June 4, 2001
The Honorable Edith Johnsen, Chair
Monterey County Board of Supervisors
120 Church Street
Salinas, CA 93901 [Sent By FAX: 831-755-5888]
RE: General Plan Update Meeting of June 5, 2001, Agenda
Dear Chairperson Johnsen and Board Members:
This letter is to comment on the report presented to you for your
June 5, 2001 meeting, and to suggest several changes to the recommendations
contained in the report.
The staff report notes that on May 30, 2001, the Planning Commission
considered this item. None of the comments made by Members of the
Planning Commission are either mentioned in the staff materials
presented to you, or are incorporated into the recommendations.
The comments made by a number of Commissioners indicate that they
share some of the concerns noted below.
- The "Summary" section of the report begins by stating
that on April 17, 2001, "the Board reaffirmed its commitment
to the 1979 Growth Management Policy as the general guide for
preparing the General Plan Update (emphasis added)." This
is not really an accurate statement. On April 17, 2001, the Board
adopted the following direction: "Reaffirm the 1979 County
Growth Management Policy for use in preparation of the General
Plan Update (emphasis added)."
This difference in language is significant. As the Board may remember,
LandWatch and many others specifically objected to the idea that
the Monterey County 21st Century General Plan should be "based
on" or "guided by" a set of policies first adopted
over twenty years ago. While LandWatch certainly agrees that County
staff can appropriately "use" the 1979 policy in preparing
the new General Plan, we hope that the Board will now make clear
to the staff that the new General Plan will not be "guided
by" the outmoded policies of 1979.
Attached to this letter is a brief critique of the 1979 Growth
Management Policy. We hope you will agree that the 1979 Growth
Management Policy does not provide a solid foundation for the
kind of "world class" General Plan that the Board has
stated it wants to achieve.
- Attachment A contains a number of proposed "General Plan
Objectives." Proposed objective #2 states that the county
should attempt to provide an "adequate land supply
meet projected population needs." This language is extremely
dangerousand a number of your Planning Commissioners agreed.
One much better formulation is contained at the end of this letter.
If the County decides that its objective is to "meet projected
population needs," as set by the State Department of Finance
and transmitted to the County through AMBAG, which is what this
"objective" suggests, it will be turning over its future
to bureaucrats in Sacramento who have no concern whatsoever for
the natural resource or community impacts that their numerical
projections would have in Monterey County. Please remember that
Monterey County and other jurisdictions have been "fighting"
the population projections received this past yearbecause
they completely overlooked water resource and fiscal constraints.
Adopting the "objective" suggested in the staff report
would be to capitulate to the states process.
LandWatch strongly believes that the "objective" of
the Monterey County General Plan should not be to accommodate
growth pressures from outside the county (which is what in large
part is fueling current population growth projections). Instead,
the objective of the Countys General Plan should be to state
what this County wants, in terms of economic development, housing
opportunity, community character, and natural resource protection.
By definition, the County General Plan should be "of, by,
and for" the people of Monterey Countyand it should
never be the "objective" of the plan to "accommodate"
population "projections" made by Sacramento bureaucrats.
Again, our suggested wording is found in the recommendations section
at the end of this letter.
- LandWatch believes that the idea of "Areas of Development
Concentration" (which means new development in unincorporated
portions of the county) should be eliminated from the new General
Plan. Therefore, we propose some different wording for proposed
General Plan Objective #3, as indicated in the recommendations
section at the end of this letter.
- LandWatch believes that proposed General Plan Objective #4 fails
adequately to address the most serious community problem now confronting
Monterey County, namely the need to ensure that future growth
and development actually provides housing for local, working families
with average and below average incomes. A number of Planning Commission
Members shared this concern. We suggest a stronger statement of
the Countys affordable housing objectives, as indicated
in the recommendations section at the end of this letter.
- Attachment B proposes a "Procedure for Consideration of
General Plan and Zoning Amendments." While the idea of separating
proposed General Plan amendments from project proposals is an
idea that LandWatch strongly supports, the specific formulation
contained in Attachment B should be reworked. As written, Attachment
B suggests that General Plan Amendments will be driven by individual
property owner requests for changes in land use designations.
This perpetuates a current problem with land use planning in Monterey
County. Instead of the General Plan providing guidance to individual
landowners, based on a community decision on what makes the most
sense for the community as a whole (and this is what a General
Plan should be), planning tends to be a series of decisions on
individually suggested land use proposals. Often, these make individual
sense (for the property owner), but result in the kind of sprawling
development that it should be the objective of this General Plan
to eliminate. LandWatch suggests alternative language, as attached
to this letter.
LandWatch would also like to note that to the extent that individual
proposals for changes to General Plan land use designations are
specifically considered as part of the current General Plan Update
process, the Environmental Review that must be undertaken for
the General Plan Update will have fully to describe and evaluate
the impacts that might occur if the requested changes are made.
To take the most obvious example, if the County of Monterey decides
to consider the proposed redesignation of the Marks Ranch property
from its current public facilities designation, to accommodate
the request received from the Las Palmas developers who apparently
want to convert it into a new subdivision, the General Plan EIR
must fully analyze all the potential impacts from such a housing
development on the Marks Ranch. A similar detailed environmental
review would need to be undertaken for each landowner-generated
request for a General Plan change. We believe that the County
is not proposing to charge the landowners anything for this review
(though they would be charged for the EIR processing if it were
carried out separately). This represents a major public subsidy
for the proposed developments.
LandWatch Monterey County urges the Board of Supervisors to make
the following changes to the recommendations contained in the report
presented to youand then to adopt the staff recommendation
with those changes:
- The Board of Supervisors should direct the County Planning Department
to use the 1979 Growth Management Policy as the current policy
in force in Monterey County, and to require that all projects
and proposals currently in the permit process be evaluated according
to the principles contained in the 1979 Growth Management Policy.
- The Board of Supervisors should direct the General Plan Update
staff to utilize the "Proposed General Plan Objectives"
(and not the twenty year old 1979 Growth Management Policy) as
the basis upon which to develop a proposed General Plan Update.
We naturally hope that the Board will incorporate into the "Proposed
General Plan Objectives" the specific suggestions for language
changes noted below.
- The Board of Supervisors should use the following language for
proposed objective #2, instead of the language found in the report
submitted to the Board:
"Ensure that there is a supply of land that can meet the
residential, commercial, and industrial development needs of Monterey
County for the next twenty years, taking into account lands located
within the cities."
- The Board of Supervisors should use the following language for
proposed objective #3, instead of the language found in the report
submitted to the Board:
"Preserve a distinction between urban and rural areas by
channeling new growth to areas already committed to an urban level
of development (e.g. cities and densely developed unincorporated
communities), and by reserving rural areas for resource-based
industries (i.e. farming, livestock grazing, mining), natural
resource protection, and open space recreation uses."
- The Board of Supervisors should use the following language for
proposed objective #4, instead of the language found in the report
submitted to the Board:
"Require that new commercial and residential development
demonstrably provide actual new residential housing for working
families in Monterey County, and specifically for families with
average or below average incomes, and strive to achieve a job
and housing balance in all areas."
- The Board of Supervisors should use the language for the Proposed
Procedure for Consideration of General Plan and Zoning Amendments
that is attached to this letter, instead of the language found
in Attachment B to the report submitted to the Board.
Thank you for taking our very strongly felt comments into consideration.
cc: General Plan Update Staff
Members, Monterey County Planning Commission
LandWatch Monterey County Critique*
MONTEREY COUNTY GROWTH MANAGEMENT POLICY (1)
The Board of Supervisors finds and declares that managed growth
and orderly development are essential to the proper utilization
of land in Monterey County. Proper utilization of the land will
contribute directly to the social, cultural, environmental, fiscal,
and economic well-being of the County.
Establishment of Growth Areas
Managed growth must be incorporated into the General Plan of
the County. In so doing, the General Plan must be written
to include appropriate growth areas within the County. These
areas must recognize the diversity among the lands of the County
and provide for the planning of each area in a way that utilizes
its unique characteristics.
In fact, the vast majority of new growth should be directed
into the existing cities. If "growth areas" means
areas where more subdivisions will be allowed in the unincorporated
areas (and that is what we believe that this language is
intended to meanand how it has been used since 1979),
then LandWatch does not believe that such additional subdivision
of unincorporated areas should continue for the next twenty
years. Before planning for more subdivisions in the unincorporated
areas, the county should first analyze how much new construction
can occur on existing lots of record. The amount is mammoth!
Future "development" in rural areas both can and
will continue without any additional subdivisions in rural,
unincorporated areas, because of the many already-existing
lots. A policy of allowing more subdivisions in the unincorporated
area during the next twenty years should not be the "guide"
for future development in Monterey County.
The policies for each planning area to be defined within the
General Plan must countenance differences between the planning
areas in terms of natural resources, physical and environmental
attributes, economic development, and sociocultural development.
Furthermore, growth areas shall be designated only where there
is provision for an adequate level of services and facilities
such as water, sewer, fire protection, and drainage, and be
coordinated with school authorities.
Development of Cities and Areas Around Cities
Cities have been created in Monterey County to provide urban
areas with local governmental services essential to sound urban
development such as sewers, storm drains, water, police protection,
fire protection, neighborhood parks, schools, and community
recreation programs. The ability of cities to cope with the
social, economic, land use, and political problems created by
urbanization is dependent in large part on their ability to
service and control urban development in their urban service
Inhabitants residing in an urban service area of a city have
a community of interest with that city and should be part of
that city so that they may receive necessary city services as
well as participate in, and contribute to, the resolution of
social, political, land use, and economic issues of their urban
community. Except as noted below, urban development should be
discouraged in areas lying outside the boundaries of urban service
areas in order to discourage premature and unnecessary conversion
of open space outside the urban service areas.
New areas of development concentration shall, where appropriate,
be encouraged if they can be shown to better achieve other aspects
of growth management such as the preservation of prime agricultural
lands or the protection of other natural resources. They shall
provide urban services to the residences such as provision of
water, sewage treatment, roads, commercial facilities, schools,
and fire protection. Developments of this type should be proposed
as specific plan amendments to the General Plan.
The idea that the County General Plan should provide for
"new areas of development concentration" is an
idea whose time has come and gone. This is essentially a
proposal for more rural subdivisions (on a large scale)
in the unincorporated parts of the county. In fact, new
development should go into existing areas of development
concentrationi.e., the cities and unincorporated areas
already committed to urban level development, including
the former Fort Ord. That is, incidentally, what other parts
of the 1979 policy require.
Establishment of New Areas of Development Concentration
The following criteria shall be used for the purposes of identifying
any new "areas of development concentration" as that
term is used in the Monterey County Growth Management Policy.
A) The area is not contiguous with existing urban concentrations,
but is in reasonably close proximity to an existing city or
other employment center and contains existing semi-rural development.
B) The area has available, or provision will be made for, appropriate
levels of public services to serve the higher intensity land
uses proposed for areas of development concentration.
C) The parcel sizes and ownerships of the undeveloped land within
the area lend themselves to orderly higher intensity development
rather than piecemeal or sprawl development. Such higher
intensity development may be rural, suburban or urban in character,
depending upon the natural resources, physical and environmental
attributes, economic development, and sociocultural development
of the particular area.
D) A new area shall not under any circumstances be located where
it may adversely impact significant prime or productive agricultural
E) Protection and conservation of the natural resources of the
overall planning area, especially the scenic quality of rural
areas and the preservation of prime agricultural land, will
be enhanced by concentrating development within the designated
This section of the 1979 Growth Management Policy outlines
a proposal for the development of large-scale rural subdivisions.
LandWatch believes that the County should move towards a
set of policies that will direct new growth into existing
areas of development (mostly in the cities), instead of
going into places that are specifically "not contiguous
with existing urban concentrations." To suggest that
this 1979 policy should "guide" the 21st Century
General Plan (along with other principles that completely
contradict this idea) is to perpetuate rural and suburban
sprawl, and to build a fundamental inconsistency into the
foundation of the General Plan.
Open space should be retained wherever advisable to maintain
the rural quality of life in the County. Clustering of development
is to be encouraged. Development should be minimized on visually
sensitive slopes. The density of development outside the urban
service areas of urban concentrations should be low.
Minor subdivision will be discouraged, especially outside urban
service areas. Minor subdivision approval will normally result
in the property being rezoned to prevent further lot divisions.
Environmental research should be conducted on large segments
of the County, coincidental with the planning areas or designated
growth areas or sub-areas where possible. Developers will participate
financially in this research through a prorata cost sharing
arrangement at such time as their projects are filed.
It will be a goal for Monterey County to develop a proportionate
share of housing affordable by low and moderate income families.
A new system of evaluation of applications shall be established.
Each application should be evaluated according to its strengths
and weaknesses in accordance with the General Plan and its policies
and elements, except master plans adopted subsequent to this
policy for planning areas shall be taken into consideration.
Evaluation systems shall be the subject of public hearing before
the Planning Commission and the Board of Supervisors prior to
their adoption. The criteria of evaluation shall be written
and made available to the public. Each applicant shall be given
a numerical score based upon an analysis of the evaluation criteria.
Applications not found to meet minimum evaluation criteria shall
not be given further consideration.
Agriculture continues to be the basis of the economy of the
County. Agricultural lands in Monterey are some of the worlds
finest. Productive agricultural lands are our greatest resource
and must be preserved. Protection of this land can be provided
through the use of such devices as zoning, scenic easements,
and Williamson Act contracts. Furthermore, development of
lands adjoining productive agriculture lands must be nonpolluting
and not otherwise detrimental to the agricultural uses. The
improvement of roads and other facilities serving areas of productive
agricultural lands should be delimited consistent with the agricultural
LandWatch agrees that "productive agricultural lands
be preserved." However, LandWatch believes that stronger
policies than those enumerated will be needed to achieve
that goal. In the next twenty years, Monterey County will
experience much more dramatic growth pressure than it has
over the last twenty years. The explosive development of
the Silicon Valleyand growth in northern San Luis
Obispo Countyare putting Monterey Countys productive
agricultural lands at great risk.
Priorities for Growth
Priority for growth will be given first to infilling within
existing urban areas. The next priority will be for development
on lands adjacent to existing and densely settled urban areas
where the necessary services and facilities are available, except
where this impacts prime and productive agricultural lands.
Growth areas adjoining urban areas shall be within the spheres
of influence of the cities and coincide with the area to which
the cities are providing services or in areas immediately surrounding
high density concentrations with the County such as the Carmel
Valley Village and Castroville, except as in paragraph #3.
This set of priorities is basically inconsistent with the
concept of "new areas of development concentration."
LandWatch suggests that the inconsistency be resolved by
eliminating the "new areas of development concentration"
concept, as noted in our earlier comments.
Low and Moderate Income Housing (3)
A managed growth program must consider, and provide for, the
housing needs of all economic segments of the community. Toward
this goal, it is the Countys intent to increase residential
densities in designated growth areas over those indicated as
land use designations of the County General Plan. Residential
densities may be increased only where such increase is determined
to provide for low and moderate income housing needs and is
in accord with environmental, health, and safety provisions,
and where such increase in density is not unduly excessive and
does not violate policies of the elements of the General Plan.
While LandWatch supports the low and moderate income housing
statements contained in this policy. They are clearly insufficient
to guide the Countys affordable housing efforts for
the next twenty years. LandWatch would support a much stronger
statement of the Countys commitment to the actual
production of affordable housing. For instance: "Require
that new commercial and residential development demonstrably
provide actual new residential housing for working families
in Monterey County, and specifically for families with average
or below average incomes, and strive to achieve a job and
housing balance in all areas."
Proposed Procedure for Consideration of General
Plan and Zoning Amendments
- Because state housing law requires the periodic review and revision
of the General Plan Housing Element on a five-year schedule, and
because the General Plan must be, by law, an internally consistent
document, the Board of Supervisors will undertake a comprehensive
review of the Monterey County General Plan each five years, on
a schedule coordinated with the required review and revision of
the General Plan Housing Element. The Board of Supervisors may
make appropriate revisions to the General Plan at the time of
each such periodic review, and will consider proposed changes
to the General Plan requested by individual property owners in
connection with each five-year review of the General Plan.
- Once each year, during the month of September, the Board of
Supervisors will place an advertisement in all major newspapers
in Monterey County, informing persons who wish to request a change
in the General Plan to submit a letter of interest to the County
of Monterey by January 1 of the year in which the next five-year
review of the General Plan will be carried out.
- Members of the public and property owners may request the Board
of Supervisors to modify the General Plan by filing a letter of
interest by January 1 of the year in which the next five-year
review of the General Plan will be carried out. When such a letter
of interest is received, County staff will enter the request into
the Geographic Information System database, and all such requests
for General Plan changes will be considered during the next five-year
review of the General Plan.
- At the start of the process for the five-year review of the
General Plan, County staff will prepare an initial study of each
request submitted. If a property owner has requested a change
in a land use designation for land in which the property owner
has an interest, and the initial study indicates that the requested
change might have an impact on the environment, and that an Environmental
Impact Report analysis will be required, County staff will so
inform the property owner, and the property owner must make arrangements
to pay for the required environmental analysis.
- During each five-year review of the General Plan, all requests
for General Plan changes proposed for each planning area will
be presented for consideration to the applicable Land Use Advisory
Committee, and the comments of the Land Use Advisory Committee
will be presented to the Planning Commission. The recommendations
of the Planning Commission will be presented to the Board of Supervisors.