LandWatch Letter Objecting to Certification of EIR and Adoption of General Plan

November 2, 2000

Mayor Jim Perrine and Council Members
Marina City Council
City Hall
211 Hillcrest Avenue
Marina, CA 93933

RE: Approval of General Plan and Certification of Final EIR

Dear Mayor Perrine and Council Members:

This letter is to make a formal protest, for the record, of your proposal to certify a Final Environmental Impact Report for the proposed Marina General Plan, and thereafter to approve that proposed General Plan.

On August 2, 2000, LandWatch submitted an extensive comment letter on the proposed General Plan. With very few exceptions, your Council chose not even to analyze or comment on the points we made, as you carried out your deliberations. It is certainly your prerogative to ignore comments and testimony from interested parties, but we believe that the General Plan before you on November 2, 2000 would better achieve the objectives articulated by the Council, and outlined in the proposed General Plan, by incorporating many of our comments. We also note that the Council, by incorporating a proposed extension of California Avenue across a Natural Reserve Area, contrary to the recommendation of the Marina Planning Commission, is apparently proposing to adopt a Plan that is inconsistent with the Fort Ord Reuse Authority Plan. We urge you again to delete this inconsistent proposal from the General Plan, and to reconfigure the General Plan accordingly.

We do not believe that the Final EIR has adequately responded to the comments submitted on the Draft EIR, including the extensive comments we submitted. Water and traffic impacts have been inadequately considered, and we particularly note that you have absolutely failed to undertake a visual analysis of the impact of the development of the Armstrong Ranch. The Draft EIR identified the degradation of visual resources as a major unmitigated environmental impact of the proposed General Plan. As we noted in our comments on the Draft EIR, we believe that CEQA requires your Council to understand the visual impacts of your proposed action, prior to acting. The public, too, has the right to visualize these impacts. It would certainly be feasible for you to prepare a computerized simulation, accurately showing the impact that the development proposed for the Armstrong Ranch would have on the extraordinary visual resources associated with that land in its current condition.

CEQA requires that the environmental documents prepared by a Lead Agency must really provide "information" about possible impacts--for both decision makers and the public--and you have chosen not to provide that information about the impact of the proposed General Plan on visual resources. It is, in fact, feasible to produce the kind of simulation our comments called for--witness the attached campaign mailer. The visualization included in the Marina 2020 Vision Campaign Committee tabloid, circulated in connection with the Measure E campaign, is not, as the tabloid notes, a visualization that represents an actual development proposal. But the fact that a small community group, at no cost, could have produced this visualization demonstrates that the City could quite feasibly have produced a fully accurate simulation--as we believe that CEQA in fact requires. We again urge the Council not to adopt a General Plan that will lead to the destruction of the visual beauty of Marina without even having a "picture" of what their decision actually means. If you could actually see the effects of what you are proposing to adopt, we believe that you might well adopt a different General Plan.

Thank you for considering these comments. LandWatch urges the City Council not to adopt the proposed resolution certifying the Final EIR on the proposed General Plan, and we again urge you not to adopt the proposed General Plan as presented to you at your November 2, 2000 meeting.