County General Plan Boot Camp"
Introductions/ Boot Camp Goals
General Plan Basics (Gary Patton)
How to Make the General Plan Better (Terry Watt)
the General Plan Does Well
the General Plan Falls Short
Comments on the General Plan
Q & A
How to Comment on the DEIR (Terry Watt)
the DEIR Does Well
the DEIR Falls Short
to Use the EIR to Support GPU Recommendations
How to Comment on the EIR
Effective Message Delivery (Catherine Lew)
information about the current draft of the General Plan Update
and the Draft EIR.
direction on how effectively to comment (orally and in writing)
on the General Plan and Draft EIR.
to key questions about the General Plan and Draft EIR.
from participants about key issues/suggestions for commenting.
citizen participation as the General Plan Update process enters
its final stages.
single most important policy document for guiding decisions and
conditions related to land use in the County. GPU at 3-1.
a vision for the Countys future and the regulatory framework.
GPU at 3-1
local constitution for land use.
blueprint for all future growth and development.
planning decisions must be consistent with the General Plan. (Specific
plans, development projects)
tools must be consistent with the General Plan. (Zoning, other
Plans must be legally adequate and internally consistent. They must
contain seven Mandatory Elements, which can be combined:
Housing Element must be updated every five years and certified"
by the State.
Draft Monterey County General Plan contains five elements to address
the required topics:
Resource Management (Open Space and Conservation)
Housing (under separate cover)
several non-mandatory, optional" elements:
also has several Appendices
General Plan must be internally consistent:
must be consistent with the land uses illustrated on land use
and land uses must be consistent with the Guiding Objectives.
and policies must be consistent with one another.
provisions must be consistent with State laws and policies.
projections and assumptions must be consistent throughout the
Land Use and Circulation Elements Must be Correlated:
Element both determines and constrains the pattern and extent
means closely, systematically or reciprocally related."
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.
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
Include standards of population density and building intensity.
To Make The General Plan Better
the General Plan Does Well:
12 Guiding Objectives:
Preserve the unique character of areas throughout Monterey County
as represented by the different Area Land Use Plans.
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.
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.
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.
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.
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.
Minimize development of commercially viable agricultural land.
Ensure that recognized needs for growth are met by infill and
contiguous, compact development.
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
Provide long-term protection of identified resource-rich and critical
10 Protect the visual integrity of ridgelines, designated scenic
corridors, and other identified sensitive visual resources throughout
Seek to provide an adequate and sustainable water supply while
protecting the countys watersheds and marine environment,
including surface water, ground water, and aquifer recharge areas.
Provide a clear statement of county land use values and policies
to provide clarity in the countys permit processing system
and to simplify review of projects that are consistent with the
the General Plan Does Well, continued:
to base policies and land use on a theme of focused growth:"
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)
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:
Discloses that three times more land is designated for development
in the GPU than is needed.
Concludes that land use patterns are largely at fault for
commute patterns and environmental impacts.
Includes data such as 43% of the work force cannot afford
the average price of a three-bedroom apartment.
States that housing currently being built serves a largely
the General Plan Falls Short:
proposed General Plan is internally inconsistent in numerous respects.
and land uses are not consistent with the Guiding Objectives.
Objective#2Identify 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.
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.
areas fail to maintain a clear distinction between urban and
rural areas as directed by the Guiding Objectives:
acres/10,567 units in Five Community Areas;
acres/6,068 units in Pine Canyon and San Lucas and Expanded
Rancho San Juan;
Housing Overlays (no estimate);
Subdivisions (6,000 population);
Centers (no estimate);
lots of record (8,000+/-).
the General Plan Falls Short, continued:
proposed General Plan fails to provide adequate direction for future
number of potential housing units built as a result of the Affordable
policies to protect farmland (DEIR finds proposed land uses will
result in significant and unavoidable impact to farmland);
number and location of housing clusters" under the
number and type of potential housing units that could be built
in Rural Centers;
effective affordable housing policy;
correlation" of land use and transportation.
water to serve proposed development without adverse impacts.
on the General Plan
on the General Plan will be most effective if expressed in terms
of alternative policy choices.
recommendations should be linked back to their achievement of
the Guiding Objectives.
information from the General Plan, the DEIR, Economic Study, other
source should be referenced (and attached) to support the policy
or land use recommendation.
of Comments on the General Plan
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.).
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.).
achieve a world class General Plan with cutting edge policies
and land uses consistent with the 12 Guiding Objectives.
Comments on the General Plan:
for the bottom line
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.
affordable housing for Monterey County residents and employees
in appropriate growth areas (below).
all new growth to the four Community Areas of Pajaro, Castroville,
Boronda and Fort Ord.
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.
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.
the Tough Choices Now
proposed General Plan will result in significant and unavoidable
impacts to prime farmland.
new development outside of growth areas only on legal lots of
new subdivisions to those necessary to sustain farming and ranching.
Comments on the General Plan cont:
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:
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)
Provide adequate and appropriate land for the Countys
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
To Comment on the DEIR
of an Environmental Impact Report (as required by CEQA):
inform the public and decision makers of the environmental consequences
of their decisions before they are made.
tell the whole truth" and support the truth with facts
and evidence. The EIR must contain facts and analysis, not just
show clearly the analytical route the lead agency (County) traveled
from evidence to action.
of a Program" EIR on a General Plan" document:
program EIR addresses a series of actions that can be characterized
as one large project and are related.]
determine where development should and should not be directed
based on environmental conditions and recommend changes to the
General Plan accordingly.
provide alternatives and mitigation measures to reduce or eliminate
impacts of the General Plan as proposed = to improve the General
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.
Authorizes Agencies to:
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).
a project to avoid significant effects (or in this case, require
an alternative General Plan).
a project with significant effects if there is no feasible way
to lessen or avoid the effects and the projects benefits
outweigh these effects.
fees for implementation.
for Review of the EIR:
description is completed (in this case, the Draft Monterey County
of Preparation (NOP) is sent to agencies
DEIR is completed and reviewed
is circulated for a minimum 45-day public review period, and written
comments are received by the County (until April 2).
public hearing on DEIR
to Comments are prepared
Document (Final EIR) distributed to agencies 10-days prior to
EIR Certified by the County
taken on the Proposed Project (General Plan) and CEQA Findings
of Determination Filed
Statute of Limitations to Challenge EIR
Contents of DEIR:
of Contents or Index
(e.g. traffic, open space/farmland land loss)
(e.g. growth inducement)
(e.g. construction noise/traffic/etc.)
(e.g. traffic, loss of biological resources)
(impacts in connection with other projects)
(no feasible mitigation or alternatives)
of Known Controversy
(No Project and Env. Superior)
Measures (in the form of different land use/alternative policies)
Irreversible Changes to the Environment
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:
Modified or new policies in the form of mitigation measures. [same
policy recommendations as on the General Plan]
to the proposed land uses and locations in the form of alternatives.
to the type or mix of land uses (for instance, a higher proportion
of affordable housing).
The DEIR Does Well:
much of the truth about the severity of impacts:
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
analysis of impacts and attempts to show the analytical routes
a No Further Subdivision" and Five Community
The DEIR Falls Down:
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.
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.
DEIR proposes a mitigation measures to monitor" the
impact of these policies rather than truly to mitigate the identified
Choice: Eliminate these policies.
Project Description and Environmental Setting Sections together
create the FOUNDATION of the EIR.
information is omitted or incorrect in these sections, the EIRs
analysis of environmental impacts cannot be adequate.
Description Should Include:
detail to support evaluation and review of environmental impacts
Units and type of units
Coverage of the land
Supporting Public Services/Infrastructure
foreseeable future phases
to Ask When Reviewing the Project Description (the General Plan):
the Project Description (GP) complete? Are there aspects about
the project that are not described accurately? Adequately?
the Project Description of the GP consistent throughout the DEIR?
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.
To Use The EIR To Support GPU Recommendations
goal of commenting on the DEIR is threefold:
Identify flaws in the DEIR that need to be rectified in order for
the document to support informed decision-making = be legally adequate.
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.
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.
on the Project Description
Follow-up Your Comment With a Specific Question
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
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 EIRs 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.
Rural Centers. How many new units/non-residential square feet
will result from development in Rural Centers? Without this information,
the DEIRs 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.
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.
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.
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.
Setting Must Include:
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
of setting information --
description of biological resources, including wildlife corridors,
animal and plant species present in proposed development areas
and in the surrounding region.
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).
about the status of services and infrastructure to accommodate
growth e.g. water; etc.
about the amount of development planned and underway in the cities.
to ask when reviewing the environmental setting sections:
the DEIR accurately and completely describe conditions as they
currently exist? (e.g. sources and uses of water, etc.)
setting information based on adequate and current surveys, other
credible and complete information sources?
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?)
missing setting information should have been developed and included
in the DEIR and why?
Comments on Setting Information:
include the following information in a revised DEIR and revise impact
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?
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.
provide information about the growth trends in adjacent counties
that may affect Monterey Countys growth. (e.g. spillover
of housing demand; increased development in North San Luis Obispo
Environmental Impact Analyses
must be described (quantified where possible) and analyzed (e.g.
acres of each habitat type destroyed; farmland converted).
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.
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.
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
to ask when reviewing the Environmental Analysis Sections:
the underlying assumptions accurate? (e.g. amount of development
at buildout allowed by the Plan; trips generated by new development,
the DEIR analyze and disclose the impacts associated with the
proposed physical development in terms of its scale/amount, location,
the DEIR analyze potential impacts associated with policies?
the DEIR accurately characterize the significance"
of the impact? If not, why not? (lack of information, incorrect
information, lack of analysis, other?)
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?
Does the DEIR omit any significant impacts?
on Adequacy of Environmental Analysis
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.
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.
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.
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.
the General Plan should plan for only that amount of development
that can be served by environmentally sound water supplies.
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
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.
to ask when reviewing the cumulative discussions:
cumulative projects or plans adequately disclosed and quantified?
cumulative impacts adequately disclosed and quantified where possible?
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).
the DEIR identify mitigation measures for cumulative impacts?
projects or planned development potential omitted from the analysis?
Concerning Cumulative Impacts
DEIRs analysis of cumulative impacts to water supply is adequate
for at least the following reasons:
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.
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.
the DEIR lacks analysis" of cumulative water impacts
and simply concludes that impacts will be significant:
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.
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.
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.
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.
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
on Growth Inducing Analysis:
DEIR fails to provide any meaningful analysis of the growth inducing
potential of the General Plans 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
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.
revised environmental document must include an adequate analysis
of the projects potential for growth inducement, including,
but not limited to the following:
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;
extent to which overbuilding high-end housing will result in demand
for additional services and/or induce demand for affordable housing
in adjacent counties.
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.
of Mitigation Measures
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)
impacts by limiting the degree or magnitude of the action and
its implementation (for instance by reducing development and support
the impact by repairing, rehabilitating, or restoring the affected
environment (for instance by replanting vegetation after removal
or eliminate the impacts over time by preservation and maintenance
during the life of the action.
for the impact by replacing or providing substitute resources
or environments (for instance payment of habitat mitigation fee
or permanent protection of habitat land)
with existing regulations or ordinances
already existing natural areas
to Ask About Mitigation Measures:
feasible mitigation measures proposed for each significant impact,
including significant cumulative impacts? The County may not put
off identification of measurable" mitigation until
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?
there other measures that should be identified?
the EIR identify secondary" impacts that may result
from the mitigation measures.
of Mitigation Measures that are Questionable/Unacceptable:
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."
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.
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.
of Feasible Measures (New Policies/Deleted Policies) Omitted from
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
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.
clear about where and what development is allowed only
in the four Community Areas of Boronda, Pajaro, Castroville and
timing, phasing, tiering policies that are confusing. Do not count
on phasing, tiering and other policies to limit development otherwise
permitted by the plan.
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).
new development outside of growth areas (Pajaro, Baronda, Castroville,
Fort Ord) only on legal lots of record.
new subdivisions to those necessary to sustain farming and ranching.
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
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.
DEIR must include a no-project" alternative and identify
the environmentally superior project alternative.
to ask when reviewing alternatives:
there other feasible alternatives that would reduce or eliminate
significant impacts of the project or project alternatives?
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?
Is a sufficient range of alternatives described?
Alternatives We Request Be Analyzed:
are other feasible alternatives that should be analyzed as follows:
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.
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.
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.).
a topic area to review (for instance, land use, biological resources,
the section with the following questions in mind:
the project sufficiently described to ascertain all potentially
significant impacts related to the topic?
there sufficient information about the project setting and regional
setting to support a complete analysis of impacts?
the section identify all potential impacts? Are they properly
characterized as less than significant, significant, etc.
all feasible mitigation measures identified for each significant
the discussion clearly state how each mitigation measure eliminates
or reduces the level of significance of the impact it addresses?
the cumulative impacts related to the topic area adequately analyzed
additional information related to each of the above questions
is required to perfect the discussion? List as questions.
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:
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.
the Economic Impact Analysis says:
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;
than 85 percent of workers need housing priced at $376,000 or
less [Page v].
development should not outpace job development in each area [Page
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].
growth scenarios show a smaller deficit, while the higher growth
scenarios increase the Countys 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
unincorporated Countys 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].
density residential developments generate costs that are much
greater than high or even medium density developments [Page
documenting the fiscal benefits of compact development
addressed the issue in all parts of the country
County should avoid significant amounts of low density development
in rural, poorly served areas
. [Page 22].
land reductions potentially impact this cluster [the Agricultural
Services Cluster], and could erode its dominant position within
the Monterey County economy.
that provide more flexibility regarding use
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].
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].
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 [countys]
economic transition is the rapid escalation of housing prices
throughout the County [Page 62].
is critical that the public infrastructure not degrade
further as new development proceeds [Page 63; emphasis added].
development should not outpace job development in each area [Page
improve our local economy, and to provide good jobs and good housing,
the GPU must:
low-density suburban development and focus growth in existing
Tie new residential development to local job growth
development before needed infrastructure is available
a significant share of permanently affordable housing ($376,000
calls for the kind of flexibility" that will undermine
our agricultural economy
Rancho San Juan
fact, this is what the Twelve Guiding Objectives also require.
Comment Period Ends: April 2, 2004
Monterey County Environmental Resource Policy
230 Church Street, Bldg. 3
Salinas Ca, 93901
Plan Comment Period Ends: March 26, 2004
comments to Genee Terada at above address
22, 2004 (special evening meeting)
Last PUBLIC HEARING before the Planning Commission Decision
of Supervisors Chambers
240 Church Street, 2nd Floor
Salinas, CA 93901
(Planning Commission special daytime meeting)
(Planning Commission recommendations to Board)
28, 2004 If needed
(Planning Commission recommendations to Board)
General Plan Website:
to County Plan Update Issues and Actions]