Addendum to Coastal Water Project EIR

April 25, 2011

Jane Parker, Chair
Monterey County Board of Supervisors
168 West Alisal, 2nd Floor
Salinas, CA 93901

SUBJECT: AGENDA ITEM S-3: ADDENDUM TO COASTAL WATER PROJECT EIR FOR TEST WELL PROGRAM

Dear Chair Parker and Members of the Board of Supervisors:

LandWatch Monterey County has reviewed the document and has the following comments:

1. The Addendum was released for the first time to the public late Thursday, April 21, for a Tuesday Board meeting. This is not enough time to review the 93 page document especially with missing technical reports.
   
   
2. Because of the addition of substantial new information, identification of new impacts and the addition of new mitigation measures, a subsequent EIR is required (CEQA Guidelines §15164 (3)(D) rather than an Addendum. These matters are addressed in items 3-5 below.
   
   
3. The Addendum states that the test wells would be located within the blue area identified in Revised Figure 5-3, FEIR, Coastal Water Project. Because the maps included in the Addendum are of various scales and geographic features that differ from Revised Figure 5-3, it is impossible to identify where in the blue area the test wells are to be located. Please identify the project location on Revised Figure 5-3.
   
   
4. The Addendum states that surveys conducted since the publication of the CPUC EIR have been completed showing that the California red-legged frogs and tiger salamanders and Santa Cruz long-toed salamanders would not be affected by the proposed project. (p. 49) This study is not included in the Addendum or referenced in the Table of Contents. It should be made available to the public for review.
   
   
5. A new mitigation measure to address impacts to the California legless lizard and coast horned lizard is included in the document based on a NEPA compliance and site-specific Test Well Program biological analyses documented in Appendix 3. (P. 50) This appendix is not included in the Addendum or referenced in the Table of Contents. It should be made available to the public for review.
   
   
6. A new mitigation measure to address impacts to special-status plants is included in the document based on a NEPA compliance and site-specific Test Well Program biological analyses documented in Appendix 3. (P. 50) This appendix is not included in the Addendum or referenced in the Table of Contents. It should be made available to the public for review.
   
   
7. Finally, Appendix 1 is also missing and should be made available for review.

Thank you for the opportunity to review the document.

Sincerely,

Amy L. White
Executive Director

cc:        Division of Ratepayer Advocates, CPUC

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posted 05.05.11