Toro Area News

July 8, 2010

Luis Osorio, Senior Planner
Monterey County Planning Department
168 West Alisal St., 2nd Floor
Salinas, CA 93901

SUBJECT: DEIR FOR CORRAL DE TIERRA NEIGHBORHOOD RETAIL VILLAGE

Dear Mr. Osorio:

LandWatch Monterey County has reviewed the project which would include 10 retail buildings, a one-story grocery store and a two-story office building, totaling 126,523 square feet and 508 parking spaces. We have the following comments:

1. Cumulative Projects List. The list does not include the following projects in the Toro area that are in the County’s permitting process: Christensen (1 unit); Briggs (4); Tjs Development (1); PLN020526 (3); PLN04061 (1); Cdt. Prop. (4); Franscioni (4); Villalobos (4); Silva (2); Provost (1); Amaral (4); Bollenbacher (212); Johnson (4); Avila (11); and CDT Prop. (4) for a total of 259 units. The list should be updated and the cumulative impact analyses adjusted accordingly.
   
   
2. Surface Runoff. The DEIR states (p. 255) that groundwater recharge resulting from an on-site retention/detention system would total 10.04 afy and that this amount would help reduce the overall project water use of 11.34 afy, resulting in a net deficit of 1.30 afy.
   
   Since the current site does not include impervious cover (p. 258), please identify the amount of water currently retained onsite and whether or not that amount was deducted from the 10.04 afy. As noted (p. 263), the project would have a significant and unavoidable impact to groundwater supplies after mitigation.
   
   
3. Consistency with General Plans. The subdivision component (Lot 1) of the Project is inconsistent with certain requirements of the County Code and therefore cannot be approved (pp. 301, 304 and 305). Based on these findings, the proposed project must either be revised or denied.
   
   
4. Traffic Analysis. The document states (p. 374) that the Harper Canyon project is 14 units. The Harper Canyon FEIR identifies the project as having 17 units.
   
   The DEIR finds that with payment of the regional transportation fee, the project level impact would be less than significant. The fee would fund the State Route 68 Commuter Improvements - the widening project from Toro Park to Corral de Tierra. This project is programmed in the Regional Development Impact Fee Strategic Expenditure Plan for construction in the 2025-2030 period. Regional fees will cover $5.9 million of the $24 million estimated total cost. The source of the remaining funds is not identified yet. Without assurance that the project will be completed in a timely manner, project level impacts should be determined to be significant and unavoidable.
   
   
5. Project Alternatives. The reduced density/redesigned project would be the environmentally superior project. Traffic impacts would be similar to those of the proposed project. The DEIR finds this alternative would result in a net benefit to the groundwater basin and would not contribute to a cumulative impact to water supply (p. 478). The net benefit is based on 10.66 afy of recharge to the basin. Please identify the amount of water currently retained onsite and whether or not that amount was deducted from the 10.66 afy.

Thank you for the opportunity to review the document.

Sincerely,

//s//

Amy L. White
Executive Director

June 24, 2010

Jay Brown, Chair
Monterey County Planning Commission
168 West Alisal St., 2nd Floor
Salinas, CA 93901

SUBJECT: HARPER CANYON / ENCINA HILLS PROJECT

Dear Chair and Commissioners:

LandWatch Monterey County commented on the DEIR and the RDEIR. Based on our review of the project and responses to comments, we oppose the Harper Canyon project which would subdivide 344 acres into 17 lots in the Toro area. LandWatch opposes this project because a sustainable water supply does not exist, and the cumulative traffic impacts from this and myriad other projects in the area will create severe congestion on the already over-burdened roadways. Our comments follow:

Water Supply
The FEIR identifies that source of water as wells within Zone 2C of the Salinas Valley Groundwater Basin. Based on our comments submitted on GPU 2010, the Salinas Valley Groundwater Basin is in severe overdraft, and the Salinas Valley Water Project as a source of a long term water supply is unreliable. The Final EIR on GPU 2010 identifies a water balance for the Salinas Basin that projects a tiny surplus as of 2030. This analysis is deeply flawed for the following reasons:

• The water balance analysis is based on baseline and projected water usage from the 2001 Salinas Valley Water Project (“SVWP”) EIR. The SVWP EIR assumed that there would be a net 1,849 acre decrease in agricultural land, whereas the 2007 General Plan EIR projects a net increase of at least 7,682 acres. Water for this increased agricultural acreage will eradicate the tiny surplus projected by the Final EIR and place the basin into substantial overdraft.
  
  
• The FEIR’s attempt to explain that the SVWP EIR remains an adequate basis to project future water supply and demand notwithstanding the increase in agricultural acreage double counts the savings the SVWP EIR projected from more efficient irrigation and changes in cropping patterns.
  
  
• The SVWP EIR baseline 1995 pumping assumptions understate actual pumping as of 1995 by 44,268 afy, based on annual pumping data reported by the MCWRA and included in the DEIR. The SVWP’s understatement of baseline pumping is two orders of magnitude greater than the 542 afy projected 2030 surplus in the FEIR. Despite this, the FEIR cites this actual pumping data to support its contention that the SVWP EIR “remains a solid basis” for evaluating future demand.
  
  
• The FEIR claims that the urban demand projections in the SVWP EIR are consistent with the FEIR’s water balance analysis, even though the FEIR projects a 46% greater urban population than the SVWP EIR. To make this claim, the FEIR “restates” the SVWP’s urban demand projection using fundamentally different population and water use assumptions, and making unexplained “minor adjustments” that are an order of magnitude larger than the FEIR’s projected 542 afy surplus.

Traffic
The FEIR acknowledges that cumulative traffic impacts would be significant and unavoidable. Numerous projects along the Highway 68 corridor are either in the planning process or included in GPU2010. Major projects include Laguna Seca Villas (104 units); Bolendecker (212 units); Affordble Housing Overlay at the intersection of Reservation Road (356 units) and the Airport/Highway 68 AHO (976 units). Intensification of development beyond that allowed on legal lots of record is unsupportable until severe traffic congestion along this corridor is addressed and mitigation measures to meet the LOS standard are funded.

Thank you for the opportunity to comment.

Sincerely,

//s//

Amy L. White, Executive Director