and other public services, GPU4 allows:
   
   

   Minor subdivisions in Rural Center to be developed without adequate infrastructure (Policy LU-2.32). Development in Rural Centers to occur without addressing existing infrastructure inadequacies (Policy LU-2.31). Forty five (45) minute response time for emergency services rather than the 15 minutes required under GPU#3. Wells and septic systems on inadequately sized parcels even in Rural Centers which discourages public systems in these higher density areas. Traffic congestion to increase in areas with good levels of service before mitigation is required.

   
   
   
7. GPU4 would allow the inappropriate urbanization of existing residential neighborhoods. LU-2.38 provides that high density residential and medium density residential areas shall be designated in communities and neighborhoods where density and development patterns of such development exist at the time of adoption of the plan. This suggests that anywhere there is even one small apartment complex, the entire area may be designated at that density.
   
   
8. Coastal plans, although not amended in GPU4, would be affected by GPU4 countywide policies, e.g., reduction of LOS and policies regarding 30% v. 25% slopes. Additionally, 30% of the Castroville Community Area is within the Coastal Zone creating an inconsistency between countywide and Coastal Zone policies.
   
   
9. GPU4 accommodates a significant increase of low-density residential development which does not address affordable housing needs, fails to concentrate limited funding for infrastructure in existing community areas where affordable housing is needed and increases the tax burden on all county residents.
   
   Administrative Process and Consistency with State General Plan Guidelines
   
   
10. General Plan Guidelines (P. 50) require “Local general plans must contain quantifiable standards of building intensity for each land use designation. These standard should define the most intensive use that will be allowed under each designation...". GPU4 fails to:
    
    

    Define intensity for commercial and industrial lands. Define range of densities for Resource Conservation.

    
    
    Specific Comments
    
    
11. P. vii. The Plan does not include amendments to Coastal programs; however, 30 percent of the Castroville Community Area is within the Coastal Zone and implementation of certain General Plan policies (e.g., LOS) will affect the Coastal Zone. These conflicts should be reconciled.
    
    
12. P. LU-1 and P. LU-4, LU-1.2. The Plan indicates that the main vision of this 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 and that premature and scattered development shall be discouraged. Many policies in the Land Use Element and Ag Element are inconsistent with this vision.
    
    
13. P. LU-4, LU-1.4 provides that growth areas shall be designated only where an adequate level of services and facilities such as water, sewerage, fire and police protection, transportation, and schools exist or can be assured concurrent with growth and development and that phasing of development shall be required as necessary in growth areas in order to provide a basis for long-range services and facilities. However, growth areas have been designated without adequate information about transportation and water so this key Policy is not achievable.
    
    
14. P. LU-7, LU-2.4 provides that areas designated for residential use shall be located with convenient access to employment, shopping, recreation, and transportation. Higher density residential areas should be located with convenient access to public transit.
    The Land Use Element is inconsistent with this policy and, therefore, makes this policy infeasible.
    
    
15. P. LU-8, LU-2.10 allows an accessory dwelling unit on a residentially designated lot if “the unit is not intended for sale and may be rented". This language is so vague as to allow units to be sold.
    
    
16. P. LU-9, LU-2.12 allows development of five or more lots outside of Community Areas and Rural centers. This is inconsistent with the main vision of the Land Use Element and Policy LU-1.2 which discourages premature and scattered development.
    
    
17. P. LU-10, LU-2.14 allows for an Affordable Housing Overlay to be developed per Appendix B. However, there is no Appendix B included in the Plan.
    
    
18. 18. P. LU-10, LU-2.16 calls for designating sufficient land in coordination with the cities to locate new housing as close to employment centers as feasible. This is a vague policy without a specific time frame that suggests additional land will be developed for housing within unincorporated areas beyond land designated in the Land Use Element.
    
    
19. P. LU-13, LU-2.32 allows creating four or fewer lots, the first single family home and one accessary units on an existing lot, on-site employee housing and caretaker units, small-scale neighborhood uses, and public/quasi public use to proceed prior to an Infrastructure and Financing Study. This is inconsistent with Policy PS-1.5 (P. PS-4) calling for the provision of infrastructure and public services either prior to or concurrent with development.
    
    
20. P. LU-13, LU-2.37 provides for transition between Rural Centers and adjoining properties which is inconsistent with the main vision of the Land Use Element and Policy LU-1.2 which discourages premature and scattered development.
    
    
21. P. LU-14, LU-2.38 provides that high density residential and medium density residential areas shall be designated in communities and neighborhoods where density and development patterns of such development exist at the time of adoption of the plan. This suggests that anywhere there may be a small apartment complex, the entire area may be designated at that density. This policy should include applicable criteria.
    
    
22. PP. LU-16 and LU-17, LU-4.1 and LU-5.1 indicate the County will designate and establish regulations for commercial and industrial use. This would allow the location of commercial and industrial areas anywhere within unincorporated areas which does not allow impacts of such development to be analyzed .
    
    
23. P. LU-20, LU-9.1, 9.2, and 9.3 would allow development in watershed areas based on subjective and vague criteria.
    
    CIRCULATION ELEMENT
    
    Policy Issues
    
    
24. GPU4 does not include a correlation between the circulation element and the expected growth and development. GPU4 does not include a description of where additional road capacity improvements are needed to accommodate the planned growth or a detailed program to assure such improvements are completed concurrent with land use approvals. Instead GPU4 reduces the quality of life for Monterey County residents. GPU4 reduces LOS from C to D on County roads with D not targeted to be met until 2026. A countywide LOS of D allows traffic in existing areas with LOS A to C (many rural areas) to degrade to LOS D without mitigation and does not address impacts on State highways. A countywide level of service D standard is not appropriate given the diversity in the road level of services throughout the county.
    
    
25. The following policies are inconsistent with the Land Use and/or Circulation Elements:
    
    

    P. Circ-10, C-6.3. “New development should concentrate along major transportation corridors and near cities to make transit services to these areas more feasible" P. LU-7, LU-2.4. “Areas designated for residential use shall be located with convenient access to employment, shopping, recreation, and transportation. Higher density residential areas should be located with convenient access to public transit.

    
    
    
26. Reduction of LOS from C to D means that the level of development being planned under GPU4 cannot meet the higher standard.
    
    Administrative Process and Consistency with State General Plan Guidelines
    
    
27. General Plan Guidelines (P. 51) require that “...the general plan must reflect both the anticipated level of land development (represented in the land use element) and the road system necessary to serve that level (represented in the circulation element). P. 56 states, “In its more concrete and practical application, the correlation requirement in subdivision (d)...is designed to insure that the circulation element will describe, discuss and set forth ‘standards’ and ‘proposals’ respecting any change in demands on the various roadways or transportation facilities as a result of changes in uses of land contemplated in the plan...The statutory correlation requirement is evidently designed in part to prohibit a general plan from calling for unlimited population growth in its land use element without providing in its circulation element, ‘proposals’ for how the transportation needs of the increased population will be met." P. 57 states, “Mandatory circulation element issues as defined in statute are: Major thoroughfares, Transportation routes, Terminal, and Other local public utilities and facilities."
    
    GPU4 does not define level of development in such a way as to identify impacts on existing transportation corridors or address future corridors.
    
    Specific Comments
    
    
28. P. CIRC-4, C-1.1 reduces Level of Service (LOS) for County roads from C to D. This allows LOS in many areas of the county with good levels of service to be reduced to LOS D without mitigation and lets projects proceed without their impacts being addressed. There should be more than one LOS standard for County roads so that existing conditions can at least be maintained.
    
    
29. P. CIRC-5, C-1.2 indicates that LOS D will be achieved by 2026 through Capital Improvement and Financing Plan. In addition to the identification of sources of funding, the Circulation Element should show what highway projects are needed to achieve LOS D by this date.
    
    
30. P.CIRC-6, C-2.5 states that overall land use patterns that reduce the need to travel by automobile shall be encouraged. The Agricultural Element Policy AG-2.1 encourages development of employment centers located in agricultural and rural areas and not in close proximity to urban centers where travel by automobile would be less.
    
    
31. P. CIRC-10, C-6.3 states that new development should concentrate along major transportation corridors and near cities to make transit services to these areas more feasible. The Land Use Element which allows urban development to sprawl throughout unincorporated areas is inconsistent with this policy.
    
    
32. P. CIRC-10, C-6.4 indicates that transit services using public funds shall coordinate service with other transit operators. How the County plans to enforce this policy should be identified.
    
    
33. P. CIRC-11, C-7.3 states that measures to provide for the continued safe operation of airports shall be implemented. Those agencies responsible for implementing and enforcing this should be identified.
    
    OPEN SPACE AND CONSERVATION ELEMENT
    
    Policy Issues
    
    
34. GPU4 fails to protect natural resources such as wildlife corridors, forests, and many biological resources, e.g., existing protection for environmentally sensitive trees is removed. The revised Draft is even more detrimental to resource protection than the March Draft. It eliminates any protection for all habitats, native plants and animal species that are not listed as critical or endangered by State or federal agencies. The overall Plan and area plans should address natural resources.
    
    
35. GPU4 does not include provisions to remain consistent with AMBAG population forecasts, thus jeopardizing air quality.
    
    
36. GPU4 exempts most agricultural activities from land use requirements, e.g., conversion of oak woodlands, water retention facilities, helicopter pads, ecotourism and preparation of a project for market. While policies are intended to protect State and federal endangered or threatened species, protection is questionable when few or no permits are required. GPU4 exempts most agricultural activities from permitting requirements e.g., conversion of oak woodlands, water retention facilities of any size, helicopter pads, ecotourism of any intensity, and preparation of a project for market. While policies are intended to protect State and federal endangered or threatened species, there is no process to ensure this when few or no permits are required. Without permitting, there is also no way for potential impacts to the environment, nearby residents, and to commercial and agricultural operations to be considered by the public and eliminated or mitigated.
    
    
37. The revised draft includes significant changes and improvements to the Archaeological Resources section based on consultation required by SB18.
    
    Administrative Process and Consistency with State General Plan Guidelines
    
    
38. The General Plan Guidelines (P. 76) require that “The discussion of water in the conservation element must be prepared in coordination with water suppliers and include any information on water supply and demand prepared pursuant to 65352.5."
    
    Based on communication with Planning staff, there was no coordination with water suppliers prior to circulating the first draft plan. Thus, the relevant data have not been integrated. Furthermore, since the Draft Plan does not quantify buildout by area, it is unclear how water suppliers can even comment.
    
    
39. Government Code 65564 Implementation requires “Every local open-space plan shall contain an action program consisting of specific programs which the legislative body intends to pursue in implementing its open-space plan". GPU4 does not include an action program.
    
    
40. General Plan Guidelines (P. 76) require an inventory of forest resources and a comprehensive analysis of conservation needs for forests and woodlands and of the interrelationships forests and woodlands have with watersheds.
    
    Forest resources were not inventoried nor were the interrelationships between forests and woodlands and watersheds addressed.
    
    Specific Comments
    
    
41. P. C/OS-1 includes an incomplete list of air monitoring stations in Monterey County. Stations at Moss Landing, Carmel Valley, King City and Salinas should be identified.
    
    
42. P. C/OS-4, OS-1.9 states that development that protects and enhances the County’s scenic qualities shall be encouraged. However, all routine and ongoing agricultural activities are exempt from the viewshed policies. Policy OS-1.9 should be required rather than encouraged.
    
    
43. P. C/OS-4, OS-1.10 eliminates planning conditions on new trails requiring trail easements. This will prevent completion of many important trails.
    
    
44. P. C/OS-6 A buffer zone adjacent to mineral resource areas should be provided, and mineral deposits should be mapped and included in the Plan.
    
    
45. P. C/OS-6. Soils with erosion and landslide potential should be mapped and included in the Plan.
    
    
46. n/a
    
    
47. P. C/0S-7, OS-3.5 provides that routine and ongoing agricultural activities are exempt from permits for slopes greater than 25%, although conversion of previously uncultivated lands on slopes greater than 25% require a permit. This is a significant change from the 1982 Plan and would allow unprecedented development on steep slopes.
    
    
48. P. C/OS-7, OS-3.6 provides that a ministerial permit for development on existing lots of record containing hydrologic hazards or constraints ...shall be established. This makes little sense!
    
    
49. P. C/0S-10, OS-5.3 provides that development shall avoid impacts to State and federally protected plant and animal communities. This policy fails to protect other potentially sensitive species as well as biological diversity as a whole. The policy also is inconsistent with policies in the coastal plans. Further, how this policy would be implemented should be identified since routine and on-going agricultural activities are exempt from permits.
    
    
50. P. C/OS-10, OS-5.5 provides that landowners and developers shall be encouraged to preserve the integrity of existing terrain and native vegetation in visually sensitive areas such as hillsides, ridges, and water sheds and exempts routine and on-going agriculture. This should be a requirement rather than just a vague policy of encouragement.
    
    
51. P. C/OS-17, OS-9.2 provides that development shall be directed toward cities, Community Areas and Rural Centers where energy expended for transportation and provision of services can be minimized. The Land Use Element is inconsistent with this policy.
    
    
52. 52. The Plan should include maps of flood hazard areas, flood plains, and urban fringe and rural-residential areas that are prone to wildland fire hazards.
    
    
53. P. C/OS-18. The Plan fails to include a policy assuring the attainment and maintenance of air quality standards for ozone through maintaining consistency with the Air Quality Management Plan.
    
    SAFETY ELEMENT
    
    Policy Issues
    
    
54. Five areas designated for development are in the 100-year flood plain. The areas include the Lower Carmel Valley Rural Center, Toro Park Rural Center, San Lucas Community Area, San Ardo Rural Center and Bradley Rural Center.
    
    Administrative Process and Consistency with State General Plan Guidelines
    
    
55. General Plan Guidelines (P. 90) require that the safety element identify flood hazard areas and establish policies to avoid unreasonable flood risks. A comprehensive approach should include mapping flood plains; establishing general policies to keep intensive new development out of flood plains.
    
    No maps are included but maps are available (P. PS-8).
    
    
56. General Plan Guidelines (P. 91) require the safety element identify urban fringe and rural-residential areas that are prone to wildland fire hazards.
    
    No maps are included.
    
    
57. General Plan Guidelines (P. 82) require that prior to preparing or revising its safety element, a city or county must consult with the Office of Emergency Services and submit one copy of its draft safety element to the California geological Survey for review.
    
    GPU4 does not include evidence that this was done.
    
    
58. General Plan Guidelines (P. 87) require, “Local governments must analyze and quantify noise levels and the extent of noise exposure through actual measurements or the use of noise modeling. Technical data relating to mobile and point sources must be collected and synthesized into a set of noise control policies and program...Noise level contours must be mapped and the conclusion of the element used as a basis for land use decisions. The element must include implementation measures and possible solution to existing and foreseeable noise problems.... element must include an inventory of current and expected noise exposure (P. 88).
    
    All noise contour maps contain the following disclaimer: “The map is intended for general reference purposes only, and not for site-specific evaluation of on-the-ground conditions. The map is based on known data available at the time it was produced, and there are no assurances as to its accuracy. Field verification of on-site conditions shall prevail over the information on the map: The source of all maps: “Map prepared by: Monterey County ERP/GIS. Data Produced, Jan. 7, 2004. Sources: Roads - Monterey County It/GIS. City Limits - Monterey County ERP/GIS. Planning Areas & Coastal Zones - Monterey County ERP/GIS;. Parcels - Monterey County IT/GIS. Noise Data and Site location - Mestre Greve & Associates." These do not appear to be based on measured data or noise modeling.
    
    Projected Noise Contours for Transportation Corridors were prepared in January 2004 for GPU3. These contours are invalid because they do not reflect the land uses and associated traffic accommodated in GPU4. GPU3 provided for far less development in the rural areas of the county. Additionally, very little development was to occur in Rural Centers, and there were no plans for changing the land use designations for Jefferson and the other new property owner requests. By reopening all the Rural Lands to development and providing for new residential and use designations in many areas, the traffic impacts will be different and the noise impacts will need to be reexamined.
    
    Specific Comments
    
    
59. P. S-7, S-2.12 requiring that all new wastewater treatment facilities...shall be encouraged to use or upgrade to tertiary treatment standards appears to be in the wrong location in the Plan.
    
    
60. P. S-7. The data in the box seems to apply to Goal S-1 rather than S-2.
    
    
61. Figure 35 C depicting raceway noise from Laguna Seca extending to Laureles Grade should be revised to reflect significant noise levels in Carmel Valley.
    
    PUBLIC SERVICES
    
    Policy Issues
    
    
62. GPU4 lacks a correlation between demand for additional water supply to serve expected growth and development and lacks a description of urban water management and supply from water purveyors. The document puts off the issue and states that a program shall be developed at an unspecified time.
    
    
63. GPU4 criteria requiring a long-term water supply for most developments are unclear, e.g., it is not clear whether the term “assured" means the water supply is secured.
    
    
64. GPU4 lacks a description of future solid waste disposal sites and their adequacy to accommodate growth. Development of residential use adjacent to the Marina landfill is now incorporated into the plan.
    
    Administrative Process and Consistency with State General Plan Guidelines
    
    
65. Solid Waste section P. PS-12 and PS 13 does not identify future waste disposal sites as required under Concerned Citizens of Calaveras County v. Board of Supervisors.
    
    
66. P. PS-8, PS-3-1 “Long term water supply" should identify the period of time the water supply should be available. A 20 year period, for example, is less than the life span of most buildings.
    
    
67. P. PS-8, PS-3.3 Criteria for determining a long term sustainable water supply should include a cumulative assessment. The policy should also address how water projects which are proposed but not yet built will be addressed.
    
    
68. P. PS-12, PS-6-4 provides for buffer zones around solid waste facilities. A buffer zone of at least 400 feet should be required. Additionally, the Plan does not identify future waste disposal sites as required.
    
    
69. P. PS-19. While the role of the Historic Resources Review Board is acknowledge, that of the Land Use Advisory Committees is not addressed anywhere in the Plan.
    
    AGRICULTURAL ELEMENT
    
    Policy Issues
    
    
70. GPU4 allows for excessive and environmentally destructive agriculture activities by exempting them from numerous natural resources, conservation and open space policies, e.g., removes limits on steep slope conversion and allows land conversion and cultivation on steep slopes over 25% with a permit.
    
    
71. GPU4 does not protect farmland. Policy AG-1.3 allows subdivisions on all farmland if it can be demonstrated that subdivisions would not be detrimental to the agricultural viability “of the adjoining parcels".
72. GPU4 only “considers" rather than enforces state laws regulating school buffers, pesticide setbacks, and other controls.
    
    Specific Comments
    
    
73. P. AG-2, AG-1.2c states that applicable state and local laws regulating school buffers, pesticide setbacks, and other controls shall be “considered" rather than enforced.
    
    
74. P. AG-3, AG-1.2 allows subdivisions on any and all farmland as long as “adjacent agricultural viability is protected or in accordance with policies of a specific plan." This is inconsistent with the promotion of the “long-term conservation of productive and potentially productive agricultural land" (Goal AG-1).
    
    
75. P. AG-5, AG-3.1 provides that routine and ongoing agricultural activities that may have significant impacts are subject to a greater level of review. The policy should identify criteria for determining significant impacts and the time during the planning process this will be addressed.
    
    
76. P. AG-6, AG-3.3 provides that routine and ongoing agricultural activities may be exempt from applicable general plan policies, although such activities may remain subject to applicable federal, state and county permit requirements to be established by ordinance. The policy should identify criteria for determining exemptions and the time during the planning process this will be addressed. Additionally, the policy provides that activities may be subject to federal and State permit requirements. The County does not have authority to exempt activities from federal and State permit requirements.
    
    
77. P. AG-6, AG-3.3 identifies routine and ongoing agricultural activities and lists “preparation of project for market". This should be defined. Additionally, “an activity listed in this section conducted at night; and, other uses of similar character, density, and intensity as to those listed in this policy" is listed. The policy should identify criteria for determining this activity and the time during the planning process this will be addressed.
    
    
78. P. AG-6, AG-3.3 identifies conversion of any land zoned agricultural as a routine and ongoing agricultural activity. This would allow the wholesale conversion of oak woodlands and conversion of land from relatively low to higher water use without a permit, even though these activities could have significant environmental impacts.
    
    
79. P. AG-6, AG-3.3 identifies ecotourism and water retention facilities as routine and ongoing agricultural activities. This would allow large and potentially destructive group activities in sensitive areas and large water retention facilities such as that built by Gallo Winery (350 AF) to proceed without a permit.
    
    
80. P. AG-6, AG-3.3. Overall, without a permit review process for many of the activities listed in this policy, what is the mechanism to draw in State and federal agencies when, for example, endangered or threatened species are involved or when the Division of Dam Safety needs to review a water retention facility?
    
    
81. P. AG-6, AG 3.3. Includes any activity recognized as compatible under the Williamson Act as “Routine and Ongoing". The Williamson Act is intended to provide property tax relief for agriculture and is not intended to provide carte blanche approval of any agricultural related uses. The Board of Supervisors have previously recognized many uses including aircraft landing strips, disposal sites for oil field wastes, and large agricultural processing plants and offices as being included under Williamson Act tax relief. However, these uses should not be exempt from public review prior to receiving a development permit.
    
    
82. The Agricultural Element fails to protect organic farming and ranching practices and is focused on policies to protect corporate farming. The element should be revised to address organic farming issues including protection from genetically-modified agricultural research or operations.
    
    AREA PLANS IN GENERAL
    
    Policy Issue
    
    
83. GPU4 would change the rural character of many area plans by allowing Rural Centers to develop in a “semi-rural" character. This contrasts with many existing area plans which contain goals of preserving the “rural character" of the overall area.
    
    Administrative Process and Consistency with State General Plan Guidelines
    
    
84. General Plan Guidelines require that general plans be internally consistent. The Area Plans are inconsistent with the following policies:
    
    

    P. LU-1. The main vision of this element is to create a general framework that encourages growth within or near developed/developing areas in order to reduce impacts to agricultural. P. LU-4. LU-1.2. Premature and scattered development shall be discouraged. P. LU-4, LU-1.4. Growth areas shall be designated only where an adequate level of services and facilities such as water, sewerage, fire and policy protection, transportation, and schools exist or can be assured concurrent with growth and development. Phasing of development shall be required as necessary in growth areas in order to provide a basis for long-range services and facilities. P. LU-5, LU-11.11. Outside of cities, Community Areas, Rural Centers and areas where urban services…exist, only low to very low residential density shall be allowed. P. LU-7, LU-2.4. Areas designated for residential use shall be located with convenient access to employment, shopping, recreation, and transportation. Higher density density residential areas should be located with convenient access to public transit. P. CIRC-4, C-1.2. LOS D to be achieved by 2026 through Capital Improvement and Financing Plans. P. CIRC-10, C-6.3. New development should concentrate along major transportation corridors and near cities to make transit services to these areas more feasible. P. C/OS-4, OS-1.9. Development that protects and enhances the County’s scenic qualities shall be encouraged. All routine and ongoing agricultural activities are exempt from the viewshed policies of this plan. P. C/OS-17, OS-9.2. Development shall be directed toward cities, Community Areas, and Rural Centers where energy expended for transportation and provision of services can be minimized. P. PS-7, PS-2.3. Development that is subject to a discretionary permit and that intensified water usage on a site that is located in an area that does not have a proven long term sustainable water supply shall not be allowed.

    
    
    Specific Comments
    
    
85. GPU4 should establish the uses, intensity and density within Special Treatment Areas. Without this information, “white holes" would be created in the land use map. Both the Plan and DEIR need to be specific about each of the Areas.
    
    AGRICULTURAL WINERY CORRIDOR PLAN
    
    Policy Issues
    
    
86. GPU4 eliminates public participation in the review of 76 wineries, tasting rooms, B&B’s, restaurants and delicatessens in the wine corridor by exempting them from CEQA project level review.
    
    
87. The Agriculture and Winery Corridor Plan creates a ministerial process for wineries, artisan wineries and tasting room. It is likely that ministerial permits are inappropriate for most wineries and tasting rooms under CEQA, and that some public approval process and a discretionary permit will be required by CEQA instead. Creating a ministerial process for many of these activities will shift the CEQA to single purpose Responsible Agencies such as RWQCB and MBUAPCD which would complicate and prolong the environment review process for applicants.
    
    
88. The potential for future simultaneous multiple events at wineries, tasting rooms and B&Bs need to be determined so that appropriate policies are included.
    
    
89. Traffic and safety issues associated with increased numbers of wineries, tasting rooms and other visitor-serving facilities, mostly serving alcohol and all using the same narrow two lane roads to provide access and egress to facilities largely without coordination and at much the same time period and on weekends throughout the year must be addressed.
    
    
90. It appears that additional traffic generated from new wineries, B&Bs, tasting rooms, and delis’ would create a Level of Service in excess of adopted standards on the narrow and sharp curves of the rural roadway systems that exist along the proposed corridors. The Wine Corridor Plan should identify how much additional traffic is to be expected with implementation of the Plan.
    
    
91. There is no identification of means to fund circulation improvements and other road improvements such as increased roadway base and curve straightening that may be needed to serve additional traffic, including heavy trucks, generated by additional wineries, B&Bs, and tasting rooms. The 2003 County Department of Public Work’s Project Study of Wine Corridor River Road prepared by Sandis Humber Jones, consultant, estimated that safety and storm drain construction improvements and engineering for River Road would total $126 million dollars. Theses improvement have not been identified in any capital improvement plans. How will needed transportation and drainage improvements resulting from planned development such as the Winey Corridor and allowed residential uses of GPU4 be funded?
    
    ADMINISTRATION
    
    Policy Issues
    
    
92. GPU4 requires over 50 programs to implement the GP and/or mitigate impacts which means GPU4 is not useable until many of these studies are completed. The time frame, implementing agencies and sources of funding for these should be identified.

Comments on the Draft EIR will be submitted under separate cover. Thank you for your consideration.

Sincerely,

Chris Fitz, Executive Director
LandWatch Monterey County

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posted 08.17.06