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"Boot Camp" Materials


March 20, 2004

Monterey County General Plan “Boot Camp"



I. Introductions/ Boot Camp Goals


II. General Plan Basics (Gary Patton)


III. How to Make the General Plan Better (Terry Watt)

  • What the General Plan Does Well
  • Where the General Plan Falls Short
  • Recommended Comments on the General Plan
  • Q & A

IV. How to Comment on the DEIR (Terry Watt)

  1. EIR Basics
  2. What the DEIR Does Well
  3. Where the DEIR Falls Short
  4. How to Use the EIR to Support GPU Recommendations
  5. How to Comment on the EIR
  6. Q & A

[12:15—Working Lunch]

V. Effective Message Delivery (Catherine Lew)

Boot Camp Goals

  1. Provide information about the current draft of the General Plan Update and the Draft EIR.

  2. Provide direction on how effectively to comment (orally and in writing) on the General Plan and Draft EIR.

  3. Respond to key questions about the General Plan and Draft EIR.

  4. Learn from participants about key issues/suggestions for commenting.

  5. Inspire citizen participation as the General Plan Update process enters its final stages.

General Plan Basics

The single most important policy document for guiding decisions and conditions related to land use in the County. GPU at 3-1.

Provides a vision for the County’s future and the regulatory framework. GPU at 3-1

  • The local constitution for land use.

  • The blueprint for all future growth and development.

  • All planning decisions must be consistent with the General Plan. (Specific plans, development projects)

  • Implementation tools must be consistent with the General Plan. (Zoning, other ordinances)

General Plans must be legally adequate and internally consistent. They must contain seven Mandatory Elements, which can be combined:

  • Land Use
  • Housing
  • Circulation
  • Open Space
  • Conservation
  • Noise
  • Safety

The Housing Element must be updated every five years and “certified" by the State.

The Draft Monterey County General Plan contains five elements to address the required topics:

  • Land Use
  • Circulation
  • Environmental Resource Management (Open Space and Conservation)
  • Health and Safety
  • ? Housing (under separate cover)

AND several non-mandatory, “optional" elements:

  • Agriculture
  • Economic Development
  • Public Services
  • Administration
  • Coastal Areas
  • Inland Areas

It also has several Appendices

A General Plan must be internally consistent:

  • Policies must be consistent with the land uses illustrated on land use maps.

  • Policies and land uses must be consistent with the Guiding Objectives.

  • Elements and policies must be consistent with one another.

  • All provisions must be consistent with State laws and policies.

  • Data, projections and assumptions must be consistent throughout the Plan.

The Land Use and Circulation Elements Must be Correlated:

  • Circulation Element both determines and constrains the pattern and extent of development.

  • “Correlated" means “closely, systematically or reciprocally related."

  • The requirement for correlation between the Circulation Element and the Land Use Element is designed to prohibit a General Plan from calling for unlimited population growth in the Land Use Element without a proposal for a circulation system to serve that growth.

The Land Use Element must:

? Identify the proposed general distribution and intensity of uses of the land for housing, business, industry, open space, natural resources, public facilities, waste disposal sites, and other categories of uses.

? Include standards of population density and building intensity.

How To Make The General Plan Better

What the General Plan Does Well:

Contains 12 Guiding Objectives:

#1 Preserve the unique character of areas throughout Monterey County as represented by the different Area Land Use Plans.

#2 Identify land that is adequate and appropriate for the residential, commercial, and industrial development needs of Monterey County during the next twenty years, taking into account land located within the cities, existing legal lots of record, and resource and infrastructure constraints.

#3 Preserve a distinction between urban and rural areas. Channel new growth to areas already committed to an urban level of development (e.g. cities, areas directly adjacent to cities, and densely developed unincorporated communities). Preserve rural areas for resource-based industries (e.g. farming, livestock, grazing, mining), natural resource protection, and open space recreation uses.

#4 Strongly encourage new commercial, industrial, and residential development to provide actual, new, permanently affordable living quarters, including housing for people with low, very low, and moderate incomes who live and/or are employed in Monterey County. Promote density, creative and innovative design concepts, and employer-produced housing which will increase affordable housing opportunities convenient to the workplace. Promote a healthy job and housing balance in all areas.

#5 Promote the development of walkable communities that meet the daily needs of their residents, offer a high quality of life for residents, and reduce the need for automobile trips.

#6 Promote, preserve, and support agriculture and the industries that serve it. Promote industries that preserve and support environmental quality or serve the local needs of our communities.

#7 Minimize development of commercially viable agricultural land. Ensure that recognized needs for growth are met by infill and contiguous, compact development.

#8 Provide adequate infrastructure and public services for existing residents and businesses. Ensure that infrastructure and public services are available, fully funded, and constructed concurrently with new development. Ensure that new development neither increases the infrastructure and public service cost for existing residents and businesses nor reduces their quality of service by any significant amount.

#9 Provide long-term protection of identified resource-rich and critical habitat areas.

# 10 Protect the visual integrity of ridgelines, designated scenic corridors, and other identified sensitive visual resources throughout Monterey County.

#11. Seek to provide an adequate and sustainable water supply while protecting the county’s watersheds and marine environment, including surface water, ground water, and aquifer recharge areas.

#12 Provide a clear statement of county land use values and policies to provide clarity in the county’s permit processing system and to simplify review of projects that are consistent with the General Plan.

What the General Plan Does Well, continued:

Attempts to base policies and land use on a theme of “focused growth:"

“The major thrust of this Plan is to manage growth by preserving a clear distinction between urban and rural areas. This means channeling new growth into planned urban areas and preserving rural areas for agricultural and other resource-based industries and for natural resource protection." (GPU at Page 24)

What the General Plan Does Well, continued:

  • ? Calls for a minimum parcel size of 40 acres in rural areas and larger where the 1982 Land Use Plan requires.
  • ? Contains or is based on detailed information to assist the public and decision-makers to get it right:
    • ü Discloses that three times more land is designated for development in the GPU than is needed.
    • ü Concludes that land use patterns are largely at fault for commute patterns and environmental impacts.
    • ü Includes data such as 43% of the work force cannot afford the average price of a three-bedroom apartment.
    • ü States that housing currently being built serves a largely out-of-county market.

Where the General Plan Falls Short:

The proposed General Plan is internally inconsistent in numerous respects.

  • Policies and land uses are not consistent with the Guiding Objectives.

    • Guiding Objective#2—Identify land that is adequate and appropriate for the residential, commercial, and industrial development needs of Monterey County during the next twenty years, taking into account land located within the cities, existing legal lots of record, and resource and infrastructure constraints.

      • Building according to the current draft of the General Plan results in a total yield of 21,666 units, or 2 _ to 3 times the amount needed to accommodate projected population growth (7-10,000 units) over 20 years.

    • Growth areas fail to maintain a clear distinction between urban and rural areas as directed by the Guiding Objectives:

      • 8,830 acres/10,567 units in Five Community Areas;

      • 2,626 acres/6,068 units in Pine Canyon and San Lucas and Expanded Rancho San Juan;

      • Affordable Housing Overlays (no estimate);

      • Clustered Subdivisions (6,000 population);

      • Rural Centers (no estimate);

      • Existing lots of record (8,000+/-).

Where the General Plan Falls Short, continued:

The proposed General Plan fails to provide adequate direction for future development:

  • The number of potential housing units built as a result of the Affordable Housing Overlay;

  • Stronger policies to protect farmland (DEIR finds proposed land uses will result in significant and unavoidable impact to farmland);

  • The number and location of housing “clusters" under the Cluster Policy;

  • The number and type of potential housing units that could be built in Rural Centers;

  • An effective affordable housing policy;

  • Adequate “correlation" of land use and transportation.

  • Adequate water to serve proposed development without adverse impacts.

Practice Tips

Comments on the General Plan

  • Comments on the General Plan will be most effective if expressed in terms of alternative policy choices.

  • Specific recommendations should be linked back to their achievement of the Guiding Objectives.

  • Supporting information from the General Plan, the DEIR, Economic Study, other source should be referenced (and attached) to support the policy or land use recommendation.

Intent of Comments on the General Plan

  • To correct legal deficiencies (for instance, lack of information about land use densities/intensities; lack of correlation between proposed land use and circulation systems, internal inconsistencies including 3+ times the amount of land designated for development as is needed, etc.).

  • To eliminate significant unavoidable impacts of the General Plan (for instance, to limit areas of new urban development so as to address impacts on agricultural land, traffic, etc.).

  • To achieve a world class General Plan with cutting edge policies and land uses consistent with the 12 Guiding Objectives.

Example Comments on the General Plan:

Work for the bottom line

We cannot afford the General Plan proposed: “The General Plan analysis identifies an 11 million deficit that will be associated with full development of the 7 community areas." Economic Impact Analysis at ii.

  • Prioritize affordable housing for Monterey County residents and employees in appropriate growth areas (below).

  • Direct all new growth to the four Community Areas of Pajaro, Castroville, Boronda and Fort Ord.

  • Eliminate policies that allow growth in areas that cannot be adequately served by services and infrastructure and will result in significant unavoidable impacts to farmland including: Affordable housing overlay areas, rural centers, cluster development, estate homes on agricultural and ranching parcels.

Keep it Simple

  • Be clear about where and what development is allowed. Eliminate timing, phasing, tiering policies that are confusing. Do not count on phasing, tiering and other policies to limit development otherwise permitted by the plan.

  • Eliminate policies that must be monitored because they may have adverse impacts, such as Special Treatment Areas and cluster development.

Make the Tough Choices Now

The proposed General Plan will result in significant and unavoidable impacts to prime farmland.

  • Permit new development outside of growth areas only on legal lots of record.

  • Limit new subdivisions to those necessary to sustain farming and ranching.

Example Comments on the General Plan cont:

(1) Either delete the clustering policy or include a detailed clustering policy that complies with State law requirements to identify the location and density of housing. The DEIR provides some direction on a more detailed policy, including:

  • No increase in overall gross density.
  • No clustered lots sited on prime farmland…
  • Creation of no more than 3 clustered lots on 10% of the property with remainder placed in permanent conservation easement.
  • etc. (MM 1a)

(2) Provide “adequate and appropriate land for the County’s development needs" by identifying Castroville, Boronda, Pajaro and Fort Ord as Community Areas. In combination with existing lots of record, these four areas achieve Guiding Objective #2. Inclusion of this policy will restore internal consistency to the General Plan.

How To Comment on the DEIR

EIR Basics

Purposes of an Environmental Impact Report (as required by CEQA):

  • To inform the public and decision makers of the environmental consequences of their decisions before they are made.

  • To “tell the whole truth" and support the truth with facts and evidence. The EIR must contain facts and analysis, not just bare conclusions.

  • To show clearly the analytical route the lead agency (County) traveled from evidence to action.

Purposes of a “Program" EIR on a “General Plan" document:

[A program EIR addresses a series of actions that can be characterized as one large project and are related.]

  • To determine where development should and should not be directed based on environmental conditions and recommend changes to the General Plan accordingly.

  • To provide alternatives and mitigation measures to reduce or eliminate impacts of the General Plan as proposed = to improve the General Plan.

  • To determine whether proposed development can be supported with “environmentally acceptable" and feasible infrastructure and recommend changes to the plan accordingly. The General Plan will guide decisions about both development and the infrastructure to support it, such as new and wider roads and new water supplies.

CEQA Authorizes Agencies to:

  • Require changes in a project to lessen or avoid significant effects, when feasible (for instance, alternative policies or changes to the proposed type, mix and intensity of land uses and locations).

  • Disapprove a project to avoid significant effects (or in this case, require an alternative General Plan).

  • Approve a project with significant effects if there is no feasible way to lessen or avoid the effects and the project’s benefits outweigh these effects.

  • Impose fees for implementation.

Process for Review of the EIR:

  • Project description is completed (in this case, the Draft Monterey County General Plan)

  • Notice of Preparation (NOP) is sent to agencies

  • Administrative DEIR is completed and reviewed

  • DEIR is circulated for a minimum 45-day public review period, and written comments are received by the County (until April 2).

  • Optional public hearing on DEIR

  • Responses to Comments are prepared

  • Response Document (Final EIR) distributed to agencies 10-days prior to City decision

  • Final EIR Certified by the County

  • Action taken on the Proposed Project (General Plan) and CEQA Findings Adopted

  • Notice of Determination Filed

  • 30-day Statute of Limitations to Challenge EIR

Required Contents of DEIR:

  • Table of Contents or Index

  • Summary

  • Project Description

  • Environmental Setting

  • Significant Environmental Impacts

    • Direct (e.g. traffic, open space/farmland land loss)

    • Indirect (e.g. growth inducement)

    • Short-term (e.g. construction noise/traffic/etc.)

    • Long-term (e.g. traffic, loss of biological resources)

    • Cumulative (impacts in connection with other projects)

    • Unavoidable (no feasible mitigation or alternatives)

  • Areas of Known Controversy

  • Alternatives (No Project and Env. Superior)

  • Mitigation Measures (in the form of different land use/alternative policies)

  • Growth Inducing Impacts

  • Significant Irreversible Changes to the Environment

Key Concept:

The EIR may direct that changes be made to the General Plan policies or land uses to lessen or avoid significant effects, when feasible, typically in the form of:

  1. Modified or new policies in the form of mitigation measures. [same policy recommendations as on the General Plan]

  2. Changes to the proposed land uses and locations in the form of alternatives.

  3. Changes to the type or mix of land uses (for instance, a higher proportion of affordable housing).

What The DEIR Does Well:

Tells much of the truth about the severity of impacts:

  • Identifies approximately 43 significant and unavoidable impacts of the Plan including loss of farmland; and

  • Identifies approximately18 significant cumulative impacts, including loss of farmland and biological resources, lack of water for new development, etc.

  • Provides analysis of impacts and attempts to show the analytical routes underlying conclusions.

  • Analyzes a “No Further Subdivision" and “Five Community Areas" Alternatives.

Where The DEIR Falls Down:

Fails to recommend feasible and clear policy choices in the form of mitigation measures that would reduce or eliminate the significant impacts of the General Plan.

  • For instance, the DEIR notes that the significant and unavoidable impacts of Special Treatment Areas and Affordable Housing Overlay areas include loss of agricultural land, neighborhood compatibility and visual impacts, among other impacts.

  • The DEIR proposes a mitigation measures to “monitor" the impact of these policies rather than truly to mitigate the identified impacts.

  • Alternative Choice: Eliminate these policies.

The Project Description and Environmental Setting Sections together create the FOUNDATION of the EIR.

If information is omitted or incorrect in these sections, the EIR’s analysis of environmental impacts cannot be adequate.

Project Description Should Include:

  • Sufficient detail to support evaluation and review of environmental impacts

  • Project Objectives

  • Project Location

  • Project Characteristics

    • Project Proposal

    • Proposed Units and type of units

    • Proposed Coverage of the land

    • Build-out Assumptions

    • All Supporting Public Services/Infrastructure

  • Reasonably foreseeable future phases

  • Required Approvals

Questions to Ask When Reviewing the Project Description (the General Plan):

  1. Is the Project Description (GP) complete? Are there aspects about the project that are not described accurately? Adequately?

  2. Is the Project Description of the GP consistent throughout the DEIR?

  3. What is the Description (GP) missing that is needed to fully and accurately disclose and analyze the impacts of the project? to agricultural resources? to traffic? etc.

How To Use The EIR To Support GPU Recommendations

The goal of commenting on the DEIR is threefold:

(1) Identify flaws in the DEIR that need to be rectified in order for the document to support informed decision-making = be legally adequate.

(2) Cite information in the DEIR that supports stronger policies in the General Plan. E.G. The numerous impacts to prime farmland support focusing growth in urban areas and additional protection for farmland.

(3) To create “leverage" for stronger policies in the General Plan. E.G. The DEIR fails to adequately analyze impacts associated with the cluster policy. Therefore, the cluster policy should either be eliminated or further defined so the cluster development does not result in significant impacts.


Comments on the Project Description

Practice Tips
Follow-up Your Comment With a Specific Question

The project description fails to adequately describe a number of key General Plan policies and proposed land uses in sufficient detail for their impacts to be adequately analyzed including, but not limited to:

1) Clustering Policy. How many cluster units will result from the GP policy with and without the mitigation measure suggested in the DEIR? Where will they be located? How will they be served by infrastructure and services? What will be the “cost" to the County of serving these units? Do they provide needed housing? Without this information, the EIR’s analysis of potentially significant impacts cannot be adequate. To address this DEIR omission, the cluster policy could either be eliminated or restricted so that cluster development does not result in a significant impact.

2) Rural Centers. How many new units/non-residential square feet will result from development in Rural Centers? Without this information, the DEIR’s analysis of potentially significant impacts is incomplete. To address this DEIR omission, the major land group “Rural Centers" could be eliminated and these areas included in Rural Lands.

3) Estate Units in Agricultural and Resource Lands. How many new units can be built in these areas? What will be the impact on ongoing agricultural uses if these units are permitted (e.g. replace units needed for ag families and workers; create conflicts with ag uses, etc.). Potentially significant impacts of this policy must be addressed or the policy changed to require first units on Agricultural parcels be accessory to agricultural purposes.

4) Special Treatment Areas. Please provide information about the number of special treatment projects, their locations and total development allowed under the Plan policies (DEIR at 5.1-62). The DEIR states that it is not possible to know at this time how many STA projects there will be or what the specific impacts of these projects will be. Removal of STAs from the General Plan would resolve this potential omission.

5) What is the assumed build-out capacity of future proposed wineries and related impacts? Please provide detailed information about the scale, type and quantity of winery uses as permitted by the General Plan with and without the proposed mitigation measure. How much water will these uses require? Other services? A General Plan policy to require a specific plan prior to implementation of winery corridors would go a long way to address these omissions in the DEIR.

Environmental Setting Must Include:

A description of the physical environmental conditions in the vicinity of the project from both a local and regional perspective, as it exists at the time the NOP is published. The regional setting must be sufficiently large in geographic extent to adequately analyze cumulative impacts.

Examples of setting information --

  • Adequate description of biological resources, including wildlife corridors, animal and plant species present in proposed development areas and in the surrounding region.

  • Relevant information about the regional context of the project that relate to the need for the project at this time (e.g. need for project to meet housing need).

  • Information about the status of services and infrastructure to accommodate growth – e.g. water; etc.

  • Information about the amount of development planned and underway in the cities.

Questions to ask when reviewing the environmental setting sections:

  1. Does the DEIR accurately and completely describe conditions as they currently exist? (e.g. sources and uses of water, etc.)
  2. Is setting information based on adequate and current surveys, other credible and complete information sources?
  3. Is the geographic study area for cumulative analyses sufficiently large? (e.g. sufficient to account for impacts associated with employee housing? For biological resources? For traffic?)
  4. What missing setting information should have been developed and included in the DEIR and why?

Example Comments on Setting Information:

Please include the following information in a revised DEIR and revise impact discussions accordingly:

  • What amount of development is currently approved in the cities? Please break down by density and unit type and square footage of non-residential uses. To what extent will this development meet countywide housing and development demands?

  • Please provide additional details concerning planned and proposed new water supplies, related storage and other infrastructure needed to serve the proposed new development under the GPU? Without this information, the DEIR cannot adequately disclose the impacts associated with providing water to serve the planned development.

  • Please provide information about the growth trends in adjacent counties that may affect Monterey County’s growth. (e.g. spillover of housing demand; increased development in North San Luis Obispo County, etc.)

Environmental Impact Analyses

  • Impacts must be described (quantified where possible) and analyzed (e.g. acres of each habitat type destroyed; farmland converted).

  • If the EIR assumes an impact will be reduced by a plan policy or mitigation measure, information must be provided concerning the effectiveness of the policy or measure to reduce the impact.


Water: An EIR must identify the water supply and analyze whether the water supply is adequate to meet demand from the project, current users and cumulative projects. The EIR must analyze the impacts of development of new water on biological resources.

Biological Resources: An EIR must go beyond the analysis of loss of habitat and evaluate effects of development (including new roads and utility corridors) on habitat fragmentation, interference with wildlife corridors, etc.

Questions to ask when reviewing the Environmental Analysis Sections:

  1. Are the underlying assumptions accurate? (e.g. amount of development at buildout allowed by the Plan; trips generated by new development, etc.)

  2. Does the DEIR analyze and disclose the impacts associated with the proposed physical development in terms of its scale/amount, location, type?

  3. Does the DEIR analyze potential impacts associated with policies?

  4. Does the DEIR accurately characterize the “significance" of the impact? If not, why not? (lack of information, incorrect information, lack of analysis, other?)

  5. If the DEIR relies on a Plan policy or mitigation measure to reduce a significant impact to less than significant, can you follow the logic? Does the DEIR clearly state how the policy or measure reduces the significance of the impact?

  6. Does the DEIR omit any significant impacts?


Comments on Adequacy of Environmental Analysis

The DEIR states that “the impacts of future growth under the GPU on regional water supply is difficult to assess because the prospects for alleviating current basin-wide deficits are both uncertain and complex." DEIR at 5.13-17. The section continues on to discuss potential impacts with respect to Community Areas and Rural Centers. For example:

  • Development of RSJ will substantially deplete ground water supplies, resulting in a net deficit in aquifer volume and lowering the local ground water table, and creat[ing] water demand that exceeds water supply available from existing resources. DEIR at 5.13-18.

  • “Urbanization of RSJ would necessitate facilities for conveyance, storage and distribution to the Community Area. Construction of these new facilities may result in environmental impacts that cannot be evaluated until site-specific plans are reviewed in conjunction with the Community Plan." DEIR at 5.13-19.

If the General Plan is to continue to include a policy to develop RSJ, a revised analysis must include additional information concerning water use and water impacts associated with development of RSJ. In the alternative, the DEIR should recommend that development not be permitted at RSJ.

Moreover, the General Plan should plan for only that amount of development that can be served by environmentally sound water supplies.

Cumulative Impacts Analysis

  • An EIR must discuss the cumulative impacts of a project when the incremental effects of a project are considerable when viewed in connection with the effects of other past, current and probable future projects.

  • A legally adequate cumulative impacts analysis views a particular project over time and must consider the impact of the project combined with other projects causing related impacts, including past, present, and probable future projects. Projects currently under environmental review unequivocally qualify as reasonably probable future projects to be considered in a cumulative impacts analysis. Alternatively, an EIR may utilize a summary of projections contained in an adopted general plan or related planning document, or in a prior environmental document which has been adopted or certified, which described or evaluated regional or area wide conditions contributing to the cumulative impact.

  • The discussion of cumulative impacts must include a summary of the expected environmental effects to be produced by those projects, a reasonable analysis of the cumulative impacts, and full consideration of all feasible mitigation measures that could reduce or avoid any significant cumulative effects of a proposed project.

Questions to ask when reviewing the cumulative discussions:

  1. Are cumulative projects or plans adequately disclosed and quantified?

  2. Are cumulative impacts adequately disclosed and quantified where possible?

  3. Are the study areas for each impact large enough to identify cumulative impacts? (e.g. the study area is limited to Monterey County for the most part).

  4. Does the DEIR identify mitigation measures for cumulative impacts?

  5. Are projects or planned development potential omitted from the analysis?


Comment Concerning Cumulative Impacts

The DEIR’s analysis of cumulative impacts to water supply is adequate for at least the following reasons:

First, the DEIR fails to fully describe project-related and cumulative water demand, including demand by foreseeable growth in the cities and all uses allowed by the proposed Monterey County GP, and therefore impacts are underestimated.

Second, the DEIR does not describe all likely sources of new water, and therefore fails to identify the significant impacts associated with development of new water.

Third, the DEIR lacks “analysis" of cumulative water impacts and simply concludes that impacts will be significant:

“All potential sources of growth within constrained water basins contribute to the water supply impacts identified above (e.g. substantially deplete supplies, groundwater sources, create demands that exceed supply, etc.). These impacts are cumulatively significant for the same reasons the impacts of growth in the areas above are significant." DEIR at 5.13-29.

Please provide additional information about TOTAL countywide water demand and potential new supplies. Based on this information, what are the impacts associated with new water development necessary to serve proposed new development without adversely impacting environmental resources and ground and surface water sources? If water imports are a source of water, please disclose the out-of-county impacts associated with such water transfers.

The DEIR concludes that “additional measures to help in mitigating cumulative impacts can be achieved through a project alternative that limits GPU growth to a level necessary to achieve project objectives. What level of new development in the County unincorporated areas/in the whole County, can be served by existing “safe yield" water supplies? (e.g. without further degradation of environmental resources, ground and surface water sources). Please analyze such an alternative in the FEIR. Planned development under the new General Plan should not exceed safe yield water supplies or result in significant adverse impacts as a result of water development, storage or transfer. That may require the General Plan to limit new development to existing lots of record in some areas.

Growth Inducing Impacts

  • o The growth inducing analysis must “[d]iscuss the ways in which the proposed project could foster economic growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment." It must also discuss how a project may “encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively" or “remove obstacles to population growth." CEQA Guidelines.

  • o Extension and enlargement of roads and extension of other services and infrastructure (e.g. water and sewer collection systems) may induce growth beyond that proposed in the General Plan if not restricted.


Comment on Growth Inducing Analysis:

The DEIR fails to provide any meaningful analysis of the growth inducing potential of the General Plan’s approach to development. Specifically, policies in the General Plan will permit significant high end housing, which will likely result in increased demand for local services and affordable housing. The growth inducing impacts of producing an over-supply of high end housing are noted in the DEIR, but not analyzed.

Moreover, the DEIR fails to analyze the growth inducing impacts of new services, including expanded roads and water supply “proposed" by the General Plan and necessary to serve new development.

A revised environmental document must include an adequate analysis of the project’s potential for growth inducement, including, but not limited to the following:

  • a complete list of infrastructure (e.g. water supply, storage, distribution) and road improvements needed to support planned growth and a determination of whether any of these will support additional growth beyond the project, including in cities and adjacent counties;

  • the extent to which overbuilding high-end housing will result in demand for additional services and/or induce demand for affordable housing in adjacent counties.

Alternatively, the General Plan can include policies that: (1) prioritize development of housing for Monterey residents and workers and (2) direct growth to cities and urban areas where extension and expansion of infrastructure will not induce development beyond planned development.

Types of Mitigation Measures

  • Avoid the impact altogether by not taking certain action or parts of an action (for instance by removing proposed development from some areas; policy specifying avoidance in the Plan)

  • Minimize impacts by limiting the degree or magnitude of the action and its implementation (for instance by reducing development and support infrastructure)

  • Rectify the impact by repairing, rehabilitating, or restoring the affected environment (for instance by replanting vegetation after removal for development)

  • Reduce or eliminate the impacts over time by preservation and maintenance during the life of the action.

  • Compensate for the impact by replacing or providing substitute resources or environments (for instance payment of habitat mitigation fee or permanent protection of habitat land)

Questionable Mitigation Measures

  • Provide funding for

  • Hire staff

  • Monitor or report

  • Comply with existing regulations or ordinances

  • Preserve already existing natural areas

Inadequate Mitigation Measures

  • Consult with

  • Submit for review

  • Coordinate with

  • Study further

  • Inform

  • Encourage/discourage

  • Facilitate

  • Strive to

Questions to Ask About Mitigation Measures:

  1. Are feasible mitigation measures proposed for each significant impact, including significant cumulative impacts? The County may not put off identification of “measurable" mitigation until later.

  2. Does the EIR explain and document how and whether the measure will avoid or substantially reduce the impact to “less than significant." If not, why is the logic flawed and what measures might effectively address the impact?

  3. Are there other measures that should be identified?

  4. Does the EIR identify “secondary" impacts that may result from the mitigation measures.

Examples of Mitigation Measures that are Questionable/Unacceptable:

Measure 1i: “Since the Use of an Affordable Housing Overlay concept is new for Monterey County and is not yet known how many projects may be proposed, the County shall monitor AHO projects as a component of the 5-year review and evaluate the cumulative land use impacts of projects relative to land use incompatibilities and consistency with adopted policies, in particular the fundamental objective of the Growth Management Policy to preserve the distinction between rural and urban lands."

Acceptable Mitigation:

Delete the Affordable Housing Overlay policy and map (LU-5) and replace with a policy that gives priority to affordable housing developments located in the four Community Areas where services can be provided.Measure 1l: Since future Special Treatment Area overlay designations may lead to the creation of more lost than could otherwise be created by the underlying land use designations and it is not known how many projects may be proposed and where they may be located, the County shall monitor new STA designations as a component of the 5-year review and evaluate the cumulative land use impacts of such projects relative to land use incompatibilities and consistency with adopted policies, in particular the fundamental objective of the Growth Management Policy to preserve the distinction between rural and urban lands. Based upon the results of each 5-year review, the Board of Supervisors shall decide whether revisions to Policy LU-11.1 are required.

Acceptable Mitigation:

Eliminate the STA policy and direct new growth into the four Community Areas where services can be provided and development will be consistent with the Growth Management Policy.

Examples of Feasible Measures (New Policies/Deleted Policies) Omitted from the DEIR:

  • Eliminate policies that allow growth in areas that cannot be adequately served including: Affordable housing overlay areas, rural centers, cluster development, estate homes on agricultural and ranching parcels.

  • Include a policy that will provide housing affordable to Monterey County residents and employees and limit high end housing that serves an out of county market.

  • Be clear about where and what development is allowed – only in the four Community Areas of Boronda, Pajaro, Castroville and Fort Ord.

  • Eliminate timing, phasing, tiering policies that are confusing. Do not count on phasing, tiering and other policies to limit development otherwise permitted by the plan.

  • Eliminate policies that must be “monitored" because they may result in development that in term generates adverse impacts (e.g. Special Treatment Areas and cluster development).

  • Permit new development outside of growth areas (Pajaro, Baronda, Castroville, Fort Ord) only on legal lots of record.

  • Limit new subdivisions to those necessary to sustain farming and ranching.

  • Require a specific plan prior to development of winery corridors. Establish interim winery related uses that can occur prior to the completion of the specific plan – that will not result in any significant impacts.


  • The range of alternatives is limited to those that meet the project objectives, are ostensibly feasible and would avoid or substantially lessen at least one of the significant impacts of the project. Feasible means capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social and technological factors.

  • The DEIR must include a “no-project" alternative and identify the environmentally superior project alternative.

Questions to ask when reviewing alternatives:

  1. Are there other feasible alternatives that would reduce or eliminate significant impacts of the project or project alternatives?

  2. Does the DEIR adequately analyze the alternatives it does include? Specifically, does the DEIR identify the comparative impacts of the alternatives to the proposed project and other alternatives?

  3. Is a sufficient range of alternatives described?

Additional Alternatives We Request Be Analyzed:

There are other feasible alternatives that should be analyzed as follows:

  • Infill First Alternative: This alternative would be based on an analysis of the “infill" potential within existing limits of Monterey cities and within each cities existing sphere of influence AND within the existing unincorporated communities of Pajaro, Boronda, Castroville and Fort Ord. Policies directed at removing barriers to high quality infill should be included in this alternative.

  • A combined “4 Community Area/Existing Lots of Record Alternative." Analysis of the 5 Community Area and Legal Lots of Record alternatives as separate alternatives hides the potential for a combined alternative to meet housing needs.

  • Alternatives should include potential “mitigation measures/policies" that could improve their outcomes (e.g. stronger affordable housing requirements to make the most efficient use of limited land; etc.).

Practice Tips

Select a topic area to review (for instance, land use, biological resources, transportation/circulation).

Review the section with the following questions in mind:

  1. Is the project sufficiently described to ascertain all potentially significant impacts related to the topic?

  2. Is there sufficient information about the project setting and regional setting to support a complete analysis of impacts?

  3. Does the section identify all potential impacts? Are they properly characterized as less than significant, significant, etc.

  4. Are all feasible mitigation measures identified for each significant impact?

  5. Does the discussion clearly state how each mitigation measure eliminates or reduces the level of significance of the impact it addresses?

  6. Are the cumulative impacts related to the topic area adequately analyzed and mitigated?

  7. What additional information related to each of the above questions is required to perfect the discussion? List as questions.

  8. Use information in the Economic Study, EIR and other reports to support your request for additional mitigation measures in the form of new or modified policies, modified land uses, deleted policies. EG. The economic study and DEIR provide numerous reasons why the General Plan must be improved:

The Economic Impact Analysis on the GPU, prepared by Applied Development Economics, convincingly demonstrates that stopping rural subdivisions, and focusing new growth into existing urban areas, will provide the best fiscal and economic effects for Monterey County. In other words, this study validates what the public has been telling the County, and what the Twelve Guiding Objectives mandate.

Specifically, the Economic Impact Analysis says:

  1. Unincorporated development exerts higher service costs on County government, than does growth in the cities. Of the $11 million incremental deficit created by the GPU growth, $10 million is associated with unincorporated development, and only $1 million with city growth, despite the much higher growth levels in the cities [Page ii; Page 18].

  2. More than 85 percent of workers need housing priced at $376,000 or less [Page v].

  3. Residential development should not outpace job development in each area [Page vii].

  4. From a policy perspective, the County may wish to avoid encouraging substantial industrial development in the unincorporated area in the Central Salinas Valley or South County [Page 7].

  5. Lower growth scenarios show a smaller deficit, while the higher growth scenarios increase the County’s fiscal deficit [Page 9; Page 17].The study…identified the cost to the County, per residence, for residents who live in the unincorporated County but work in another county. This cost is estimated at $466 per residence [per year], more than six times the cost per residence for those who both live and work in the unincorporated County [Page 18].

  6. The unincorporated County’s role as a bedroom community, either for workers employed in neighboring counties or for workers employed in Monterey County, is very expensive and a constant net drain on County resources [Page 20].

  7. Low density residential developments generate costs that are much greater than high or even medium density developments [Page 20].

  8. Studies documenting the fiscal benefits of compact development…have addressed the issue in all parts of the country…and California [Page 21].

  9. The County should avoid significant amounts of low density development in rural, poorly served areas…. [Page 22].

  10. Agricultural land reductions potentially impact this cluster [the Agricultural Services Cluster], and could erode its dominant position within the Monterey County economy.

  11. Policies that provide more flexibility regarding use … may improve agricultural land value or farm income but in aggregate and over time weaken overall agricultural viability by increasing land values beyond the point supported by agricultural value [Pages 42-43; emphasis added].

  12. The unincorporated areas around Rancho San Juan produce higher value crops such as strawberries, which results in a much higher potential impact per acre [for conversion of these agricultural uses to urban uses] [ Page 46].

  13. The extraordinary beauty of the communities along the coast draw very high income individuals, some of which [sic] retire in the area. It is also due in part to the demand for commuter housing from workers in silicon Valley….The primary evidence of the [county’s] economic transition is the rapid escalation of housing prices throughout the County [Page 62].

  14. It is critical that the public infrastructure not degrade further as new development proceeds [Page 63; emphasis added].

  15. Residential development should not outpace job development in each area [Page 63].

To improve our local economy, and to provide good jobs and good housing, the GPU must:

  • Slow down growth
  • Stop low-density suburban development and focus growth in existing urban areas
  • Tie new residential development to local job growth
  • Disallow development before needed infrastructure is available
  • Require a significant share of permanently affordable housing ($376,000 and below)
  • Refuse calls for the kind of “flexibility" that will undermine our agricultural economy
  • Disallow Rancho San Juan

In fact, this is what the Twelve Guiding Objectives also require.

Useful Information

DEIR Comment Period Ends: April 2, 2004

Send comments to:

Genee Terada
Monterey County Environmental Resource Policy
230 Church Street, Bldg. 3
Salinas Ca, 93901

General Plan Comment Period Ends: March 26, 2004

Send comments to Genee Terada at above address

Public Hearing Dates:

March 22, 2004 (special evening meeting)
Last PUBLIC HEARING before the Planning Commission Decision


Board of Supervisors Chambers
County Courthouse
240 Church Street, 2nd Floor
Salinas, CA 93901

April 7, 2004
(Planning Commission special daytime meeting)

April 21, 2004
(Planning Commission recommendations to Board)

April 28, 2004 –If needed
(Planning Commission recommendations to Board)

County General Plan Website:

Landwatch Website:

Economic Impact Analysis:

[Return to County Plan Update Issues and Actions]


LandWatch's mission is to protect Monterey County's future by addressing climate change, community health, and social inequities in housing and infrastructure. By encouraging greater public participation in planning, we connect people to government, address human needs and inspire conservation of natural resources.



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