Agenda packet — Monterey City Council, July 16, 2024 (part 15 of 22)

Meredith Harrill - Fisherman’s Flats
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2026, Packet Page 2354 3/5/24, 3:49 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/3 Feedback on Monterey City Draft Housing Plan
andrew hawryluk
Tue 3/5/2024 3:29 PM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Dear Ms. Sabdo;
My wife and I are residents near the proposed housing project for 640 units off Highway 68 currently owned by the Monterey Peninsula School District. I want to express my objection to this proposal. There are many proposals for housing near the airport and the cumulative impact of all these units will be unacceptable for a variety of reasons that I outline below. These proposed housing units include new housing along Garden Court, a County proposal for 1324 units along Olmsted Road and your 640 units in Tarpy Flats. Taken together, there are approximately 2000 new housing units being proposed within a small area with no planned increase in infrastructure. While I support the need for additional residential development that is affordable to ensure hard working people can afford to live and work in Monterey County, several of the proposed sites are of particular concern especially given the high density.

The two projects that I especially object to are the County's 1324 units being proposed off Olmstead Rd and the city of Monterey's 640 units being proposed for land that was previously designated for education. Both of these projects violate the State of California's desire for infill on already developed land. They also violate the Governor’s “30x30” initiative (https://www.californianature.ca.gov) and the Scenic Highway designation of Highway 68. My objections are based upon the following:
*Traffic on Olmstead Road and Highway 68, including the proposed roundabout: The approximately 2000 additional housing units will likely produce 5000 additional car-trips through the already congested Olmstead-Highway 68 intersection. The expansion of the airport facilities and proposed housing on South Boundary Rd and the current courthouse off Aguajito Rd. would make traffic even worse. Enormous costs of widening Hwy 68 would be paid for by taxpayers. There is currently no mass transit in the area. What is the plan to mitigate the impact of all this extra traffic? The additional congestion through that intersection will make the airport less appealing to travelers and will likely push flyers to the San Jose airport. Has the impact of this congestion been evaluated or discussed with the Airport?
*Environmental impact and vanishing Greenbelt: The removal of this greenbelt is a significant adverse impact aesthetically and a huge contrast from the scenic easement that gives this area such a special character. It is also a loss of habitat for many keystone animal species that can be observed on the subject parcel. Frequent observations occur of Apex/keystone species such as Mountain Lion, Bobcat and Coyote as well as many avian species of special interest. Does the County understand the implications of eliminating this biological corridor? The current residential zoning in this area is one home per 10 acres to allow for new residential development, while still preserving the rural character of this beautiful area. How does such a high density (10-20 units per acre) fit into this environment? I don't understand how a designated scenic corridor can be turned into a high ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2027, Packet Page 2355 3/5/24, 3:49 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/3 density set of houses and roads. That is not in the spirit of what California state criteria is for affordable housing and it is in direct conflict with the governor’s 30x30 initiative.
*Lack of Infrastructure. At present, there exists no infrastructure for this development. Water, sewer, power, etc., will all have to be brought in. Streets will have to be constructed. There is no public transportation. The local streets (particularly HW 68 and 218) cannot support the additional traffic burden and will have to be modified to support the additional load. There are no stores nearby (which will cause additional car usage and traffic). The costs for the additional infrastructure will be high and will have to be transferred to the residents, increasing the cost of the development, and making it less likely to be successful. A more costefficient approach is to reuse existing, under-utilized facilities that already have streets, water, sewer, power, etc. *Flight Crash Risk. 2 years ago, there was a crash into an unoccupied single-family home in the Monterra neighborhood. If such an incident were to occur in a high-density community, there could be a substantial loss of life. Similar incidents have occurred in California (i.e. Truckee with a private jet, as well as Naples FLA recently). Has the city of Monterey and County consulted with Monterey Regional Airport on the flight crash risk specific to the subject property? *Fire Protection. This development would come with the extraordinary expense of added fire response personnel and equipment. This is compounded by traffic jams adding to response times. Additionally, one of the important functions of the existing greenbelt zoning gives the entire community an important firebreak. CALFIRE depends on this parcel for fire protection of this whole region. These parcels were an important staging area for firefighters during the last fire just three years ago and we would lose that critical capability if this land were to be developed. Does the city of Monterey and County comprehend the magnitude of additional risk of wildfire this abandonment of firebreak will produce, given the forest densities to the east and west? Is the city of Monterey and County prepared to assume liability for a future wildfire disaster, which could have been prevented by preservation of this critical firebreak? Has the County consulted with CALFIRE on the details of how this firebreak is vital to community safety along the entire Hwy 68 corridor?
*Air Quality. The additional traffic, especially considering the projected congestion and idling, will cause significant deterioration in local air quality, both to onsite residents of the new development and to nearby existing populations. The specific pollutants of public health concern are sulfur dioxide, oxides of nitrogen, carbon monoxide and carbon fiber from tires. Is the County aware that approximately 20,000 deaths per annum occur in the United States from these air pollutants? How will this be mitigated for current and future residents?
*Quality and Availability of Water: If the moratorium on drilling wells is lifted, is there data to support that the onsite wells can provide sufficient healthy ground water for over 3000 new residents for the County development and ~1000 for the Monterey city development without being a detriment to the current ground water supply? It is well established that there are a number of carcinogenic and toxic chemicals in the groundwater emanating from Fort Ord. It is also known that this subsurface water plume is presently moving in the direction of the proposed rezoning parcel, if not already present beneath the subject parcel. This is a serious threat to residents of the subject parcels, particularly to children who will predictably explore the soils of their neighborhood. See for example: Cancer cluster at Fort Ord: Sick vets wonder, are there more of us? (thecalifornian.com) .

Thank you for including my input. I would encourage you to look at using ADUs and other infill strategies using land that has already been developed and is not being fully utilized, such as empty lots next to MPC and Casa Verde, the old courthouse and ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2028, Packet Page 2356 3/5/24, 3:49 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 3/3 hospital, as well as parcels around Cannery Row.

Regards,
Andrew Hawryluk, Ph.D.
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ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2029, Packet Page 2357 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2030, Packet Page 2358 Subject: Significant concern with 640 unit development off Highway 68 We are nearby residents of the proposed housing project for 640 units off Highway 68 currently owned by the Monterey Peninsula School District. I'm shocked with all the development being proposed all around the airport/68, including the Garden Court development, the 1324 units being proposed by the county, and the Boundary Road project with significant units in the Ryan Ranch area. Does anyone care about the cumulative effects of all these developments on an area that already is struggling with traffic and was designated a scenic corridor? Many of us moved to this area to escape the urbanization and densification in other parts of California. While I support the need for additional residential development that is affordable to ensure hard working people can afford to live and work in Monterey County, several of the proposed sites are of particular concern especially given the high density.

*Traffic on Olmstead Road and Highway 68, including the proposed roundabout: It can be estimated that Monterey's proposed development could generate up to 1600 extra cars per day and the County's project 3250 extra cars per day. This would be approximately 5000 more cars in an area already dense with traffic and backups, especially during commute windows. The assumption is 2.5 car trips per housing unit per day). The expansion of the airport facilities and new apartments on Garden Rd and proposed housing on South Boundary Rd and the current courthouse off Aguajito Rd. would make traffic even worse. Enormous costs of widening Hwy 68 would be paid for by taxpayers. There is currently no mass transit in the area. What is the plan to mitigate the impact of all this extra traffic? *Environmental impact and vanishing Greenbelt: The removal of this greenbelt is a significant adverse impact aesthetically and a huge contrast from the scenic easement that gives this area such a special character. It is also a loss of habitat for many keystone animal species that can be observed on the subject parcel. Frequent observations occur of Apex/keystone species such as Mountain Lion, Bobcat and Coyote as well as many avian species of special interest. Does the County understand the implications of eliminating this biological corridor? The current residential zoning in this area is one home per 10 acres to allow for new residential development, while still preserving the rural character of this beautiful area. How does such a high density (10- 20 units per acre) fit into this environment? I don't understand how a designated scenic corridor can be turned into a high density set of houses and roads. That is not in the spirit of what California state criteria is for affordable housing.

*Pedestrian and Bicycle safety: It is not clear the roads in and out of the 640 unit housing complex since there would need to be at least one additional road for entry in ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2031, Packet Page 2359 and out. Is this also going to be onto Olmstead Road through the County's development? Olmstead Rd would go from a quiet rural road to a very busy urban one. What is the plan for pedestrian and bike safety with a high volume of cars coming in and out onto Olmstead on both sides of the street? Are you planning to access the development directly from Highway 68? This would also pose significant safety risks.

*Flight Crash Risk. 2 years ago, there was a crash into an unoccupied single-family home in the Monterra neighborhood. If such an incident were to occur in a high-density community, there could be a substantial loss of life. Similar incidents have occurred in California (i.e. Truckee with a private jet, as well as Naples FLA recently). Has the city of Monterey and County consulted with Monterey Regional Airport on the flight crash risk specific to the subject property?

*Fire Protection. This development would come with extraordinary expense of added fire response personnel and equipment. This is compounded by traffic jams adding to response times. Additionally, one of the important functions of the existing greenbelt zoning gives the entire community an important firebreak. CALFIRE depends on this parcel for fire protection of this whole region. These parcels were an important staging area for firefighters during the last fire just three years ago and we would lose that critical capability if this land were to be developed. Does the city of Monterey and County comprehend the magnitude of additional risk of wildfire this abandonment of firebreak will produce, given the forest densities to the east and west? Is the city of Monterey and County prepared to assume liability for a future wildfire disaster, which could have been prevented by preservation of this critical firebreak? Has the County consulted with CALFIRE on the details of how this firebreak is vital to community safety along the entire Hwy 68 corridor?

*Police Protection. This proposed rezoning will place an untenable burden on our existing police resources, which already are in critical shortage. This is not only a public safety threat, but also an extraordinary economic impact by placing 3000 new residents with the county's Olmstead development and ~1500 with Monterey's development in locations, which are not even conveniently serviced for the expected demand level. Has the Monterey County sheriff been consulted and are they prepared to handle this high density loading and increased risk?

*Air Quality. The additional traffic, especially considering the projected congestion and idling, will cause significant deterioration in local air quality, both to onsite residents of the new development and to nearby existing populations. The specific pollutants of public health concern are sulfur dioxide, oxides of nitrogen, carbon monoxide and carbon fibre from tyres. Is the County aware that approximately 20,000 deaths per annum occur in the United States from these air pollutants? How will this be mitigated for current and future residents?

*Quality and Availability of Water: If the moratorium on drilling wells is lifted, is there data to support that the onsite wells can provide sufficient healthy ground water for over 3000 new residents for the County development and ~1500 for the Monterey city ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2032, Packet Page 2360 development without being a detriment to the current ground water supply? It is well established that there are a number of carcinogenic and toxic chemicals in the groundwater emanating from Fort Ord. It is also known that this subsurface water plume is presently moving in the direction of the proposed rezoning parcel, if not already present beneath the subject parcel. This is a serious threat to residents of the subject parcels, particularly to children who will predictably explore the soils of their neighborhood. See for example: Cancer cluster at Fort Ord: Sick vets wonder, are there more of us? (thecalifornian.com) .

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2033, Packet Page 2361 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2034, Packet Page 2362 Subject: Significant concern with 640 unit development off Highway 68 We are nearby residents of the proposed housing project for 640 units off Highway 68 currently owned by the Monterey Peninsula School District. I'm shocked with all the development being proposed all around the airport/68, including the Garden Court development, the 1324 units being proposed by the county, and the Boundary Road project with significant units in the Ryan Ranch area. Does anyone care about the cumulative effects of all these developments on an area that already is struggling with traffic and was designated a scenic corridor? Many of us moved to this area to escape the urbanization and densification in other parts of California. While I support the need for additional residential development that is affordable to ensure hard working people can afford to live and work in Monterey County, several of the proposed sites are of particular concern especially given the high density.

What is the plan for pedestrian and bike safety with a high volume of cars coming in and out onto Olmstead on both sides of the street? Are you planning to access the development directly from Highway 68? This would also pose significant safety risks. *Flight Crash Risk. 2 years ago, there was a crash into an unoccupied single-family home in the Monterra neighborhood. If such an incident were to occur in a high-density community, there could be a substantial loss of life. Similar incidents have occurred in California (i.e. Truckee with a private jet, as well as Naples FLA recently). Has the city of Monterey and County consulted with Monterey Regional Airport on the flight crash risk specific to the subject property?
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2035, Packet Page 2363 *Fire Protection. This development would come with extraordinary expense of added fire response personnel and equipment. This is compounded by traffic jams adding to response times. Additionally, one of the important functions of the existing greenbelt zoning gives the entire community an important firebreak. CALFIRE depends on this parcel for fire protection of this whole region. These parcels were an important staging area for firefighters during the last fire just three years ago and we would lose that critical capability if this land were to be developed. Does the city of Monterey and County comprehend the magnitude of additional risk of wildfire this abandonment of firebreak will produce, given the forest densities to the east and west? Is the city of Monterey and County prepared to assume liability for a future wildfire disaster, which could have been prevented by preservation of this critical firebreak? Has the County consulted with CALFIRE on the details of how this firebreak is vital to community safety along the entire Hwy 68 corridor?
*Police Protection. This proposed rezoning will place an untenable burden on our existing police resources, which already are in critical shortage. This is not only a public safety threat, but also an extraordinary economic impact by placing 3000 new residents with the county's Olmstead development and ~1500 with Monterey's development in locations, which are not even conveniently serviced for the expected demand level. Has the Monterey County sheriff been consulted and are they prepared to handle this high density loading and increased risk?
*Air Quality. The additional traffic, especially considering the projected congestion and idling, will cause significant deterioration in local air quality, both to onsite residents of the new development and to nearby existing populations. The specific pollutants of public health concern are sulfur dioxide, oxides of nitrogen, carbon monoxide and carbon fibre from tyres. Is the County aware that approximately 20,000 deaths per annum occur in the United States from these air pollutants? How will this be mitigated for current and future residents?
*Quality and Availability of Water: If the moratorium on drilling wells is lifted, is there data to support that the onsite wells can provide sufficient healthy ground water for over 3000 new residents for the County development and ~1500 for the Monterey city development without being a detriment to the current ground water supply? It is well established that there are a number of carcinogenic and toxic chemicals in the groundwater emanating from Fort Ord. It is also known that this subsurface water plume is presently moving in the direction of the proposed rezoning parcel, if not already present beneath the subject parcel. This is a serious threat to residents of the subject parcels, particularly to children who will predictably explore the soils of their neighborhood. See for example: Cancer cluster at Fort Ord: Sick vets wonder, are there more of us? (thecalifornian.com) .

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2036, Packet Page 2364 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2037, Packet Page 2365 Subject: Significant concern with 640 unit development off Highway 68 We are nearby residents of the proposed housing project for 640 units off Highway 68 currently owned by the Monterey Peninsula School District. I'm shocked with all the development being proposed all around the airport/68, including the Garden Court development, the 1324 units being proposed by the county, and the Boundary Road project with significant units in the Ryan Ranch area. Does anyone care about the cumulative effects of all these developments on an area that already is struggling with traffic and was designated a scenic corridor? Many of us moved to this area to escape the urbanization and densification in other parts of California. While I support the need for additional residential development that is affordable to ensure hard working people can afford to live and work in Monterey County, several of the proposed sites are of particular concern especially given the high density.

The two I especially object to are the County's 1324 units being proposed off Olmstead Rd and the city of Monterey's 640 units being proposed for land that was previously designated for education. Both of these projects violate the State of California's desire for infill on already developed land and pose significant risk, including:
*Traffic on Olmstead Road and Highway 68, including the proposed roundabout: It can be estimated that Monterey's proposed development could generate up to 1600 extra cars per day and the County's project 3250 extra cars per day. This would be approximately 5000 more cars in an area already dense with traffic and backups, especially during commute windows. The assumption is 2.5 car trips per housing unit per day). The expansion of the airport facilities and new apartments on Garden Rd and proposed housing on South Boundary Rd and the current courthouse off Aguajito Rd. would make traffic even worse. Enormous costs of widening Hwy 68 would be paid for by taxpayers. There is currently no mass transit in the area. What is the plan to mitigate the impact of all this extra traffic? *Environmental impact and vanishing Greenbelt: The removal of this greenbelt is a significant adverse impact aesthetically and a huge contrast from the scenic easement that gives this area such a special character. It is also a loss of habitat for many keystone animal species that can be observed on the subject parcel. Frequent observations occur of Apex/keystone species such as Mountain Lion, Bobcat and Coyote as well as many avian species of special interest. Does the County understand the implications of eliminating this biological corridor? The current residential zoning in this area is one home per 10 acres to allow for new residential development, while still preserving the rural character of this beautiful area. How does such a high density (10- 20 units per acre) fit into this environment? I don't understand how a designated scenic corridor can be turned into a high density set of houses and roads. That is not in the spirit of what California state criteria is for affordable housing. *Pedestrian and Bicycle safety: It is not clear the roads in and out of the 640 unit housing complex since there would need to be at least one additional road for entry in ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2038, Packet Page 2366 and out. Is this also going to be onto Olmstead Road through the County's development? Olmstead Rd would go from a quiet rural road to a very busy urban one. What is the plan for pedestrian and bike safety with a high volume of cars coming in and out onto Olmstead on both sides of the street? Are you planning to access the development directly from Highway 68? This would also pose significant safety risks. *Flight Crash Risk. 2 years ago, there was a crash into an unoccupied single-family home in the Monterra neighborhood. If such an incident were to occur in a high-density community, there could be a substantial loss of life. Similar incidents have occurred in California (i.e. Truckee with a private jet, as well as Naples FLA recently). Has the city of Monterey and County consulted with Monterey Regional Airport on the flight crash risk specific to the subject property?
*Fire Protection. This development would come with extraordinary expense of added fire response personnel and equipment. This is compounded by traffic jams adding to response times. Additionally, one of the important functions of the existing greenbelt zoning gives the entire community an important firebreak. CALFIRE depends on this parcel for fire protection of this whole region. These parcels were an important staging area for firefighters during the last fire just three years ago and we would lose that critical capability if this land were to be developed. Does the city of Monterey and County comprehend the magnitude of additional risk of wildfire this abandonment of firebreak will produce, given the forest densities to the east and west? Is the city of Monterey and County prepared to assume liability for a future wildfire disaster, which could have been prevented by preservation of this critical firebreak? Has the County consulted with CALFIRE on the details of how this firebreak is vital to community safety along the entire Hwy 68 corridor?
*Police Protection. This proposed rezoning will place an untenable burden on our existing police resources, which already are in critical shortage. This is not only a public safety threat, but also an extraordinary economic impact by placing 3000 new residents with the county's Olmstead development and ~1500 with Monterey's development in locations, which are not even conveniently serviced for the expected demand level. Has the Monterey County sheriff been consulted and are they prepared to handle this high density loading and increased risk?
*Air Quality. The additional traffic, especially considering the projected congestion and idling, will cause significant deterioration in local air quality, both to onsite residents of the new development and to nearby existing populations. The specific pollutants of public health concern are sulfur dioxide, oxides of nitrogen, carbon monoxide and carbon fibre from tyres. Is the County aware that approximately 20,000 deaths per annum occur in the United States from these air pollutants? How will this be mitigated for current and future residents?
*Quality and Availability of Water: If the moratorium on drilling wells is lifted, is there data to support that the onsite wells can provide sufficient healthy ground water for over 3000 new residents for the County development and ~1500 for the Monterey city ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2039, Packet Page 2367 development without being a detriment to the current ground water supply? It is well established that there are a number of carcinogenic and toxic chemicals in the groundwater emanating from Fort Ord. It is also known that this subsurface water plume is presently moving in the direction of the proposed rezoning parcel, if not already present beneath the subject parcel. This is a serious threat to residents of the subject parcels, particularly to children who will predictably explore the soils of their neighborhood. See for example: Cancer cluster at Fort Ord: Sick vets wonder, are there more of us? (thecalifornian.com) .

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2040, Packet Page 2368 3/25/24, 10:03 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/2 General Plan comments
Daian Hennington
Mon 3/25/2024 9:43 AM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Dear City of Monterey:

I am writing to express my concern and objection to planned construction near Highway 68 and Olmstead and Garden Roads.

As a retired County Social Worker, I understand the requirement to provide affordable housing. However, the 640 unit city development and the 1324 units proposed by the County are unsustainable in this area.

First, there is no water to sustain this degree of development on the Peninsula. CalAm has already over-drafted the Carmel River. Whatever “water credit” planning there may be can’t possibly meet the water needs of this many homes and the families who would live there. I live in the Jacks Peak area and my home is served by wells managed by Canada Woods Water. My understanding is that this water already requires significant treatment due to mineral content. In addition, I worry that any new wells in the meadow area of Tarpy’s Flat will deplete existing water resources and lead to dry wells, as we have seen happen in Prunedale. Jack’s Peak acts as a watershed and the lower meadow area certainly is a catchment basin that maintains the water table, keeps trees and vegetation alive and serves area wells. Lowering the water table leads to more dead Oak and Pine trees and a high fire risk; you can see the effects of a lower water table in the Del Monte Forest area. Paving over this area for streets and houses will irrevocable damage this water resource.

The open space meadow at Tarpy’s Flat serves other functions in addition to capturing water. It is a carbon sink. Studies show that grasslands serve as carbon sinks and assist with climate management. It is a home to wildlife and a corridor linking Ft Ord, with Jacks Peak, Los Padres and beyond. I think that although the area has been in private hands and not studied like Ft Ord, there may be rare and endangered biota in addition to already at risk Coast Oak, Monterey Pine, Mountain Lions, Bobcats, the occasional Bear and the like. Like the Bay, this meadow is the first impression of Monterey entering from the Airport and from Salinas. It showcases the beauty of our area for visitors and locals alike.

I have safety concerns as well. This particular junction at Hwy 68 and Olmstead/Garden Road cannot manage the level of traffic.

Even if a new intersection is built I don’t see how this many people will get through that small a space. With the number of units being proposed it follows that there would be more children. The risk of injury would increase with possibly children walking to school and middle and high school students catching a bus into town. The airport poses a risk with potential airplane crashes as we have seen recently. Only, the crash might be on a house close to the airport instead of on the golf course. Air quality would deteriorate due to traffic, and more buildings, fewer trees. Then there is the cost of police and fire service.

Smart development practices recommend using in-fill with lower density and walkable neighborhoods. Certainly, the amount of suggested units can be spread across the area and not centered in one dense area and could use other sites having ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2041, Packet Page 2369 3/25/24, 10:03 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/2 infrastructure readily accessible.

Thank you for your attention.

Sincerely,
Daian & Glenn Hennington
Monterey 93940
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ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2042, Packet Page 2370 3/19/24, 4:40 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/1 Olmsted Road Residential Proposals
Michael H
Tue 3/19/2024 2:45 PM
To:Christy Sabdo <[email protected]>
You don't often get email from . Learn why this is important The proposal to develop the Olmsted Road property for high density residential is the worst idea for residential development that i have seen in my three decades of work as an environmental scientist, where i have been the principal in charge of over 1500 Environmental Impact Reports applying CEQA,

1. Are you aware that the Olmsted pasture is a critical open land firebreak, essential for stopping wildfires in the Hwy 68 Corridor? It has been used for firefighting staging, but more importantly serves as an essential fireb

2. Have you analyzed the risk to new residents of an Olmsted development, in regard to risk of aircraft crash risk? An aircraft crash in Monterra occurred in 2021; the Olmsted site is much more likely at risk for a crash, w

3. Are you aware of the high single event sound levels that exist at the Olmsted site? They are at an intensity that causes the slow degradation of human hearing; additionally, a child crossing one of the streets could not

4. Have you calculated the increase of air pollutants from automobile operations in the vicinity of the Olmsted development? Dr. C. Michael Hogan, an expert in air quality modeling has calculated that the concentration o SIGNED
Dr. C. Michael Hogan
Monterey
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2043, Packet Page 2371 3/7/24, 5:04 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/3 Comment about Draft Program EIR for the Monterey 2031 General Plan Update Housing Element Grant Hunt <
Wed 3/6/2024 3:05 PM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Ms. Christy Sabdo, AICP ([email protected])
Senior Associate Planner
City of Monterey, Planning Division

VIA E-MAIL
Dear Ms. Sabdo:

The email is being sent in response to your invitation for comments to the 45-day Public Review of the Draft Program EIR for the Monterey 2031 General Plan Update commenting specifically about the 2023-31 Housing Element Revised Draft - Volume 1.

This email is to voice my strenuous opposition to the inclusion of the Monterey Peninsula Union School District owned property located adjacent to SR-68 between Olmsted Road and Canyon del Rey Blvd. in the Housing Element. I have several distinct concerns that I list below.

Housing Density and Traffic
The housing element proposes the development of 640 units of various types of housing on a land locked property owned by MPUSD. While an easement for development must be offered by law, one questions where access would be granted. A driveway off SR-68? Caltrans has strongly resisted adding access to SR-68 because of the already over-taxed traffic in that area. Perhaps access from the SR68-SR218 merge? That also taxes an already overburdened intersection. Neither option seems optimal.

This proposed location abuts a County-proposed addition of 1,324 units of housing on unincorporated Monterey property also adjacent to SR-68 stretching from Olmsted Road to this city-proposed development. Let’s assume for the sake of argument that each housing unit averages four residents, these two proposals alone add 7,856 residents onto one of the last areas of environmental greenbelt left in the City.

Now, one needs to also add in the three Garden Road developments that are permitted and are well on their way to being built. The three Garden Road properties are permitted for 146 housing units. Again, using the 4 residents per housing unit assumption that I cited above, another 584 residents are being added that will use the Olmsted/SR-68 intersection. The traffic impact of perhaps 7,000 +/-instances of ingress and egress per day is enormous.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2044, Packet Page 2372 3/7/24, 5:04 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/3 Highway 68 is a designated Scenic Highway by the State. It seems very difficult to square this designation with the huge amount of additional traffic that these three potential developments will dictate.

Cumulative Effect
The cumulative effect of these three proposals could theoretically add nearly 8,500 residents to a several block area of Monterey. Using 2021 U.S. census data, there are roughly 29,874 residents in Monterey. These three projects would add more than 28% of the current total city population in a small area of open space. This certainly seems like a policy overreach without any underlying facts supporting it.

The trend of population growth in Monterey is not positive; but rather it is negative. The population of Monterey 30 years ago was 32,567 and it has steadily trended downwards by 9% since then. Why does the City propose increasing the housing stock for a dwindling population? Why does the City propose such a drastic high-density housing project in this area that is surrounded by residential zoning of one home per acre? Those are diametrical opposites that our city planning experts are supposed to consider. Everyone realizes that affordable housing is a challenge statewide, but adding such staggering amounts of high-density urban housing seems like policy makers are trying to shoot a squirrel with a bazooka.

Environmental and Wildfire Concerns
The area proposed in this part of the housing element is one of the last remaining open spaces in Monterey. As such, it is the habitat of many species of wildlife that will be displaced with this proposed development. Obviously, wildlife does not trump human population growth, BUT our population is not growing! It is extremely difficult to square up the logic for including high density urban housing when the need for such a development is suspect (to say the least).

CAL FIRE has stated that this property, along with the adjoining properties currently being included in other housing elements, are part of their fire mitigation planning for the area. This is a two-fold plan by CAL FIRE. First, these areas serve as a key fire break in the case of the inevitable future urban wildfire like others that have previously plagued our beautiful county. Losing this defensible space could cause a horrifying conflagration that no one wants to consider. Second, this flat open space is also planned as a staging area for fire equipment in case of a large wildfire.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2045, Packet Page 2373 3/7/24, 5:04 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 3/3 May I kindly ask that you acknowledge receipt of this email and add it to the official comments? Grant Hunt
Monterey, CA
[NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2046, Packet Page 2374 3/18/24, 1:10 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/3 Response to Housing Element Proposal for MPUSD property Susan Hunt
Mon 3/18/2024 1:01 PM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Ms. Christy Sabdo, AICP ([email protected])
Senior Associate Planner
City of Monterey, Planning Division

VIA E-MAIL
Dear Ms. Sabdo:

This email is to voice my strenuous opposition to the inclusion of the Monterey Peninsula Union School District owned property located adjacent to SR-68 between Olmsted Road and Canyon del Rey Blvd. I have several distinct concerns that I list below.

Housing Density and Traffic
The housing element proposes the development of 640 units of various types of housing on a land locked property owned by MPUSD.

While an easement for development must be offered by law, one questions where access would be granted. A driveway off SR-68? Caltrans has strongly resisted adding access to SR-68 because of the already over-taxed traffic in that area. Perhaps access from the SR68- SR218 merge? That also taxes an already overburdened intersection. Neither option seems optimal.

This proposed location abuts a proposed addition of 1,324 units of housing on unincorporated Monterey property also adjacent to SR-68 stretching from Olmsted Road to this city-proposed development. Let’s assume for the sake of argument that each housing unit averages four residents, these two proposals alone add 7,856 residents onto one of the last areas of environmental greenbelt left in the City.

Now, one needs to also add in the three Garden Road developments that are permitted and are well on their way to being built. The three properties are permitted for 146 housing units. Again, using the 4 residents per housing unit assumption that I cited above, another 584 residents are being added that will use the Olmsted/SR-68 intersection. The traffic impact of perhaps 7,000 instances of ingress and egress per day is enormous.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2047, Packet Page 2375 3/18/24, 1:10 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/3 Highway 68 is a designated Scenic Highway by the State. It seems very difficult to square this designation with the huge amount of additional traffic that these developments will dictate.

Water
So, our Peninsula residents have been told for decades that there is no additional water for property development; but now there is plentiful supply to add housing for a massive addition of 28,000 residents? Wait, what? Is it any wonder than no one trusts anything that our government officials say any longer?
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2048, Packet Page 2376 3/18/24, 1:10 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 3/3 If the plan for this property is to tap an underground aquifer, has there been any consideration as to the effect on those nearby water users that are also using well water such as the Monterey Peninsula Regional Airport and Cañada Woods Water Company? For these reasons, I strongly request that you remove this property from the Housing Element of this proposal.

May I kindly ask that you acknowledge receipt of this email and add it to the official comments? Susan Hunt
Monterey
[NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2049, Packet Page 2377 3/21/24, 9:54 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/3 Proposed Olmsted housing development
Stuart Jacobs
Wed 3/20/2024 11:45 AM
To:Christy Sabdo <[email protected]>
Cc:Jacobs Dermatology
You don't often get email from Learn why this is important Dear Ms. Sabdo:

I am writing to provide you with my comments regarding the Draft EIR for the Monterey 2031 General Plan Update.

The proposed housing plan for the City of Monterey includes developing a 50 acre parcel on Highway 68. Developing this parcel would have a significant negative impact on the Highway 68 Scenic Corridor and on the environment, in general, especially as it would increase traffic congestion on Highway 68 and the surrounding rural roads. The parcel is in an area that is labeled as a “highly sensitive viewshed.” There has already been extensive development in the Highway 68 Scenic Corridor as evidenced by the airport runway extension, the Highway 68 car condos, and the Montage Ohana building that was inexplicably allowed to loom over the highway. At least, the south side of the highway has maintained a scenic rural character. If that is now developed, the designation of Highway 68 as a scenic corridor would be in jeopardy.

The population of Monterey has actually decreased by 2.2% over the past 3 years and is projected to continue to decrease. The source of these projections, AMBAG, states
that employment drives growth, but projected employment growth does not support the numbers used as the basis for the proposed housing development plan. The Proposed Plan assumes that, by 2031, employment in Monterey will grow by 8.3%, but population will grow by 37.6%, and somehow that necessitates a 41.9% growth in housing units.

For each new job, it is proposed that approximately 5 people will move to Monterey. Is population growth outpacing employment growth due to the birth rate and/or due to the number of unemployed (potentially retired) people expected to move to Monterey? If it is the birth rate, it should be noted that children live in the same housing unit as their parents so there should not be a need for 3 times as many housing units as new jobs, as is proposed.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2050, Packet Page 2378 3/21/24, 9:54 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/3

It leads one to wonder if perhaps the
Highway 68 parcel is included because an influential developer would like to build on it at the expense of the Highway 68
Scenic Corridor, the environment, and the general
enjoyment and welfare of the community.

Goal 7
, entitled “Maintain Existing Housing” , states that the city wants to “assure high quality maintenance, safety, and habitability of existing housing resources.” If this is so, why not have programs to rehabilitate and remodel existing housing, especially in core areas of the city? If you build an excess of new housing and significantly increase vacancy rates and decrease rental rates, it is well known that landlords will not be willing or able to maintain existing properties. The result will be some nice new buildings along Highway 68 while the appearance of Monterey's central district continues to degrade.

Goal 8
states that appropriate housing sites “are proximate to transportation, shopping and schools...” This goal is in line with the State of California’s goal to promote infill as a way to promote sustainability and minimize negative impacts on the environment. The parcel on Highway 68 does not meet this goal. It is not infill and would require residents to use cars to get to work and for all errands. It is not on a major transit route and it has a very low walk score.

Goal 12
states that the Proposed Plan should be consistent with the Airport Land Use Compatibility Plan (ALUCP) yet development of the 50 acre parcel blatantly violates this stated goal. According to ALUCP, the parcel is in Zone 3, where all residential development is prohibited, except low density and infill in already developed areas.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2051, Packet Page 2379 3/21/24, 9:54 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 3/3 Goal 9
states that the Proposed Plan should “support a vibrant local economy.” This goal is what is used to promote the Proposed Plan over the “Increased Workforce Alternative Plan.” The City of Monterey report states that the Increased Workforce Alternative Plan is environmentally superior to the Proposed Plan as it avoids significant and unavoidable impacts to agricultural resources and air quality. However, the City of Monterey rejects the Increased Workforce Alternative Plan because it does not support local economic vitality to the same extent as the Proposed Plan does. This is in direct contradiction to the stated facts! Goal 9, which discusses economic vitality, states that there should be a balance of jobs and housing so that those who work in Monterey can afford to live in Monterey but the report also states that with the Proposed Plan, low wage hospitality and tourism workers would increase their vehicle miles traveled (VMT).

So isn’t the Increased Workforce Alternative Plan better for low wage workers, better for the environment, and better for everyone else as it reduces traffic congestion and air pollution and maintains the scenic beauty of the Highway 68 Corridor? Finally, why not embrace a hybrid plan? Development of the land on South Boundary Rd, as described in the Proposed Plan, makes sense as it’s within walking distance of jobs at Ryan Ranch. Why not implement part of the Increased Workforce Alternative Plan but also develop housing along Boundary Rd? Boundary Rd. is not part of a recognized scenic corridor and would be much less likely to add to traffic congestion on Highway 68. In keeping with the State of California’s guideline for higher density units that are infill, the City of Monterey could modernize and further develop areas that could
use revitalization without destroying the natural beauty and rural character that attracts tourists to visit and retirees to relocate to the Monterey Peninsula.

Thank you for your time and consideration of my input.

Dr Stuart Jacobs
Sent from my iPhone
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ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2052, Packet Page 2380 3/21/24, 9:59 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/1 Opposition to Housing Development on Hwy. 68
Peter and Kay
Wed 3/20/2024 1:31 PM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Dear Ms. Sabdo:

I am sending my comments to strongly oppose the proposed housing plan for the City of Monterey that includes developing a 50 acre parcel into 650 housing units on Highway 68. Specifically:

Traffic congestion on Hwy 68--There is already significant traffic congestion on Hwy.68 which will only become worse with the airport expansion and condos along Garden Rd and expansion further south by Ryan Ranch. This parcel is landlocked. Where will the egress points be? There is no mention for significant volumes of traffic in this area in the Cal Trans round-about plans. There is no mass transit in the area other than a small bus stop on the other side of the highway.

Negative impact on Scenic Corridor designation for Hwy. 68--This would be in serious jeopardy. This parcel is in an area labeled "highly sensitive viewshed". One thing that was appealing about Monterey when we decided to relocate here was that it wasn't all built out and still had green belt spaces and rural character.

Environmental--Related to above, this area is a huge and significant wildlife corridor and is home to beautiful heritage oaks, wild flowers, deer, fox, coyote, bobcats, skunk, owls, turkeys and a whole array of raptors. Just like areas along our coastlines, this area too must be preserved for nature and our animal friends.

Lack of infrastructure--As mentioned above, this parcel is landlocked with no roads nor supporting infrastructure. While being expensive to develop, this is in conflict with a goal by the City of Monterey to encourage new housing locations supported by existing or planned infrastructure. Surely, there must be other sites in Monterey that don't pose these challenges.

Conflict with proximity goals--This goal is about proximity to transportation, shopping and schools. This parcel is not infill and would require residents to use cars to get to work and for all errands. It is not on a major transit route and it has a very low walk score.

Inconsistency with Airport Land Use Compatibility Plan--Development of this 50 acre parcel seriously violates that plan. It is in Zone 3, where all residential development is prohibited, except low density and infill in already developed areas.

For these reasons (and more), I believe that it is totally inappropriate to develop this land into housing units and hope that you will agree and prevent this from moving forward.

Thank you for your consideration.

Kind regards,
Kay Jamieson
[NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2053, Packet Page 2381 3/18/24, 8:23 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/2 Subject: Significant concern with 1300 unit development on Olmstead Rd Michelle Jones
Fri 3/15/2024 2:04 PM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Dear Christy,
We are nearby residents of the proposed housing project for 640 units off Highway 68 currently owned by the Monterey Peninsula School District. I'm shocked with all the development being proposed all around the airport/68, including the Garden Court development, the 1324 units being proposed by the county, and the Boundary Road project with significant units in the Ryan Ranch area. Does anyone care about the cumulative effects of all these developments on an area that already is struggling with traffic and was designated a scenic corridor? Many of us moved to this area to escape the urbanization and densification in other parts of California. While I support the need for additional residential development that is affordable to ensure hard working people can afford to live and work in Monterey County, several of the proposed sites are of particular concern especially given the high density.

The two I especially object to are the County's 1324 units being proposed off Olmstead Rd and the city of Monterey's 640 units being proposed for land that was previously designated for education. Both of these projects violate the State of California's desire for infill on already developed land and pose significant risk, including:
*Traffic on Olmstead Road and Highway 68, including the proposed roundabout: It can be estimated that Monterey's proposed development could generate up to 1600 extra cars per day and the County's project 3250 extra cars per day. This would be approximately 5000 more cars in an area already dense with traffic and backups, especially during commute windows. The assumption is 2.5 car trips per housing unit per day). The expansion of the airport facilities and new apartments on Garden Rd and proposed housing on South Boundary Rd and the current courthouse off Aguajito Rd. would make traffic even worse. Enormous costs of widening Hwy 68 would be paid for by taxpayers. There is currently no mass transit in the area. What is the plan to mitigate the impact of all this extra traffic? *Environmental impact and vanishing Greenbelt: The removal of this greenbelt is a significant adverse impact aesthetically and a huge contrast from the scenic easement that gives this area such a special character. It is also a loss of habitat for many keystone animal species that can be observed on the subject parcel. Frequent observations occur of Apex/keystone species such as Mountain Lion, Bobcat and Coyote as well as many avian species of special interest. Does the County understand the implications of eliminating this biological corridor? The current residential zoning in this area is one home per 10 acres to allow for new residential development, while still preserving the rural character of this beautiful area. How does such a high density (10-20 units per acre) fit into this environment? I don't understand how a designated scenic corridor can be turned into a high density set of houses and roads. That is not in the spirit of what California state criteria is for affordable housing.
*Pedestrian and Bicycle safety: It is not clear the roads in and out of the 640 unit housing complex since there would need to be at least one additional road for entry in and out. Is this also going to be onto Olmstead Road through the County's development? Olmstead Rd would go from a quiet rural road to a very busy urban one. What is the plan for pedestrian and bike safety with a high volume of cars ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2054, Packet Page 2382 3/18/24, 8:23 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/2 coming in and out onto Olmstead on both sides of the street? Are you planning to access the development directly from Highway 68? This would also pose significant safety risks.
*Flight Crash Risk. 2 years ago, there was a crash into an unoccupied single-family home in the Monterra neighborhood. If such an incident were to occur in a high-density community, there could be a substantial loss of life. Similar incidents have occurred in California (i.e. Truckee with a private jet, as well as Naples FLA recently). Has the city of Monterey and County consulted with Monterey Regional Airport on the flight crash risk specific to the subject property? *Fire Protection. This development would come with extraordinary expense of added fire response personnel and equipment. This is compounded by traffic jams adding to response times. Additionally, one of the important functions of the existing greenbelt zoning gives the entire community an important firebreak. CALFIRE depends on this parcel for fire protection of this whole region. These parcels were an important staging area for firefighters during the last fire just three years ago and we would lose that critical capability if this land were to be developed. Does the city of Monterey and County comprehend the magnitude of additional risk of wildfire this abandonment of firebreak will produce, given the forest densities to the east and west? Is the city of Monterey and County prepared to assume liability for a future wildfire disaster, which could have been prevented by preservation of this critical firebreak? Has the County consulted with CALFIRE on the details of how this firebreak is vital to community safety along the entire Hwy 68 corridor? *Police Protection. This proposed rezoning will place an untenable burden on our existing police resources, which already are in critical shortage. This is not only a public safety threat, but also an extraordinary economic impact by placing 3000 new residents with the county's Olmstead development and ~1500 with Monterey's development in locations, which are not even conveniently serviced for the expected demand level. Has the Monterey County sheriff been consulted and are they prepared to handle this high density loading and increased risk?
*Air Quality. The additional traffic, especially considering the projected congestion and idling, will cause significant deterioration in local air quality, both to onsite residents of the new development and to nearby existing populations. The specific pollutants of public health concern are sulfur dioxide, oxides of nitrogen, carbon monoxide and carbon fibre from tyres. Is the County aware that approximately 20,000 deaths per annum occur in the United States from these air pollutants? How will this be mitigated for current and future residents? *Quality and Availability of Water: If the moratorium on drilling wells is lifted, is there data to support that the onsite wells can provide sufficient healthy ground water for over 3000 new residents for the County development and ~1500 for the Monterey city development without being a detriment to the current ground water supply? It is well established that there are a number of carcinogenic and toxic chemicals in the groundwater emanating from Fort Ord. It is also known that this subsurface water plume is presently moving in the direction of the proposed rezoning parcel, if not already present beneath the subject parcel. This is a serious threat to residents of the subject parcels, particularly to children who will predictably explore the soils of their neighborhood. See for example: Cancer cluster at Fort Ord: Sick vets wonder, are there more of us? (thecalifornian.com) .

Thank you for including my input. I would encourage you to look at using ADUs and other infill strategies using land that has already been developed and is not being fully utilized, such as empty lots next to MPC and Casa Verde, the old courthouse and hospital, as well as parcels around Cannery Row.
[NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2055, Packet Page 2383 3/25/24, 3:43 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauC… 1/2 Subject: Significant concern with 640 unit development off Highway 68 as well as 1300 unit development along Olmstead Rd
Young Kim
/22/2024 11:27 AM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Dear Christy,
I am a resident of Monterey and live in the Monterra area for over a dozen years and I am very concerned about the proposed RHNA plan. I moved here because of the beautiful natural area and to escape the urbanization of other parts of this great area.

We are nearby residents of the proposed housing project for 640 units of Highway 68 currently owned by the Monterey Peninsula School District. I'm shocked with all the development being proposed all around the airport/68, including the Garden Court development, the 1324 units being proposed by the county, and the Boundary Road project with significant units in the Ryan Ranch area. Does anyone care about the cumulative effects of all these developments on an area that already is struggling with traffic and was designated a scenic corridor? Many of us moved to this area to escape the urbanization and densification in other parts of California. While I support the need for additional residential development that is affordable to ensure hard working people can afford to live and work in Monterey County, several of the proposed sites are of particular concern especially given the high density.

What is the plan to mitigate the impact of all this extra traffic? *Environmental impact and vanishing Greenbelt: The removal of this greenbelt is a significant adverse impact aesthetically and a huge contrast from the scenic easement that gives this area such a special character. It is also a loss of habitat for many keystone animal species that can be observed on the subject parcel. Frequent observations occur of Apex/keystone species such as Mountain Lion, Bobcat and Coyote as well as many avian species of special interest. Does the County understand the implications of eliminating this biological corridor? The current residential zoning in this area is one home per 10 acres to allow for new residential development, while still preserving the rural character of this beautiful area. How does such a high density (10-20 units per acre) fit into this environment? I don't understand how a designated scenic corridor can be turned into a high density set of houses and roads. That is not in the spirit of what California state criteria is for affordable housing. *Pedestrian and Bicycle safety: It is not clear the roads in and out of the 640 unit housing complex since there would need to be at least one additional road for entry in and out. Is this also going to be onto Olmstead Road through the County's development? Olmstead Rd would go from a quiet rural road to a very busy urban one. What is the plan for pedestrian and bike safety with a high volume of cars coming in and out onto Olmstead on both sides of the street? Are you planning to access the development directly from Highway 68? This would also pose significant safety risks. *Flight Crash Risk. 2 years ago, there was a crash into an unoccupied single-family home in the Monterra neighborhood. If such an incident were to occur in a high-density community, there could be a substantial loss of life. Similar incidents have occurred in California (i.e. Truckee with a private jet, as well as Naples FLA recently). Has the city of Monterey and County consulted with Monterey Regional Airport on the flight crash risk specific to the subject property? *Fire Protection. This development would come with extraordinary expense of added fire response personnel and equipment.

This is compounded by traffic jams adding to response times. Additionally, one of the important functions of the existing greenbelt zoning gives the entire community an important firebreak. CALFIRE depends on this parcel for fire protection of this whole region. These parcels were an important staging area for firefighters during the last fire just three years ago and we would lose that critical capability if this land were to be developed. Does the city of Monterey and County comprehend the magnitude of additional risk of wildfire this abandonment of firebreak will produce, given the forest densities to the east and west? Is the city of Monterey and County prepared to assume liability for a future wildfire disaster, which could have been prevented by preservation of this critical firebreak? Has the County consulted with CALFIRE on the details of how this firebreak is vital to community safety along the entire Hwy 68 corridor? ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2056, Packet Page 2384 3/25/24, 3:43 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauC… 2/2 *Police Protection. This proposed rezoning will place an untenable burden on our existing police resources, which already are in critical shortage. This is not only a public safety threat, but also an extraordinary economic impact by placing 3000 new residents with the county's Olmstead development and ~1500 with Monterey's development in locations, which are not even conveniently serviced for the expected demand level. Has the Monterey County sheriff been consulted and are they prepared to handle this high density loading and increased risk?
*Air Quality. The additional traffic, especially considering the projected congestion and idling, will cause significant deterioration in local air quality, both to onsite residents of the new development and to nearby existing populations. The specific pollutants of public health concern are sulfur dioxide, oxides of nitrogen, carbon monoxide and carbon fibre from tyres. Is the County aware that approximately 20,000 deaths per annum occur in the United States from these air pollutants? How will this be mitigated for current and future residents?
*Quality and Availability of Water: If the moratorium on drilling wells is lifted, is there data to support that the onsite wells can provide sufficient healthy ground water for over 3000 new residents for the County development and ~1500 for the Monterey city development without being a detriment to the current ground water supply? It is well established that there are a number of carcinogenic and toxic chemicals in the groundwater emanating from Fort Ord. It is also known that this subsurface water plume is presently moving in the direction of the proposed rezoning parcel, if not already present beneath the subject parcel. This is a serious threat to residents of the subject parcels, particularly to children who will predictably explore the soils of their neighborhood. See for example: Cancer cluster at Fort Ord: Sick vets wonder, are there more of us? (thecalifornian.com) .

We are wriSng to voice opposiSon to the Monterey 2031 General Plan, specifically as it relates to the proposed development along Olmsted Road/Highway 68 and surrounding areas. We object to the project for several reasons.

First, the proposed plan at Olmsted Road and surrounding areas would adversely impact the health and welfare of the community. The draL Environmental Impact Report (EIR) concedes that the proposed plan would both degrade air quality through polluSon and “generate substanSal traffic” in the Olmsted Road/Highway68 planning area. Increased traffic flow and congesSon will invariably generate environmental pollutants. In fact, the EIR states the planning areas around Highway 68 are “hotspots” for CO emissions. In addiSon, the extent of impact on air quality in the Olmsted Road/Highway68 area is not known without addiSonal research.

Specifically, the EIR suggests that the Olmsted Road/Highway68 area needs addiSonal study to fully assess air quality impact.

Next, the proposed plan poses an increased risk of wildfire danger. According to the DraL Safety Element as a part of the General Plan, areas along Highway 68 are located in very high/high fire hazard severity zones. At present, proposed plan proposes inadequate miSgaSon efforts to reduce wildfire and other hazardous risks to the community. By removing the exisSng essenSal fire break, the proposed development at Olmsted and surrounding areas substanSally increases the risk of fire danger to the lives, property, and watersheds of the community.

What is more, removal of natural scenery and wildlife via the project is at odds with how the City defines it land own land use prioriSes. The Safety Element emphasizes “the natural beauty of the forested hills and the California coastline in and around Monterey helps define the character of the community,” and the EIR states that the Highway 68 plan “recognizes the value of the area’s scenic character.” As proposed, more measures are needed to protect against the removal of wildlife and scenery from this area to beher align with the character of the community as defined by the City. As long-term California residents, and residents of our coastal community, it is important to protect our natural and wildlife resources for long-term environmental preservaSon.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2058, Packet Page 2386 In addiSon, the proposed plan would adversely impact water supply. As wrihen, the EIR needs addiSonal research to address potenSal decreases groundwater supplies and water quality. The report acknowledges that construcSon arising from the plan could result in water quality impacts, but the plan does not do enough to ensure the community has access to clean, affordable water.

Finally, the proposed plan will adversely impact noise in the area. The EIR states the “predominant source of noise” in the planning area is motor vehicles, and the “second significant source of noise is aircraL flights and operaSons at the Monterey Regional Airport.” Adding increased traffic volume along Olmsted/Highway 68 near the airport exacerbates exisSng noise concerns. As wrihen, the plan needs addiSonal study and miSgaSon techniques to ensure minimal impact on noise in this area to comply with exisSng with Monterey regulaSons.

We hope you will consider our concerns. Thank you for your Sme and consideraSon.

Regards,
Brent J. Lanier, MD
Andrea B. Lanier, MD
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2059, Packet Page 2387 3/20/24, 8:27 AM Mail - Christy Sabdo - Outlook
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Nigel Lovett
Tue 3/19/2024 6:05 PM
To:Christy Sabdo <[email protected]>
Cc:Nigel Lovett
[You don't often get email from Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ] Dear Ms Sabdo,
As a resident of Monterey I wanted to express my concerns about the developments being contemplated on the meadowlands south of Hwy 68 and on both sides of Olmsted Road. My concerns are as follows:-

1. I am most concerned by the prospect of pristine meadowlands being used for housing. These meadowlands and their views of the mountains between Monterey and Salinas are simply too beautiful to be sacrificed for residential or any development. It is the town’s open spaces, parks and seascape that make Monterey such a special place for residents and tourists alike. The loss of these meadowlands would be a tragedy for our community and made more so by the accelerating development just north of Hwy 68 both on Garden Road and also at the airport.

2. I understand that Caltrans is planning to ease the current traffic saturation on Hwy 68 by building multiple roundabouts, including one at Olmsted Road and Hwy 68. However there must remain concerns, despite the roundabout, about the ability of Hwy 68 to handle all the incremental traffic associated with any residential development in the meadowlands alongside Hwy 68 and Olmsted Road, quite apart from the incremental traffic from residential development on Garden Road.

I assume you know that an increasing amount of evening rush hour traffic is avoiding Hwy 1 North by using Aquajito Road and then Olmsted Road to get onto Hwy 68. This simply compounds the actual and potential traffic problems in this specific area.

3. Having heard that water is a scarce commodity in Monterey County, how will any new development be supplied with sufficient water, other than through the drilling of more wells, which potentially drain water from the wells servicing existing houses in the area? I appreciate your consideration of my concerns. I am sympathetic with your housing challenges, but have to believe that there are other areas more suitable for development, such as the two acres of raw land behind the El Estero Lake car wash, which is owned by the Monterey Museum of Art and most unlikely to be developed by the Museum. A smaller development there would not have such an adverse impact on local traffic and would deprive nobody of any scenic setting. Water, of course, would be another matter though.

Sincerely,
Nigel Lovett
Sent from my iPhone
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2060, Packet Page 2388 March 24, 2024
Dear Ms. Sabdo:

I am writing to provide you with my comments regarding the Draft EIR for the Monterey 2031 General Plan Update.

The population of Monterey has actually decreased by 2.2% over the past 3 years and is projected to continue to decrease. The source of these projections, AMBAG, states that employment drives growth, but projected employment growth does not support the numbers used as the basis for the proposed housing development plan. The Proposed Plan assumes that, by 2031, employment in Monterey will grow by 8.3%, but population will grow by 37.6%, and somehow that necessitates a 41.9% growth in housing units.

PROPOSED PLAN CONFLICTS WITH PROJECT OBJECTIVES
The Proposed Plan, which includes development of the 50 acre parcel on Highway 68, conflicts with six of the specific objectives, or goals, for the project as outlined in the report. Goal 1 states that the plan should address the regional housing needs (RHNA) but, as mentioned above, Monterey appears to be planning for many more new units than are necessary to meet projected needs. It leads one to wonder if perhaps the Highway 68 parcel is included because an influential developer would like to build on it at the expense of the Highway 68 Scenic Corridor, the environment, and the general enjoyment and welfare of the community.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2061, Packet Page 2389 Goal 6 states that the City of Monterey should “ encourage new housing in locations supported by existing or planned infrastructure, while maintaining existing neighborhood character.” There is no existing infrastructure on the 50 acre Highway 68 parcel and the neighborhood character is low density residential and rural so the proposed plan does not meet goal 6.

Goal 7, entitled “Maintain Existing Housing” , states that the city wants to “assure high quality maintenance, safety, and habitability of existing housing resources.” If this is so, why not have programs to rehabilitate and remodel existing housing, especially in core areas of the city? If you build an excess of new housing and significantly increase vacancy rates and decrease rental rates, it is well known that landlords will not be willing or able to maintain existing properties. The result will be some nice new buildings along Highway 68 while the appearance of Monterey's central district continues to degrade.

Goal 8 states that appropriate housing sites “are proximate to transportation, shopping and schools…” This goal is in line with the State of California’s goal to promote infill as a way to promote sustainability and minimize negative impacts on the environment. The parcel on Highway 68 does not meet this goal. It is not infill and would require residents to use cars to get to work and for all errands. It is not on a major transit route and it has a very low walk score.

Goal 12 states that the Proposed Plan should be consistent with the Airport Land Use Compatibility Plan (ALUCP) yet development of the 50 acre parcel blatantly violates this stated goal. According to ALUCP, the parcel is in Zone 3, where all residential development is prohibited, except low density and infill in already developed areas.

So isn’t the Increased Workforce Alternative Plan better for low wage workers, better for the environment, and better for everyone else as it reduces traffic congestion and air pollution and maintains the scenic beauty of the Highway 68 Corridor? Finally, why not embrace a hybrid plan? Development of the land on South Boundary Rd, as described in the Proposed Plan, makes sense as it’s within walking distance of jobs at Ryan Ranch. Why not implement part of the Increased Workforce Alternative Plan but also develop housing along Boundary Rd? Boundary Rd. is not part of a ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2062, Packet Page 2390 recognized scenic corridor and would be much less likely to add to traffic congestion on Highway 68. In keeping with the State of California’s guideline for higher density units that are infill, the City of Monterey could modernize and further develop areas that could use revitalization without destroying the natural beauty and rural character that attracts tourists to visit and retirees to relocate to the Monterey Peninsula.

Thank you for your time and consideration of my input.

Yours very truly,
Carlyle MacHarg
Monterey, CA 93940
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2063, Packet Page 2391 March 24, 2024
Attention: Christy Sabdo
Subject: Significant concern with 640-unit development off Highway 68 We are nearby residents of the proposed housing project for 640 units off Highway 68 currently owned by the Monterey Peninsula School District. I'm shocked with all the development being proposed all around the airport/68, including the Garden Court development, the 1324 units being proposed by the county, and the Boundary Road project with significant units in the Ryan Ranch area. Does anyone care about the cumulative effects of all these developments on an area that already is struggling with traffic and was designated a scenic corridor? Many of us moved to this area to escape the urbanization and densification in other parts of California. While I support the need for additional residential development that is affordable to ensure hard working people can afford to live and work in Monterey County, several of the proposed sites are of particular concern especially given the high density.

2.5 car trips per housing unit per day). The expansion of the airport facilities and new apartments on Garden Rd and proposed housing on South Boundary Rd and the current courthouse off Aguajito Rd. would make traffic even worse.

Enormous costs of widening Hwy 68 would be paid for by taxpayers. There is ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2064, Packet Page 2392 currently no mass transit in the area. What is the plan to mitigate the impact of all this extra traffic?
*Environmental impact and vanishing Greenbelt: The removal of this greenbelt is a significant adverse impact aesthetically and a huge contrast from the scenic easement that gives this area such a special character. It is also a loss of habitat for many keystone animal species that can be observed on the subject parcel. Frequent observations occur of Apex/keystone species such as Mountain Lion, Bobcat and Coyote as well as many avian species of special interest. Does the County understand the implications of eliminating this biological corridor? The current residential zoning in this area is one home per 10 acres to allow for new residential development, while still preserving the rural character of this beautiful area. How does such a high density (10-20 units per acre) fit into this environment? I don't understand how a designated scenic corridor can be turned into a high density set of houses and roads. That is not in the spirit of what California state criteria is for affordable housing. *Pedestrian and Bicycle safety: It is not clear the roads in and out of the 640 unit housing complex since there would need to be at least one additional road for entry in and out. Is this also going to be onto Olmstead Road through the County's development? Olmstead Rd would go from a quiet rural road to a very busy urban one. What is the plan for pedestrian and bike safety with a high volume of cars coming in and out onto Olmstead on both sides of the street? Are you planning to access the development directly from Highway 68? This would also pose significant safety risks.
*Flight Crash Risk. 2 years ago, there was a crash into an unoccupied single-family home in the Monterra neighborhood. If such an incident were to occur in a high-density community, there could be a substantial loss of life.

Similar incidents have occurred in California (i.e. Truckee with a private jet, as well as Naples FLA recently). Has the city of Monterey and County consulted with Monterey Regional Airport on the flight crash risk specific to the subject property?
*Fire Protection. This development would come with extraordinary expense of added fire response personnel and equipment. This is compounded by traffic jams adding to response times. Additionally, one of the important functions of the existing greenbelt zoning gives the entire community an important firebreak.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2065, Packet Page 2393 CALFIRE depends on this parcel for fire protection of this whole region. These parcels were an important staging area for firefighters during the last fire just three years ago and we would lose that critical capability if this land were to be developed. Does the city of Monterey and County comprehend the magnitude of additional risk of wildfire this abandonment of firebreak will produce, given the forest densities to the east and west? Is the city of Monterey and County prepared to assume liability for a future wildfire disaster, which could have been prevented by preservation of this critical firebreak? Has the County consulted with CALFIRE on the details of how this firebreak is vital to community safety along the entire Hwy 68 corridor?
*Police Protection. This proposed rezoning will place an untenable burden on our existing police resources, which already are in critical shortage. This is not only a public safety threat, but also an extraordinary economic impact by placing 3000 new residents with the county's Olmstead development and ~1500 with Monterey's development in locations, which are not even conveniently serviced for the expected demand level. Has the Monterey County sheriff been consulted and are they prepared to handle this high density loading and increased risk? *Air Quality. The additional traffic, especially considering the projected congestion and idling, will cause significant deterioration in local air quality, both to onsite residents of the new development and to nearby existing populations.

The specific pollutants of public health concern are sulfur dioxide, oxides of nitrogen, carbon monoxide and carbon fibre from tyres. Is the County aware that approximately 20,000 deaths per annum occur in the United States from these air pollutants? How will this be mitigated for current and future residents? *Quality and Availability of Water: If the moratorium on drilling wells is lifted, is there data to support that the onsite wells can provide sufficient healthy ground water for over 3000 new residents for the County development and ~1500 for the Monterey city development without being a detriment to the current ground water supply? It is well established that there are a number of carcinogenic and toxic chemicals in the groundwater emanating from Fort Ord. It is also known that this subsurface water plume is presently moving in the direction of the proposed rezoning parcel, if not already present beneath the subject parcel. This is a serious threat to residents of the subject parcels, particularly to children who will ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2066, Packet Page 2394 predictably explore the soils of their neighborhood. See for example: Cancer cluster at Fort Ord: Sick vets wonder, are there more of us? (thecalifornian.com) .

In summary, I am strongly opposed to high density development in the areas pointed out for the reasons stated in this letter. We should learn from other municipalities that have unsuccessfully gone this route.

Sincerely,
Kimiko MacHarg
Monterey, CA 93940
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2067, Packet Page 2395 3/13/24, 2:01 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/3 OLMSTED RD AND HWY 68
Oona McLoghlin
Tue 3/12/2024 5:33 PM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Hi Chrsty,
This letter is to express my very strong objections to the proposals the County and City have made regarding the OLMSTED Project, as follows:

TRAFFIC
Per Monterey County projections, traffic will increase at the rate of 3,250 extra cars per day.

Per Monterey City projections:1,600 extra cars per day.

Total: 4,850 extra cars per day.

Probable access will be thru Olmsted Rd, on both sides of the road. This will cause massive congestion.

This will COMPLETELY change this beautiful scenic quiet and calm countryside into the traffic-congested air-polluted urbanized and undesirable area it will become, the type of area we’ve all moved here to avoid. How is this ok?

MASS TRANSIT
There is no mass transit. MILLIONS of dollars will be spent to cover this cost, millions that could be used for other projects for low income home owners.

JOBS
I would like to see the studies showing an increase in new and available jobs in the area to support this undertaking. Considering the current 8.6% unemployment rate in Monterey County and the seeming lack of new businesses moving into the area, this needs to be established.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2068, Packet Page 2396 3/13/24, 2:01 PM Mail - Christy Sabdo - Outlook
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FIREBREAKS
The horrendously high fire insurance that is currently being paid in this area includes this community firebreak that you now intend to remove. When the insurance companies realize this, we will be dropped altogether. Low income homeowners will be covered while the existing homeowners will have none, or little to none.

WATER
Can you please show the studies that have been done indicating there is 1) sufficient water available and 2) that you have stopped the progression of carcinogens and harmful chemicals that are emanating from Fort Org and advancing to this actual location (if not already there), also the subsurface water Plume reports that is especially dangerous for children playing outside.

POLICE PROTECTION
This will be a huge extra burden on the police force in this area, handling an extra 4 to 5000 residents may prove untenable leaving existing homeowners, as well as, the new homeowners without adequate protection..

COSTS
Low income housing is important, a given in every city state and country in the world with few exceptions, and sensible intelligent thinking in its management must be job one, well thought out decisions that benefit everyone. That said, you have known about this for over a year now, and we, having come across it almost by accident (no thanks to your lack of advertising), found out about it just recently. We vehemently reject it, all of it.

We need to now put yours and other experts heads together and decide on better and more usable locations, less costly locations, a better plan.

Thank you.

Oona McLoghlin
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2069, Packet Page 2397 3/13/24, 2:01 PM Mail - Christy Sabdo - Outlook
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ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2070, Packet Page 2398 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2071, Packet Page 2399 Monterey 2031 General Plan Update Draft EIR comments:

Subject: Significant concern with 640 unit development off Highway Christy Sabdo
AICP, Senior Associate Planner
City of Monterey Planning Division
I am a nearby resident of the proposed housing project for 640 units off Highway 68 currently owned by the Monterey Peninsula School District. I'm shocked with all the development being proposed all around the airport/68, including the Garden Court development, the 1324 units being proposed by the county, and the Boundary Road project with significant units in the Ryan Ranch area. Does anyone care about the cumulative effects of all these developments on an area that already is struggling with traffic and was designated a scenic corridor? Many of us moved to this area to escape the urbanization and densification in other parts of California. While I support the need for additional residential development that is affordable to ensure hard working people can afford to live and work in Monterey County, several of the proposed sites are of particular concern especially given the high density.

*Traffic on Olmstead Road and Highway 68, including the proposed roundabout: It can be estimated that Monterey's proposed development could generate up to 1600 extra cars per day and the County's project 3250 extra cars per day. This would be approximately 5000 more cars in an area already dense with traffic and backups, especially during commute windows. The assumption is 2.5 car trips per housing unit per day). The expansion of the airport facilities and new apartments on Garden Rd and proposed housing on South Boundary Rd and the current courthouse off Aguajito Rd. would make traffic even worse. Enormous costs of widening Hwy 68 would be paid for by taxpayers. There is currently no mass transit in the area. What is the plan to mitigate the impact of all this extra traffic? *Environmental impact and vanishing Greenbelt: The removal of this greenbelt is a significant adverse impact aesthetically and a huge contrast from the scenic easement that gives this area such a special character. It is also a loss of habitat for many keystone animal species that can be observed on the subject parcel. Frequent observations occur of Apex/keystone species such as Mountain Lion, Bobcat and Coyote as well as many avian species of special interest. Does the County understand the implications of eliminating this biological corridor? The current residential zoning in this area is one home per 10 acres to allow for new residential development, while still preserving the rural character of this beautiful area. How does such a high density (10- 20 units per acre) fit into this environment? I don't understand how a designated scenic ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2072, Packet Page 2400 corridor can be turned into a high density set of houses and roads. That is not in the spirit of what California state criteria is for affordable housing.

*Pedestrian and Bicycle safety: It is not clear the roads in and out of the 640 unit housing complex since there would need to be at least one additional road for entry in and out. Is this also going to be onto Olmstead Road through the County's development? Olmstead Rd would go from a quiet rural road to a very busy urban one. What is the plan for pedestrian and bike safety with a high volume of cars coming in and out onto Olmstead on both sides of the street? Are you planning to access the development directly from Highway 68? This would also pose significant safety risks.

*Air Quality. The additional traffic, especially considering the projected congestion and idling, will cause significant deterioration in local air quality, both to onsite residents of the new development and to nearby existing populations. The specific pollutants of public health concern are sulfur dioxide, oxides of nitrogen, carbon monoxide and carbon fibre from tyres. Is the County aware that approximately 20,000 deaths per ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2073, Packet Page 2401 annum occur in the United States from these air pollutants? How will this be mitigated for current and future residents?

*Quality and Availability of Water: If the moratorium on drilling wells is lifted, is there data to support that the onsite wells can provide sufficient healthy ground water for over 3000 new residents for the County development and ~1500 for the Monterey city development without being a detriment to the current ground water supply? It is well established that there are a number of carcinogenic and toxic chemicals in the groundwater emanating from Fort Ord. It is also known that this subsurface water plume is presently moving in the direction of the proposed rezoning parcel, if not already present beneath the subject parcel. This is a serious threat to residents of the subject parcels, particularly to children who will predictably explore the soils of their neighborhood. See for example: Cancer cluster at Fort Ord: Sick vets wonder, are there more of us? (thecalifornian.com) .

Respectfully submitted,
Lurline Menzies
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2074, Packet Page 2402

DAVID ALAN NIKSSARIAN
March 21, 2024
Christy Sabdo
City of Monterey
Sent via email:[email protected]
Dear Ms. Sabdo:

I want to express my concerns about the proposed RHNA Plan to convert the old School property (along Monterra) near Highway 68 into 650 housing units.

My biggest concerns are:
• Scenic Corridor/Sensitive Wildlife Area. The proposed area is an environmentally sensitive area in a scenic corridor. It provides a huge buffer zone for wildlife moving from various areas such as between Jack's Peak, Monterra/Tehama, and the many smaller forested areas in Monterey. • Traffic Congestion. Highway 68 is the biggest traffic bottleneck in Monterey County. This will h01Tibly aggravate an already stressed traffic area. • Destroying agricultural land. There are many areas in Monterey that can be used to place houses on. Taking away agricultural land is not the best use of a very prec10us resource.

I believe a better alternative is the area on South Boundary Road, which will allow residents to walk to work. This will protect agricultural land, eliminate the additional traffic stress, and protect a sensitive environmental area.

Respectfully Submitted,
~
Monterey, CA 93 940
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2075, Packet Page 2403

MARY KHASIGIAN NIKSSARIAN
March 21, 2024
Christy Sabdo
City of Monterey
Sent via email:[email protected]
Dear Ms. Sabdo:

I want to express my concerns about the proposed RHNA Plan to convert the old School property (along Monterra) near Highway 68 into 650 housing units.

My biggest concerns are:
• Taking away agricultural land. There are many areas in Monterey that can be used to place houses on. Taking away agricultural land is not the best use of a very precious resource.
• Traffic Congestion. Highway 68 is the biggest traffic bottleneck in Monterey County. This will horribly aggravate an already stressed traffic area.
• Scenic Corridor/Sensitive Wildlife Area. The proposed area is an environmentally sensitive area in a scenic corridor. It provides a huge buffer zone for wildlife moving from various areas such as between Jack's Peak, Monterra/Tehama, and the many smaller forested areas in Monterey.

Respectfully Submitted, ~ 11 1[/~ Ma~ian Nikssarian, Residen ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2076, Packet Page 2404 3/25/24, 2:18 PM Mail - Christy Sabdo - Outlook
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Carol O'Neil <
Mon 3/25/2024 1:56 PM
To:Christy Sabdo <[email protected]>
Regarding the hundreds of units planned for Tarpy Flats:

Highway 68 is already overloaded and roundabouts will not absorb that much more traffic.

Worse traffic there puts more pressure on the secondary roads as people “cut through." Though not in the city, a large population increase that close to Monterey will certainly impact our infrastructure. Police and fire response will suffer with the worsening traffic. Mutual aid responses will also degrade our public safety.

Putting people and housing “where the jobs are” is wishful thinking. There seems to be nothing to keep people from other areas from buying second homes.

With hundreds of units planned for Garden Road and an upgrade/expansion to the airport coming soon, the intersections at Olmsted/68 and Canyon Del Rey/68 will become nightmares.

Someone told me that "most cities look for ways to bring nature into their cities; Monterey is a city that exists in nature." Let’s keep it that way.

Carol O'Neil
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2077, Packet Page 2405 3/25/24, 2:39 PM Mail - Christy Sabdo - Outlook
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COMMENTS ON TARPY HOUSING ELEMENT OF DRAFT PROGRAM-LEVEL DRAFT EIR FOR THE MONTEREY 2031 GENERAL PLAN UPDATE
[email protected]
Mon 3/25/2024 2:25 PM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Dear Ms. Sabdo:

The City of Monterey is converting a number of office buildings on Garden Road to housing units. Coincidentally, the Monterey Airport is expanding at the end of Garden Road along Highway 68.

Anyone who travels Highway 68 between Highway 1 and the Airport during work rush hours is already familiar with the massive traffic on Highway 68 as it approaches and leaves the City during rush hour. It is difficult to conceive how the Highway could handle additional traffic from a large development in the County along 68 between Olmsted Road and Highway 218.

Traffic has already increased along Olmsted Road and Josselyn Canyon Road as drivers attempt to avoid congestion on Highway 1, especially during the afternoon commute.

I also believe building a housing development directly across from the expanding airport is not a good idea. Noise from the airport is already an issue but I think living so closer to the airport might be unhealthy giving the increase noise volume.

There are other locations in the County that would not incur the anticipated traffic problems and noise issues which will arise from this proposed development.

John O’Neil
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2078, Packet Page 2406 3/25/24, 9:12 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/deleteditems/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqA… 1/2 Olmsted development for 3k+ people in our small neighborhood of 42 homes? 7112 Oak Tree Place Help! Andrea B Pace
Sun 3/24/2024 4:29 PM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Oak Tree Views neighborhood off Olmsted Road
Andrea B Pace
Monterey, Ca 93940
Hello Christy,
I live at and have for over 27 years. We recently became aware of plans to put 1350+ apartment units in an undeveloped field below our small neighborhood, and there were no plans to tell us! When we moved here in 1997, this area was declared scenic easment, so never did we imagine that it would be developed in such a drastic way! There are 42 homes in our neighborhood, so approximately 168 residents. We are in the country with owls, coyotes, rabbits, hawks, turkeys and other wildlife. We had planned spend the rest of our lives here. 1) Country field full of wildlife: How can you propose to put a small city of 3,000+ residents, cars and pets be plopped in the middle of a country field with no infrastructure? I have lived here for 27 years and our area is full of wildlife. Olmsted Road is two lanes, and late in the day, handles the flow of traffic from cars taking the back way when Hwy 1 has heavy traffic. The intersection at 68 and Olmsted is backed up from 4-5pm M-F with cars trying to get onto Hwy 68. 2) Pine trees: we lost our fire insurance a few years ago due to being backed up to Jack's Peak which is full of dead and dying pine trees. It looks like kindling! When our neighborhood was being built in 1997, about 75 pine trees were planted along the front of our homes to obscure us from the road below. They are now 27 years old, many have died and are getting tall enough to fall on some of our homes. Planting of pine trees should be banned as they are no longer suited to our warming climate and pose high fire risk! I saw a note about replacing pines to obscure homes. Please do not plant anymore unsafe fuel! 3) Water: where is the water coming from for 1350 apartments? Our water bills are high already and we are on a septic system. 4) Fire: The closest fire station is at the corner of Hwy 68 and Los Laureles Grade. How will these unites get fire insurance? And how will our fire department protect us with 3000 new residents? Please re-think this excessive and unsafe plan!
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2079, Packet Page 2407 3/25/24, 9:12 AM Mail - Christy Sabdo - Outlook
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Andrea B Pace
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2080, Packet Page 2408 To: Christy Sabo
Email: [email protected]
Date: March 11,2024
Subject: City of Monterey RHNA Plan
Dear Christy,
I am a resident of Monterey for over a dozen years and I am very concerned about the proposed RHNA plan. I moved here because of the beau�ful natural area and to escape the urbaniza�on of other parts of this great state.

I see a need for housing but ques�on the 640-unit development off Hwy 68. I am concerned about:

1. The traffic this will impose on our Highway 68, which is already overu�lized presently with community travel, not to men�on how it will impede the service of all responders to our area for fire and police. Please note that this will also increase accidents for those who walk or use a bicycle in this area.

2. Our local airport is expanding, which will already increase traffic for those who are visi�ng for business and leisure. Will the increase in flights be a risk for those who are residing under the flight path? We have had an experience a very sad accident that resulted in fatali�es.

3. Where will all the wild life go? I have first hand witnessed daily travel of coyotes, bob cats, birds and even mountain lions on occasion, not to men�on amphibians and insects. They are present on this parcel.

4. Water is an issue for this whole community. We conserve presently to maintain quality and quan�ty for future usage. Will the water be safe for this community if the Fort Ord toxic chemicals are present?

5. This area is a natural fire-retardant area for homes and wooded area in higher eleva�on. Will this impact our insurance availability as most insurance companies have already le� this state?

6. How will air quality be maintained by future residents and services? There are not any mass transit systems available.

Please consider my concerns above and note that there are other areas that may be developed since most of the infrastructure is present with facili�es available for living and transporta�on. The old County Courthouse, our old part of the County Hospital, Fort Ord Mixed Use Area and even areas around the Carmel Barnyard Redevelopment Area and Cannery Row are areas that are not fully u�lized.

Thank you for your aten�on,
Rebecca Powell
Rebecca Powell
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2081, Packet Page 2409 3/5/24, 9:38 AM Mail - Christy Sabdo - Outlook
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Gail Robbins
Sat 3/2/2024 4:27 PM
To:Christy Sabdo <[email protected]>
[You don't often get email from Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ] Dear Ms Sabdo,
Both the City and County of Monterey have very ambitious plans for adding affordable housing to fulfill the State’s mandate.

I have been living in a moderate income inclusionary housing community since 1997, and am grateful for the well designed, planned and very conscious development of these 42 homes off of Via Malpaso, called Oak Tree Views.

That being said, the City of Monterey plan appears inappropriate in some areas. The congestion, grid-lock on Highway 68 is already significant. Adding apartments on Garden Rd as well as apartments on Tarpy Flats would cause immeasurable commuter delay due to significant increase of cars using 68. To compound this, the County has identified 3 lots that are on the East and West side of Olmsted Rd proposing 1,327 County apartments, and 650 City apartments. With those numbers of apartments , there possibly could be 4,000 additional cars added to the busiest intersection, affect traffic in both directions as well as access to the airport.

These numbers of apartments are unsustainable for the places that have been indicated above. There is no infrastructure in place. Where is public transport for those who do not drive or own a car? Where will the water and sewer come from? There is a cease and desist order in place regarding any new water meters. Our water shortage is a real and continuing problem. Where would that potential massive number of cars ingress and egress, and more importantly, how will the traffic patterns be significantly impacted? What about the extra police and fire protection potentially needed? If the large percentage of apartments are for very low and low income, where will the subsidy money come from?? The state presently does not have the means to do this. While all make look good on paper, in reality it appears totally unsustainable.

According to your EIR plan, the intersection and corridor that runs parallel to the airport has the most significant air pollution from the planes and exhaust from vehicles. Why would you place men, women, and children in such a high health risk area? Were these sites chosen arbitrarily just because the land was vacant?? What about repurposing land along Fremont, where buildings have been leveled or are abandoned? There is mass transit, and stores within walking distance. Has an investigation of land and buildings been exhaustive?
Everyone wants housing to be affordable and available for residents of California. Finding effective AND sustainable land and/or repurposing ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2082, Packet Page 2410 3/5/24, 9:38 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/2 buildings should be the priority and commitment.

Sincerely,
Gail Robbins
Monterey, Ca 93940
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2083, Packet Page 2411 LAW OFFICES OF THOMAS D. ROTH
1900 S. Norfolk Street, Suite 350
By Overniah,t
Christy Sabdo
Senior Associate Planner
San Mateo, CA 94403
( 415) 508-5810
[email protected]
March 6, 2024
City of Monterey Planning Division
570 Pacific Street
Monterey, CA 93940
Re: Comments of Owner of 1099 Del Monte Ave, Monterey on February 9~ 2024 Monterey 2031 General Plan Update
Draft EIR and General Plan Element Updates
Dear Ms. Sabdo:

This firm has been retained by and represents, Julie M. Gorman and Jeanne L.

McWhorter, as Trustees for THE LOGAR TRUST, dated March 9, 2007 (the "Trust").

The Trust owns in fee the parcel located at 1099 Del Monte Ave., Monterey (APN 001-801-003-000) ("1099 Del Monte").

The Trust submits the follow comments on the above-referenced DEIR and General Plan Update Elements.

DEIR. Volnme l
Table of Contents
The Table of Contents fails to list all of the Figures that are present in the DEIR.

Executive Summary
In the Executive Summary, the City states "The Proposed Plan is both a policy docwnent and an implem,entation tool for implementing the City's General Plan." It is unclear what the City means by the term 11implementation tool." For instance, a LCP under the Coastal Act requires an "implementation plan." Is any part of the DEIR or corresponding plan updates intended to function as an implementation plan under the Coastal Act? If so, it fails to meet minimum requirements for such a plan under the Coastal Act. Presently, the City does not have a certified or approved LCP or LUP implementation plan. When the Coastal Commission rejected the City's LCP ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2084, Packet Page 2412 Amendment application in 2016, the Coastal Commission noted that the City had failed, inter alia, to include as part of its application "designated land uses, land use maps" or changes to the zoning code. (Ex. 2, at 1.)
The DEIR also fails to explain how this proposed plan relates to the partial LUPs certified by the Coastal Commission. For instance, on page 1-6, the City lists "other relevant plans." It lists a City of Monterey Local Coastal Land Use Plan (2016). It is not clear what this refers to. There is no 2016 LUP. In July 2016, the Coastal Commission approved only a vea: limited amendment to the 2003 Harbor Plan LUP. SpecificaIIy, the Coastal Commission approved a limited modification of the Harbor LUP to delete the Wharf Master Plan (repealed by the City in February 2016) from the Harbor LUP appendices (affecting Fisherman's Wharf). (Ex. 1.) The Coastal Commission noted at that time that the City had adopted in 2016 the Waterfront Master Plan, and that the City intended to submit that new plan as part of a LUP implementation plan to comply with the Coastal Act. (Ex. 1.) But the Coastal Commission had refused to accept the City's proposed implementation plan ("IP") application without modifications, and the City never re-submitted a revised plan. (Ex. 2.) Under Coastal Commission policy, the City IP application expired on October 6, 2016 without Coastal Commission action. Thus, the City does nm have a Coastal Commission-certified IP. (Id.) The DEIR must explain all of this and also clarify what it means by the 2016 LUP referenced on page 1-6.

In addition, also on page 1-61 the City lists the City of Monterey Waterfront Master Plan (2016). However, the City fails to advise the reader that the 2016 Waterfront Master Plan is not presently effective .. By its own terms, that plan is only effective if the Coastal Commission approves it, but the Coastal Commission has never approved it. (Ex. 3 [Ord. 3539].) Thus, that plan and any zoning under that plan (within the coastal zone) is not legally binding and may not be relied upon in this General Plan Update.

A.related problem is that the DEIR fails to list the 2003 Harbor LUP at all, even though that plan was certified by the Coastal Commission and is presently effective. The City also must clarify how this General Plan Update is intended to relate and interact, if at all, with the existing 2003 Harbor LUP.

These issues are particularly important to the Trust because in recent years certain City staff have scared off potential tenants for the 1099 Del Monte property by insisting that the 2016 Waterfront Master Plan zoning is effective. After discussions last fall, the City Attorney admitted that the Waterfront Master Plan, by the terms of City Council Ordinance No. 3539 (March 1, 2026), is not effective, and thus, zoning that pre-dated that proposed plan is the current zoning. (Ex. 4.)
For the 1099 Del Monte property, the zoning is C-2. That zoning is consistent with the binding 2003 Harbor LUP. It should be noted that the proposed (but not effective) zoning in the 2016 Waterfront Master Plan is inconsistent with the 2003 Harbor LUP, and thus, is at a minimum bad land use policy. (Ex. 5.) Thus, the DEIR needs to be revised to address all of these planning these issues.

Under the CEQA Guidelines, the DEIR must discuss and analyze "any inconsistencies between the proposed project and applicable general plans, specific plans, and regional plans." 14 CCR§ 15125(d). The DEIR has failed to adequately discuss these issues, and leaves out critical information regarding the interaction among the plans.

In addition to being a CEQA issue, from a substantive standpoint, the City is 2 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2085, Packet Page 2413 improperly assuming that the 2016 Waterfront Master Plan and its zoning is effective, when it is not. In addition to the lack of Coastal Commission approval, the 2016 Waterfront Master Plan is ineffective because it purports to convert open space to development uses without voter approval, which is in violation of the City's Charter. (Ex. 6, § 2.75.)
Page2-4
The DEIR states "Adopted in January 2005 and last amended in June 2020, the current General Plan established goals, objectives, policies, and actions to guide development and preservation in the city. Acting as a 'constitution' for the physical development of the city, the General Plan serves as the basis of decisions concerning the development of property."
The DEIR is unclear on how these proposed General Plan amendments relate to the 2003 Harbor LUP, or how the 2005 General Plan relates to the 2003 Harbor LUP, leaving the Trust and the public in the dark on this issue.

Figure2-2
Figure 2-2 purports to depict existing land use. With respect to 1099 Del Monte, the figure is in error. It appears to list the property as "general commercial." That is not correct. The land use, zoning is C-2. (Ex. 4.) C-2 zoning is not "general commercial," but rather "community commercial." (City Zoning Code, § 38-29.) The figure should be corrected.

Page2-26
The DEIR states "Implementation of the Proposed Plan will require additional regulatory actions by the City of Monterey, including amendments to the Zoning Code to ensure consistency across documents. Additionally, the Proposed Plan will require a recommendation from the Planning Commission and adoption by the City Council.

Future, subsequent development under the Proposed Plan may require approval of federal, State, and responsible or trustee agencies that may rely on this programmatic EIR for decisions in their areas of expertise."
This needs to be clearer in two respects. First, it is unclear how the zoning will change based on the DEIR. That lack of transparency makes it difficult, if not impossible, for the public and the Trust to provide meaningful comments. Second, the Coastal Act is clear that if there are proposed zoning changes in the coastal zone or • • · •. • amendments to the LUP, those will not be effective without Coastal Commission consideration and certification. To suggest otherwise runs counter to the Coastal Act.

Further, it is insufficient to say that other agency approval may be necessary. The DEIR needs to be more specific about what approvals are necessary, including whether Coastal Commission approval is necessary.

Pages 3.1-12 and 3.1-13
These pages purport to discuss certain LUPs, but do not discuss the 2003 Harbor LUP. The reader is left in the dark as to whether the City is seeking to amend that plan in any way by the General Plan Updates. Under the CEQA Guidelines, the DEIR must discuss and analyze "any inconsistencies between the proposed project and applicable general plans, specific plans, and regional plans." 14 CCR § 15125(d). The DEIR also fails 3 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2086, Packet Page 2414 to clearly explain how the project amends the LUP, if at all. The DEIR has failed to adequately discuss these issues.

Fi.gure 3.10-1: Existing Land Use
This figure incorrectly shows 1099 Del Monte as "general commercial" rather than "community commercial." It should be corrected.

Fi.gli.re 3.2-2: Current Zoning
The DEIR needs to clarify that the current zoning of 1099 Del Monte is C-2. Figure

3.2-2 shows 1099 Del Monte as "planned community." That is an error. While the 2016 Waterfront Master Plan purported to rezone 1099 Del Monte as planned community, that plan was never approved by the Coastal Commission, and therefore, by its own . terms, it is not effective. Thus, 1099 Del Monte's· current zoning is C-2. (The map also uses terminology concerning commercial uses that is different than the zoning code which is confusing to the public.)

Page 3 ends

The DEIR discusses the 2016 Waterfront Master Plan as if it is presently effective, when the City's Ordinance adopting the plan made its effectiveness contingent on Coastal Commission's approval and certification. (See, e.g., page 3.12-13.) The Coastal Commission has never approved the 2016 Waterfront Master Plan in full, and therefore, it is not effective and is not lawful. Both the DEIR and the General Plan Update err by treating the 2016 Waterfront Master Plan as effective and relying on its provisions. This seriously misleads the public and causes great confusion as to the applicable legal, land use and zoning standards that are lawfully binding.

This error directly affects 1099 Del Monte. The 2016 Parks and Recreation Master Plan states that a proposed project is to "Relocate the Beach House (currently on the beach) to the east side of the park, with a new bathroom and added parking to the east." (Ex. 7, p. 63.) The relevant photo projects the bathrooms to be located on 1099 Del Monte, which is private property with a long-existing office structure. The 2016 Parks and Recreation Master Plan does not mention that the City would need to acquire this private property, and that the property would need to be rezoned from its present C2 zoning.

This error is likely an extension of the DEIR's repeated error of assuming that the 2016 Waterfront Master Plan is effective, which it is not. The 2016 Waterfront Master Plan identifies as a project "Project E.2.d. Construct a new restroom towards the east end of the Monterey Bay Park." (p. 53.) The 2016 Waterfront Master Plan is not effective and thus the stated project cannot be implemented, not to mention that the City does not own the property.

In addition to being a CEQA issue, the City's reliance on the 2016 Waterfront Master Plan as a legally binding plan is legal error, and that error permeates the entire 4 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2087, Packet Page 2415 land Use Element of the General Plan Update.

Review by Airport Land Use Commission
Before adoption, the General Plan JJ.Ddate must be submitted to, and reviewed by the Airport Land Use Commission. (See Monterey Regional Airport Land Use Compatibility Plan, § 4.1.10.) The airport plan mandates ALUC review of ''land use actions" including the "proposed adoption or amendment of general plans, specific plan, community plans, zoning ordinances and building regulations affecting land within an AIA." (Id.; see also Pub. Util. Code, § 21674(a), (b) and (d).) Since the City proposed General Plan Update includes such land, the General Plan Update must be submitted to the ALUC for review.1 The DEIR fails to discuss this or even mention this req.uirement.

In addition to being a CEQA issue, the City's failure to seek and obtain Airport Land Use Commission approval of the General Plan Update sub$lntively violates the airport plan requirements, and renders the entire General Plan Update ineffective.

This violates not only CEQA but, also independently, the airport plan review requirement.

Airport Safety Overlay
The DEIR references a Figure 3.8-3 but there is no such figure in the DEIR.

The Trust understands that the City is seeking to apply the Airport Overlay in exactly the same way that is explained in the Monterey Regional Airport Land Use Compatibility Plan. If this is incorrect, please advise immediately so that the Trust AD Pl'Cl>are additional comments.

For example, 1099 Del Me>nte is located in Safety Zone 4. The DEIR states "The overlay would be applied to the General Plan Land Use map as shown on Figure 2-4 and would permit continuance of existing uses and allow for new development or ·expansion of existing uses only as consistent with the ALUC infill exemption .... " (3.10-19.) But for zone 4, the infill exemption does nm apply unless the property owner seeks to build 1 If a city proposes to amend its general plan or zoning ordinance in an area within an airport land use plan, the city must first submit its proposed action to the airport land use commission for a determination of whether the action is consistent with the airport land use plan. (Pub. Util. Code§ 21676(b).) If the airport land use commission determines that the proposed action is inconsistent with the airport land use plan, the city may overrule the determination by a two-thirds vote of its governing body and make specific findings that the proposed action is consistent with the purposes of the State Aeronautics Act. (§ 21676(b); Citizens for Planning Responsibly v. County of San Luis Obispo (2009) 176 Cal.App.4th 357, 370.)
5 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2088, Packet Page 2416 structures that are prohibited in Table 4B of the airport plan. Similarly, if the owner seeks to expand an existing use, the infill exemption also would run apply unless the expanded use is one of the prohibited uses listed under zone 4 in Table 4B. Thus, the Trust reads the DEIR sentence "The overlay would be .applied to the General Plan Land Use map as shown on Figure 2-4 and would permit continuance of existing uses and allow for new development or expansion of existing uses only as consistent with the .

ALUC infill exemption" to mean that the infill exemption applies only if req,ub:ed by Table 4B for zone 4, and the City is DDt seeking to add new infill restrictions to new development or expanded uses that are not otherwise prohibited in Table 4B. If this is not correct, please advise me irnmedjgtely.

If the City is seeking to change how the airport overlay is applied compared when compared to the Monterey Regional Airport Land Use Compatibility Plan, then that highlights the necessity to submit the General Plan Update airport overlay to the Airport Commission for review.

Draft !aruJ Use mement
Map 3: Existing Land Use
With respect to 1099 Del Monte, Map 3 is incorrect. The map creates an "office" category and a "commercial" category, when 1099 Del Monte's present zoning C-2 allows both commercial and office. The map is therefore misleading and inconsistent with the City's 7.oning Code.

Land Use Classifications
This section is confusing. Under "commercial," it conflates the range of commercial and office uses that are separated by specific zoning designations in the Zoning Code. It also omits professional offices. It is unclear whether the City is proposing to change the Zoning Code, and if so, how.

Sincerely, _.,.,,-,,,,,,,..-
~ om Roth
6 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2089, Packet Page 2417 Ex. 1 CCC staff report for July 15, 2016 hearing re City of Monterey LCP Amendment Ex. 2 April 16, 2016 CCC Letter to City of Monterey re Inadequate LCP Application Ex. 3 City of Monterey Ord. No. 3539
Ex. 4 November 20, 2023 Email Exchange with City Attorney, Christine Davi confirming Del Monte Zoning as C-2
Ex. 5 Excerpt from 2003 Monterey Harbor Land Use Plan, certified by CCC on Oct. 1 o, 2003
Ex. 6 Excerpt from City Charter
Ex. 7 Excerpt from 2017 Monterey Parks and Recreation Master Plan ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2090, Packet Page 2418 Exhibitt
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2091, Packet Page 2419 STATB OP CALIJIODIIA-NATUKAL IUl8()mCl!I AOBHCY

CALIFORNIA COASTAL COMMISSION
cmn'1lAL COAIT DISTRicr omCB
725 l'RONT STRBBT, SUITB 300
SANTA CllUZ, CA 95060
PHONE: (131) 427-4163
PAX: (131) 427-4177
WBB: WWW,COAITAL.CA.OOV !ADOPTED
Prepar~ June 24, 2016 (for July 15, 2016 Hearing)
To: Commissioners and Interested Persons
From: Susan Craig, Central Coast District Manager
Brian O'Neill, Coastal Planner
BDMUND Q, BROWN JL, GarMN(M
Flla
Subject: City of Monterey. LCP Amendment Number LCP-3-MTC-1(;-0013.;l (Wharf Master Plan Modlftcati.001).

Proposed Amendment
The City of Monterey (the City) prop~ to modify its Harbor Land Use Plan (Harbor LUP) to delete the Wharf Master Plan (Plan) . Harbor LUP Appendices A and C, and incorporate the . Plan's. public access, open space, and public view protection policies from Appendix A into the body of the Harbor LUP. The Wharf Master Plan includes policies and standards for development on Fisherman's Wharf: The City recently adopted a new Waterfront Master Plan, which replaces the Wharf Master Plan (which the City repealed in February 2016). The City intends to include the Waterfront Master Plan as part of its Implementation Plan (IP) in the near future. 1 Given that the City does not yet have a Commission-certified IP and thus cannot include the Waterfront Master Plan in the LCP at this time, and because the City has repealed the Wharf Master Plan from its Municipal Code, in the interim, this amendment serves to delete all references and outdated components of the Wharf Master Plan, and insert the Wharf Master Plan's other applicable_ coastal resource protection policies (including its open space, public access, and public view protections) directly into the Harbor LUP as regulatory standards. Thus, this amendment will ensure that necessary coastal resource protection policies for Fisherman's .Wharf remain in place until the time when the City-adopted Waterfront Master Plan is submitted as part of the City's Implementation Plan during the ongoing LCP certification process.

Minor LCP Amendment Determination
Pursuant to Title 14 of Califpmia Code of Regulations (CCR) Section 13555, the Executive Director may determine that a proposed LCP amendment is "minor." 14 CCR Section 13554 defines minor LCP amendments. Among other things, minor LCP amendments include:
14 CCR Section 13554(11). Changes in wording which make the use as designated in the 1 The City of Monterey currently docs not have a Commission-certified Implcm.cntation Plan. The Commission and Ocean Protection Council granted the City $235,000 as part of the Fi.seal Year 2014/2015 LCP Local Assistance Grant Awards program to both update the existing Land Use Plans and adopt an Implcmcntati.on Plan to create a complete Local Coastal Program, thereby transferring coastal development permit-issuing authority from the Commission to. the City. The City is scheduled to submit its Local Coastal Program to the Commission for certification in March 2017. •
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2092, Packet Page 2420 LCP-3-MTC-16-0013-1 (Wharf Master Plan Modifications)
zoning ordinances, zoning district ".'aps or other implementing actions more specific and which do not change_ the kind, location, intensity, or density of use and which are found by the Executive Director of the Commission or the Commission to be consistent.with the land use plan as certified by the Commission.
14 CCR Sectlon 13554(4)(2). For land use plans ... co"ection, reorganization, revisions, or deletion of certified language which when taken together does not change the kind, location, intensity or density of use or modify the resource protection measures for any area or property. • • •
If the Executive Director determines·that an amendment is minor, that determination must be mailed to all parties the Executive Director has reason to know may be interested and must also be reported to the Commission. If one-third of the appointed members of the Commission request that it be processed as a major LCP amendment, then the amendment shall be set for a future public hearing; if less than one-third of the appointed members of the Commission object to the minor LCP ~dment determination, then the amendment is deemed approved, and it becomes a certified part of the LCP immediately (in this case, on July 15, 2016).

The purpo1e of tbu notice ii to advise interested parties of the Executive Director's determination that the proposed LCP amendment ii minor.

The proposed LCP amendment will delete Appendices A and C from the Harbor LUP, which_ contain portions of the Wharf Master Plan that was adopted as part of the City's Municipal Code in 1986. In February 2016, the City repealed the Wharf Master Plan and adopted the Waterfront Master Plan. The proposed amendment deletes certain requirements within the now-repealed ~ Master Plan the City has found either onerous or unnecessary, deletes all references to it within the Harbor LUP, but retains necessary coastal resource protection policies from the Wharf Master Plan, including on public view, public access, and open space protections, by inserting such policies directly into the body of the Harbor LUP. As examples of requirements identified for deletion, the Wharf Master Plan includes provisions that: require ·Architectural Review Board approval for minor modifications of existing buildings; and include a list of permitted items concessionaires can sell on Fisherman's Wharf. The City has found these particular ~equirements to be onerous on applicants, including by requiring ·Board approval for even minor architectural changes. Therefore, the amendment will delete all references to the Architectural Review Board.

By contrast, the amendment incorporates into the Harbor i.UP the Wharf Master Plan's public view, open space, and public access protection policies, which require new development to maintain existing public access and views, and to explore options for increased open space and views when existing structures are redeveloped. Figure 5 of Appendix; which identifies views and open space on the Wharf, will be relabeled Figure 5 .1 and inserted after Figure S of the Harbor LUP .. The amendment will serve· only to delete cross-references and overly detailed nonsubstantive restrictions on existing concessionaires. The substantive policies guiding allowable uses and development patterns on the Wharf are either already included or are being incorporated within the body of tlie Harbor LUP. In essence, this amendment simply ·deletes all references to the now-repealed Wharf Master Plan, but retains the Plan's· important coastal resource protection policies by inserting them directly into the body of the Harbor LUP. The amendment is therefore consistent with the Coastal Act.

It should be noted that Fisherman's Wharf is owned by the City and space on the Wharf is leased 2 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2093, Packet Page 2421 LCP-3-MTC-16-0013-1 (Wharf Master Plan Modifications)
to private concessionaires who operate a series of commercial establishments, including restaurants and gift shops. The Wharf is located entirely within public trust lands granted to the City by the State of California. As such, the Wharf is located within the Commission's retained • coastal development permit jurisdiction where the Coastal Act is the standard of review for all development. Thus, on the Wharf, the Harbor LUP and the IP (including should the Waterfront Master Plan be a com~ent) anticipated for certification only provide guidance, and this amendment will not impact the standard of review that development on the Wharf must meet That being said, the City has spent considerable time and effort developing the Waterfront Master Plan and bas indicated that it will likely include it as part ofthe·IP during the LCP certification process, at which time the Commission will review it for conformance with all applicable LUP policies. Once certified, the Commission looks forward to using the Waterfront Master Plan as a guidance tool to help inform development at this critically important coastal area. Until then, this am~ent will ensure that necessary coastal resource protections for development on Fisherman's Wharf are in place.

In conclusion, the proposed change will allow the City to delete unnecessary references to the Wharf Master Plan in the Harbor LUP, while retajnjng the Wharf Master Plan's coastal resource protection policies as regulatory standards within the Harbor LUP. As such, the proposal does not change the kind, location, intensity, or density of use of land. The amendment is thus consistent with and adequate to carry out the policies of Chapter 3 of the Coastal Act.

California Environmental Quallty Act (CEQA)
· The City has determined that the project is exempt from further review under CEQA, pursuant to Section 15305 of the Public Resources Code, "Minor Alterations in Land Use Limitations," and a Notice of Exemption has been prepared. The Coastal Commission's review and. development process for LCPs and LCP amendments has been certified by the Secretary of Resources as being the functional equivalent of the enviromnental review required by ~EQA. This report has discussed the relevant coastal resource issues with the proposal, and has concluded that the proposed LCP amendment is not expected to result in any significant adverse impact on the environment. Thus, it is unnecessary for the Commission to suggest modifications to the proposed amendment to address adverse enviromnental impacts because the proposed amendment, as submitted, will not result in any significant environmental effects for which feasible mitigation measures would ·be required. Therefore, this LCP amendment is consistent with CEQA, pursuant to Section 21080.5(d)(2)(A) of the Public Resources Code.

Coastal Commission Concurrence .

The Executive Director will report this minor LCP amendment determination, and any comments received on it, to the Coastal Coin.mission at its July 15, 2016 meeting in San Diego. For any questions or needed additional information regarding the proposed amendment or the process under which it is being certified, please contact Brian O'Neill at the Central Coast District Office in San~ Cruz. •
Exhibit:

Exhibit 1: Proposed LUP Modifications
3 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2094, Packet Page 2422

MONTEIREY HARBOR

LAND USE PLAN

CITY OF MONTEREY

LOCAL COASTAL PROGRAM
AdOJ:!tion History
Certified by Coastal Commission
Maya, 2003
City of Monterey Adopts Resolution
Accepting Coastal Commission Changes
June 3, 2003
Coastal Commission Certification Review
October 10, 2003
Prepared with financial assistance from the office of Coastal Zone Management, National ·oceanic and Atmospheric Administration, under the provisions of the Federal Coastal Zone Management Act of 1972; and from the Califomia Coastal Commission under the provisions of the Callfornia Coastal Ad of 1976.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2095, Packet Page 2423

TABLE OF CONTENTS
PREFACE ....................................................................................... , .......................................... 3 INTRODUCTION ....................................................................................................................... 4 NATURAL COASTAL RESOURCES ......................................................................................... 6 Natural M~rine Resources and Habitat Areas , ....................................................................... 6 Coastal Act Provisions ................................................................................................... -............ 6 Water Resources ,. •••••.•• ········································•.················~································· • •••••••••••••• 15 Diking, Dredging, Filling and Shoreline Structures ................................................................ 18 Natural Hazards .................................................................................................................... 22 PUBLIC AND COASTAL RELATED USE AND ACCESS ......................................................... 27 Public Access ........................................................................................................................ 27 Public Recreation .................................................................................................................. 36 Commercial Fishing and Recreational Boating ............................................ ~........................ 44 Public Works, Parking, and Circulation ................................................................................. 50 LAND USE AND DEVELOPMENT ............................................................................................ 57 Coastal Visual Resources ......................................................................................... :........ 57 Locating and Planning New Development ............................................................................. 63 APPlil\JQIX ft~: ¥.'t:lar:f Master Plan Pu~lle AesesalOpen 8paeeJ /t.:eRiteet:ural Cantrel Pelioiaa as .6.Qepted in the Wt:lar:f Mamer Plan for J;laRaMlan'a lA'l=lar:f ey tl=le MentaF&y City Ceuneil .......... 77 APPENDIX B: Land Uses .Permitted by the Redevelopment Plan for the Custom House Redevelopment Project ............................................................. _.................... :......... , .............. 80 APPlil\JCIX C: Wharf Master Plan ParFRitted Use Pelieiee as AElepktEI in \Re tO.'har:f Master Plan for FiaheMlaR'a ).f.«l=lar:f by the Menteray City CoYneil ................................................................ 82 1 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2096, Packet Page 2424 LCP Policies
The poli~ies in this section specifically address protection, enhancement, and provision of public access to and along the Harbor area shoreline. Figure 5 depicts the policies presented below. •
a. • The City shall encourage the Army to allow continued access to City-operated publlc facilities on the Presidio property, e.g. the Army Museum. b. Existing vertical access points, as described in Figure 5, shall be protected, Improved, or replaced with equal or better access as new development is proposed. New vertical access points, as described in Figure 5, shall be Improved with a clearly signed accessway that is a minimum of ten (10) feet in width.· A lesser width to a minimum of five (5) feet may be allowed if justified by site characteristics along· the rocky shoreline .of Lighthouse Curve.

Access to Monterey Beach from Figueroa Street/Del Monte Avenue shall be a minimum width of twenty-five (25) feet to· allow multi-hull ,:,oats access. ~All access policies iA tlqe i;:ialqoFFRaR's ).\'haFf Master PlaR {Seo AppoRaiK A~ shall he aahereEI ta.as follows:
e.

1. The present open space and view areas, shown in Figure 5. shall be maintained.

2. To provide additional public access and view area, Concession 34 should be allowed to replace its structure over the water under the condition that access be placed across the back of the structure. This access should be provided in a way that will not preciudo the linking of this access with the existing public access on adjoining Concessions 35 and 33, as shown in Figure 5. The required public access for Concession 34 shall not be required to be linked to Concessions 35 and 33 without the consent of Concession 35 and 33. The existing public access on Concessions 35 and 33 should be considered separate and should be required to be linked to public access improvements on Concession 35 as a condition of development when improvements are proposed for either Concession 35 or 33.

3. The provision of a panoramic viewpoint accessible to the general publlc should be a condition of any lease area expansion, as provided for in Architectural Control Policy 1.* This panoramic viewpoint should be linked to other viewpoints so as to provide lateral access at the backs of structures, where feasible, and subject to the approval of all adjacent concessionaires.

4. Should any concession cease operation and not desire to renew its lease. the City should study the structure to see If the structure should be removed and the area should become permanent open space.
d. Planned improvements consistent with the Monterey State Historic Parks General Plan (1983) to the Sloat Landing site by the State Department of. Parks a~d Recreation, including access to the shoreline, shall' be supported.
e. No intervening development shall block potential vlsual access or physical access to the beach.
f. Redevelopment of the east Catellus site shall provide increased opportunities for access to Monterey Beach and Wharf No. 2.
g. As part of any_ d·evelopment on the west Cstellus property, lateral access, a minimum width 31 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2097, Packet Page 2425 h. All aFGhitea1:ual eeRvel pelieies iR the 1-isherRlaR'a 'Nharf Maaer PlaR Eaee AppeRdi• A) shall be adhered te.
i. The City of Monterey and the State Department of Parks and Recreation shall continue to preser:ve histo_rlc cypress trees on State Parks historic properties within the City. j. Fences, walls, and landscaping shall not block harbor view corridors, as shown ori Figure .10.

Proposed LCP Implementation Measures
a. Revise the Zoning Ordinance to Implement development standards for protecting coastal visual resources.
62 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2098, Packet Page 2426 Exhibit2
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2099, Packet Page 2427 5T/\TE OF CAl,lfOltNIA-NIITUI\AI. RESOURCES AGRNC\'

CALIFORNIA COASTAL COMMISSION
CliNTRAL COAIT DISTIIIC-r OPP/CR
1:!S FkONT STIU!l!T, SUITI! 300
SANTA CRU:t, CA 'lSOtO '
PJIONI! (ll I) 421-4HJ
PAX llll)427• 171
WEb WWW COI\ITAL.C'A UOY
l!DMUNU O UROWN JR, (/tll'I/NNtJlt
April 6, 2016
Elizabeth Caraker
Principal Planner
City of Monterey
570 Pacific Street
Monterey, CA 93940
Subject: City of Monterey LCP Amendment (LCP-3-MTC-16-0013-1) Dear Ms. Caraker:

We have received the Local Coastal Program (LCP} amendment request that your office submitted on behalf of the City of Monterey. This is the City's first proposed amendment to the certified Land Use Plan (LUP) for 2016. The proposed amendment includes replacement of Appendix A, B, and C of the certified Harbor LUP with the submitted Waterfront Master Plan.

Please note that this amendment request has been given the Commission tracking number of LCP-3-MTC-16-0013-1.

The Coastal Act and the Commission's regulations require that proposed LCP amendment packages include .. materials sufficient for a thorough and complete review" (Coastal Act Section 3051 O(b ), California Code of Regulations (CCR) Title 14 Section 13553) before an amendment submittal can be deemed submitted (also commonly referred to as "filed"). We have reviewed the materials that you submitted, and are in need of a few clarifications/infonnatjon to adequately analyze the proposed amendment for Coastal Act consistency and to schedule it for a Commission meeting. Towards this end, we are unable to file this amendment request until the following is submitted:

1. The submitted resolution inc.ludes a rezoning of the entire Waterfront Master Plan planning area from General Commercial, Open Space, and Planned Community to Planned Community- Waterfront. The City's zoning ordinance is not part of the certified LU,P. Please confirm whether the City's intent is to replace the designated land uses, land use maps, and associated development standards jn the -certified LUP (found generally on pages 91-116 of the Cannery Row LUP and 65-84 of the Harbor LUP) with a new land· use designation and development standards.

2. CCR Section 13551 requires that all LCP amendment submittals include. a resolution (or ordinance) signed and dated by the City Council: 1) indicating that the local government intends to carry out the LCP in a manner fully consistent with the California Coastal Act; 2) indicating when the LCP amendment will take effect. F:urther, Coastal Act Section 305 lO(a) also requires said resolution to include a statement that the LCP will be carried out in full confonnance with the Coastal Act. ]>lease provide a copy of a signed ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2100, Packet Page 2428 Elizabeth Caraker, Monterey Plnnning Department
LCP-3-MTC-16-0013-1
April 6, 2016
Page2
resolution adopted by the City that includes the requirements of ·ccR Section 13551 and· Coastal Act Section 305 I O(a).

We will hold the City's amendment request package for six months from today's date (i.e., until October 6, 2016) pending receipt of these materiali;. After all of the above-listed materials have been received, the package will again be reviewed and will b~ filed if it contains materials sufficient for a thorough and complete review. Please submit all of the requested materials at the same tim~. Please note that there may be additional materials necessary for filing purposes depending upon the nature of the infonnation provided pursuant to the above-listed materials. particularly if the City wishes to replace the designated land uses currently identified in the certified LUP. If all of the above-listed materials are not received within six months, the City of Monterey LCP Amendment LCP-3-MTC-16-0013-1 will be considered withdrawn and will be returned to you. This submittal deadline may be extended for good cause 1f such request is made prior to October 6, 2016.

Regards,
Brian O'Neill
Coastal Planner
Central Coast District Office
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2101, Packet Page 2429 Exbibit3
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2102, Packet Page 2430 ORDINANCE NO. 3638 ~-
-~ ORDINANCE OF THE COUNCIL OF THE CITY OF MONTEREY
DFZONEllEW-"iEIU-RONTIIASTERPLAN Pl.ANNING AREA 1U PUNNED COIIMUNRY •WATEIIFRIOllr
:HE COUNCIL OF me CfTV Of MONTEREY DOES ORDAIN. as fol~ SECTION 1:

WHEREAS, the WaafRJnl Mast8r' Plan im,-ments General Plan and local C08ldal Plan palicias for the planning area. which sbetchea along 1he ahoraline from San Cartos Beach on the wast to Sloat Avenue on the east;
WHEREAS. the City af Monterey intends to cany out the Waterfmr4 Master PLan in a mamerfutly constatent will the Calfomia Coastal Al:k,
wtEREAS, the Walelflont Maat8r Plan incll Ides programs and projed8 that are designed to achNMt community goals and 'Vision for the fuhn d the watarfront CNer the longterm; and includes regulatory uae and development Bfandards and dalign guidelines lmanded to preserve and promote existing and future uses and develop that also fwlher the vision OV9I' the allorMam - .U • the long-lann; •
VVHEREAS, the Planned Community zoning deaignation is U88d when there is a apacific plan, master plan or master use permit adoplad for" 1he planning area (Exhibit A); WHEREAS, on September 22, 2015. the Planning Comminton held a duly noticed public beartng, raviewad lhe ram• and recommended adoption; WHEREAS, adoption of the Waterfront Master Plan and na:oning of the planning area to PC-W qualifies as a project under Califul,ia Environmental Qualiy Ad. (CEQA); , WHEREAS, a Notice of Intent to Adopt a Mitigated Negative Declaration was posted accon11W ID the C8lifomia Envbvnmenlal Quality Ad (CEQA) Section 15072 and a Draft Initial Study and Miligated Negative Dedaration (IS/UNO) - c:irculalfng for public nwiew for the n,quirad 30-day public raview period. from August 20, 2015 to September 21. 2015 (CEQA Section 15073), during which time alt ndalad documents ware made available at the Monterey City Hall Planning Office and on the City's webaite for the waterfro.it plOjec:t (Exhibit A); the ISIMND ida111ifies lhat the prqact could result in poantfally agnificant envlft1nmantal inpacll aaoc:ialad with bialogica1 and culual ~Mitigation......_ have bean required that wll raduce the p01811lial impacts to a taaa-a,an.eigni B181; and a Notice of Oetennination wtll be filed according to CEQA n,qalirementB following Planning Commisaian recommendation and City Council adoption of the Nagattw, Dec:taration; and VVHEREAS, 1he City Councl, at a praper1y noticed public he ilQ on February 18, 2018, canlfutly COIISidered aD m1he illformation Pfl!IBnlBct to ft. including the agenda rapart and information IUbmiltad at the public hearing by intarasled persona. •
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2103, Packet Page 2431 SECTION2:'DleW i lwtlkrt rPlanf1annlngAlaa,wilhthe~a..1245 Wa1h1nglm1 (Urgent Care) APN: 001701003000., is hanq 1w&i fmm~aal eonun.cial (C-2»> Opm Spam (0). Plannm Communly (PC) and U.IZIOMd ID Pim.- Ccmmunllywatarrrant (PC-W) n ahawn on Exhibft:A SECTION 3: Al Olditme88and .... aOldllii!luC88 in caaftic:l ha::eUlh .. heraby ~~~ • 8ECIION4: Tia Orcllwlhall belnfillfan:aand.aliacl8fal• till •IJ lllsCDr t t OoiiNI i ·m approval .
• PASSED AND ADOPTB> BYTIE C0UNCL OFllE CITY CFIIONlBEYthls 1st day~ llan:h. 2018. byl'le fGlalling vala: -
AYES:

NOES:

ABSENT:
1'BSTAIN:

ATTEST:
5 COUNCl1.liEUBER Ba.RIii. DoMllly, Haifa. Smlh.. Rala'son 0 C0UNCll.MEMBERS Nana
O COUNCllMEIIBERS None
0 C0UNCUEUIERS: Nana
APPROVED:

Mayor ofsaicf Cfly
CityCladcltaaof
•• 1 ' •• , • j, ·- ...
.
. ' . .
.
·- ..
,. .
.
.
2 •
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2104, Packet Page 2432 Exhibit4
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2105, Packet Page 2433 Monday. March 4, 2024 at 07:48:39 Pacific Standard Time Subject: Re: 1099 Del Monte
Data:

From:

Monday, November 20, 2023 at 2:50:34 PM Pacific Standard Time Christine Davi
To: Tom Roth, Kimberly Cole, Ursula Glick-Kelley
Hi Mr. Roth:

The City's GIS map has been corrected. Furthermore, I never guaranteed a number of days that it would take to make the correction. I said I was not sure how long it would take as I do not personally make those corrections.

I am not sure what other maps you are referring to. Please let this serve as confirmation that presently the property is zoned C-2. If third parties need verification beyond this email, please send them to me or to Community Development Director Kimberly Cole.

Sincerely,
Christine
From: Tom Roth <rothlawl@comcast,net>
Date: Monday, November 20, 2023 at 2:05 PM
To: Christine Davi <[email protected]>
Subject: Re: 1099 Del Monte
I You doni often get email from rott;aw1 !IOOPlGMIJJIS. LucowbY: Uia ts ln:mor&IJl I am following up with this. The City agreed that the property is zoned C-2 and the maps would be corrected in a matter of days.

However, as of today (approximately 1 week after that conversation), the City has not corrected the erroneous maps.

What gives?
Tom Roth
From: Christine Davi <2IDli@montere¼.Q[g>
Date: Thursday, November 16, 2023 at 3:08 PM
To: Thomas Roth <rothlawl@comcast,net>
Subject: Re: 1099 Del Monte
I will check with IT and get back to you soon.
1 of 3
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2106, Packet Page 2434 Exhibits
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2107, Packet Page 2435

MONTEREY HARBOR

LAND USE PLAN

CITY OF MONTEREY

LOCAL COASTAL PROGRAM
Adoption History
Certified by Coastal Commission
MayB,2003
City of MonlBrey Adopts Resolution
Accepting Coastal Commission Changes
June 3, 2003
Coastal Commission Certification Review
October 10, 2003
Prepared with financial assistance from the office of Coastal Zone Management, National Oceanic and Atmospheric Administration, under the provisions of the Federal Coastal Zone Management Ad of 1972; and from the Callfomla CoastaJ Commission under the provisions of the California Coastal Ad. of 1976.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2108, Packet Page 2436 f. Use development standards and procedures pennitted on Fiahennan's Wharf shall be those pennittad in the Fishennan's Wharf Mas1Br Plan (see Appendix C) adopted by the City in July, 1986, and as consistent with LUP policies. g. Public parking to serve the designated land uses shaU be provided as shown In Figure 14. h. The west catellus property shall be designated Catallus multi-use. Allowable uses include parking, coastal dependent, coastal related, and public serving uses. Specific uses allowed on the west Catsllus property shalt be limited to those uses supporting and serving the marina, Wharf No. 2, and Monterey Beach. The existing railroad passenger depot shall be preserved. The recreation trail shall pass through this area. Parking for the west Catellus site shall be provided on site or in the marina area •
Specific development standards for the west side parcel shall be as follows:
1) Twenty-fiv&.foot height Omit;
2) development shall be set back from Figueroa Street to protect the view corridor to Wharf 2;
3) all required parking shall be provided on site.
i. The east Catallus property ahaR be designated Catallus multi-use. AHowable uses. include open space, raaeation trail, public restmom, equipment rentals and sales. small snack bar/small restaurant, beach entertainment, boat sales and chandlerfes; bait and tacldelsundry shops; boat storage and rental.

New development shall be limited to parking lot improvements, landscaping, dry boat storage with saaenlng, public plazas, and development of a wave runup barrier to protect the plaza and public beach access and prevent flooding of Del Monte Avenue, onry if such devetopmant does not adversely impact sand supply.
j. The City of Monterey shall continue to develop a continual, visual park-like setting between El Estero Park and the Monterey Beach waterfront through acquisition of commercial land and buildings along Del Monte Avenue. Fotlowing any public purchase, allowable uses on the land north of Del Monte Avenue shall consist of public uses, which generaBy include trails; beaches; parks and their support facilities, such as restrooms; parking for beach and boating public; and low-impact recreation improvements. Development of these properties shall not interfere wtth potential restoration of rail service to Monterey. A portion of this land shall be used to widen the north side of Del Monte Avenue.

Any properties fronting on Del Monte Avenue on the bay side between Camino el Estero (at the ea&tem boundary of the east Catellus parcel) and Sloat Avenue, that have not been purchased by the City of Monterey for inclusion into Monterey Bay Park, shall be designated commercial with the principal pennitted use of commercial visitor serving and a conditional use of general commeraal uses, with devek>pment being llmlted to the scale and intensity of existing uses.
1) No new buildings shall be allowed bet\¥aen Camino El Estero and Park Avenue along the north side of Del Monte Avenue, In order to enhance the bay view. Development shall be limited to low-Intensity public recntational and open space uses that preserve 74 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2109, Packet Page 2437 Exhibit6
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2110, Packet Page 2438 Sec. 2.75
Voter Approval Required for Sale of Open Space Zoned Property in Coastal Zone. (November 2000 Election).

All City-owned property located within the Cannery Row, Harbor or Del Monte Beach Local Coastal Plan areas of the Coastal Zone as that area is depicted on the attached map referred to as Exhibit •A-1" and which is zoned ''O" (open space district), shall be retained as such and not sold or transferred without first receiving approval for the decision to rezone, sell or transfer the property from a majority of the voters.

ExhibltA1:
(see last page of Charter, page 18j)
CilY Website; www.monterey.org
Hosted by Code Publishing Company, AGeneral Code company.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2111, Packet Page 2439 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2112, Packet Page 2440 05 guidelines & projects

MONTEREY BAY PARK
Monterey Bay Park is a beautiful park that
has not reached tts full potential. It is underutilized, even on the busiest days of the year. The following projects are intended to
balance maintaining its visual beauty, while
providing new facilities to make the park
more popular.

Beach House
Relocate the Beach House (currently on
the beach) to the east side of the park, with
a new bathroom and added parking to the
east. Relocating here would benefit from
easy parking ~ from the busy wharf,
views and access to the beach.

Illustration of acti'l8 space wtt/1 buffered seating
Active space
Establish a more active area within park for
informal sports and play, such as bocce ball
or informal sports field. Create a bermed
seating area to act as a barrier and buffer to
the street, as illustrated above.
city of monterey parks & recreation master plan
lndoorlOutdoor Wedding and Event Center Example
Bathrooms
In addition to adding bathrooms to the east
side of the park, bathrooms on the west
side near the kayak facility are also needed.

These bathrooms should be able to serve
beach users, boaters, Recreation Trail users
and community activities at the park.
page 63
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2113, Packet Page 2441 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2114, Packet Page 2442 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2115, Packet Page 2443 Dear Ms. Sabdo:

I am writing to provide you with my comments regarding the Draft EIR for the Monterey 2031 General Plan Update.

The population of Monterey has actually decreased by 2.2% over the past 3 years and is projected to continue to decrease. The source of these projections, AMBAG, states that employment drives growth, but projected employment growth does not support the numbers used as the basis for the proposed housing development plan. The Proposed Plan assumes that, by 2031, employment in Monterey will grow by 8.3%, but population will grow by 37.6%, and somehow that necessitates a 41.9% growth in housing units.

PROPOSED PLAN CONFLICTS WITH PROJECT OBJECTIVES

The Proposed Plan, which includes development of the 50 acre parcel on Highway 68, conflicts with six of the specific objectives, or goals, for the project as outlined in the report. Goal 1 states that the plan should address the regional housing needs (RHNA) but, as mentioned above, Monterey appears to be planning for many more new units than are necessary to meet projected needs. It leads one to wonder if perhaps the Highway 68 parcel is included because an influential developer would like to build on it at the expense of the Highway 68 Scenic Corridor, the environment, and the general enjoyment and welfare of the community.

Goal 6 states that the City of Monterey should “ encourage new housing in locations supported by existing or planned infrastructure, while maintaining existing neighborhood ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2116, Packet Page 2444 character.” There is no existing infrastructure on the 50 acre Highway 68 parcel and the neighborhood character is low density residential and rural so the proposed plan does not meet goal 6.

Goal 7, entitled “Maintain Existing Housing” , states that the city wants to “assure high quality maintenance, safety, and habitability of existing housing resources.” If this is so, why not have programs to rehabilitate and remodel existing housing, especially in core areas of the city? If you build an excess of new housing and significantly increase vacancy rates and decrease rental rates, it is well known that landlords will not be willing or able to maintain existing properties. The result will be some nice new buildings along Highway 68 while the appearance of Monterey's central district continues to degrade.

Goal 12 states that the Proposed Plan should be consistent with the Airport Land Use Compatibility Plan (ALUCP) yet development of the 50 acre parcel blatantly violates this stated goal. According to ALUCP, the parcel is in Zone 3, where all residential development is prohibited, except low density and infill in already developed areas.

So isn’t the Increased Workforce Alternative Plan better for low wage workers, better for the environment, and better for everyone else as it reduces traffic congestion and air pollution and maintains the scenic beauty of the Highway 68 Corridor? Finally, why not embrace a hybrid plan? Development of the land on South Boundary Rd, as described in the Proposed Plan, makes sense as it’s within walking distance of jobs at Ryan Ranch. Why not implement part of the Increased Workforce Alternative Plan but also develop housing along Boundary Rd? Boundary Rd. is not part of a recognized scenic corridor and would be much less likely to add to traffic congestion on Highway 68. In keeping with the State of California’s guideline for higher density units ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2117, Packet Page 2445 that are infill, the City of Monterey could modernize and further develop areas that could use revitalization without destroying the natural beauty and rural character that attracts tourists to visit and retirees to relocate to the Monterey Peninsula.

Thank you for your time and consideration of my input.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2118, Packet Page 2446 3/20/24, 8:40 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/3 City's plan converting Olmsted Road property
[email protected]
Wed 3/20/2024 1:40 AM
To:Christy Sabdo <[email protected]>
You don't often get email from . Learn why this is important Dear Ms. Sabdo:

I am writing to provide you with my comments regarding the Draft EIR for the Monterey 2031 General Plan Update.

PROPOSED PLAN CONFLICTS WITH PROJECT OBJECTIVES
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2119, Packet Page 2447 3/20/24, 8:40 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/3 The Proposed Plan, which includes development of the 50 acre parcel on Highway 68, conflicts with six of the specific objectives, or goals, for the project as outlined in the report.

Goal 9
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2120, Packet Page 2448 3/20/24, 8:40 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 3/3 states that the Proposed Plan should “support a vibrant local economy.” This goal is what is used to promote the Proposed Plan over the “Increased Workforce Alternative Plan.” The City of Monterey report states that the Increased Workforce Alternative Plan is environmentally superior to the Proposed Plan as it avoids significant and unavoidable impacts to agricultural resources and air quality. However, the City of Monterey rejects the Increased Workforce Alternative Plan because it does not support local economic vitality to the same extent as the Proposed Plan does. This is in direct contradiction to the stated facts! Goal 9, which discusses economic vitality, states that there should be a balance of jobs and housing so that those who work in Monterey can afford to live in Monterey but the report also states that with the Proposed Plan, low wage hospitality and tourism workers would increase their vehicle miles traveled (VMT).

Thank you for your time and consideration of my input.

Stephanie Stevenson
[NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2121, Packet Page 2449 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2122, Packet Page 2450 Comments on Monterey 2032 General Plan Update
(submitted by Steven Thayer, 03/25/24)

Page 3 ends

statements related to development near the Monterey Regional Airport and Highway 68:
• “The inventory assumes development of 515 new multifamily units along Garden Road.” • “The inventory assumes 640 new housing units” [on the 50-acre site east of Tarpey Flats and south of the airport]
To put the scale of this potential development in perspective, the nearby community of Oak Tree Views has 42 home sites, while Monterra Ranch has 168 home sites. In other words, the city is seemingly proposing to add over five times the number of housing units as currently exist in this area.

The traffic impact alone is concerning. The city itself recognizes in various ways the need to properly assess traffic impacts in the following policies (contained in the Draft Circulation Element):

Policy a.7 Do not support non-aviation uses within the Monterey Peninsula Airport District that create unnecessary traffic impacts in adjacent residential neighborhoods.

Policy a.9 Limit direct access from private property to State highways.

Policy j.9 Protect emergency evacuation routes.

Policy j.10 Maintain capacity on principal arterials to support emergency evacuation.

Emergency evacuation is of particular concern to those of us who live in this vicinity (a high to very high fire hazard region). Highway 68 is the only way out for those of us who may have to evacuate on short notice if a fire were to break out in the heavily-forested hills south of Oak Tree Views and Monterra Ranch. A similar concern is noted by the city with respect to the evacuation-constrained parcels in Deer Flats and Fishermans Flats (see Map 18 in the Draft Safety Element). Encountering a traffic jam on Highway 68 during an emergency evacuation could be catastrophic.

Compounding these already serious concerns are plans for airport expansion (adding to the traffic on Garden Road, Olmsted Road and Highway 68) and the county’s housing element which identifies the open space bounded by Highway 68, Olmsted Road, and Via Malpaso as a site for the potential addition of 1,324 housing units!
Bottom Line: Let’s not build catastrophe into the plans for this neighborhood.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2123, Packet Page 2451 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2124, Packet Page 2452 3/21/24, 9:56 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/3 I have been on the Greater Monterey LUAC for a number of years which advises the Planning Commission regarding all construction along the unincorporated Highway 68 corridor. We had many limitations as to what could be approved.

A project with this proposed density is absurd and will create a number of issues far beyond those above. These proposed projects are not easily accessible to jobs, maybe a few at the airport and on Garden Road but that’s it. Then a car is required. Then the congestion just moves from one place to another. If Monterey County is not concerned about population numbers then consider other properties that put residents within easy walking of most available jobs. The premise is to have the workforce near jobs; there are vacant properties along Fremont Blvd in Monterey and Seaside; along DelMonte near the shopping malls and auto mall; adjacent to Ryan Ranch with many offices. I assume that Monterey County could make “a deal” with any of the adjacent cities to be willing to build under the County plan in a place where residents are walking distance to work or along bus routes. I suggest that you consider that housing for those in hospitality (the suggested main concern) would be better served by being in the cities where the hospitality businesses actually exist. Again, perhaps the County can find ways to work with the cities. I also suggest that you consider small complexes incorporated into areas with far lower density. It seems that the City of Monterey has decided to put two enormous projects as far out of town as is possible, not helping with transportation issues for the workers but complying with the states requirement of numbers. Numbers vs quality, money vs community character and easy vs thoughtful. Also impacting the nature of Highway 68, a designated Scenic Highway! Traffic from the two City of Monterey projects that we are aware of will be increased by at least 1,000 vehicles if not two to three times that. Traffic from the project between Olmstead Road, Highway 68, Via Mal Paso could include at least 3,000 vehicles if not more.

This pasture is filled with wild life, including mountain lions, and is considered a natural pathway and habitat for these creatures.

California Department of Fish and Wildlife has expressed much concern.

Foothill school is no longer operating as a MPUSD school.

There are very few buildings over two stories tall. For the years I have been involved with LUAC the Countydid not approve buildings over two stories along this road, they did not approve buildings that made a visual impact on Highway 68. The City of Monterey seems to have no problem with this. The Car condos serve a purpose but make a terrible visual impact on this scenic highway. At least put in some plants.

While discussing the above you might reconsider traffic circles along Highway 68. These might work well on roads with 25-40 mph speed limits. Highway 68 is 55 and this makes little sense. Much of the day there is a steady stream along Highway 68 and I’m not sure how easily we will be able to merge. It also makes little sense considering that our fire department is approximately 8 miles east of us on Highway 68. Good luck getting those rigs here in the event of fire. Oak Tree Views and other neighboring communities are on the edge of a HIGH fire risk area. There is only one way out for some of us and that is Olmstead Road to Highway 68 or Garden Road. With the number of additional vehicles I would imagine that egress will be impossible.

Have you considered schools? Rain runoff? Impact on Olmsted/Monhollan Road? Medical services? Police? Other services? ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2125, Packet Page 2453 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2126, Packet Page 2454 3/18/24, 8:53 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/3 Comments Re: Draft EIR for the Monterey 2031 General Plan Update Lisa Villafranca
Sun 3/17/2024 4:34 PM
To:Christy Sabdo <[email protected]>
Cc:Lisa Villafranca
March 17, 2024
Dear Ms. Sabdo,
Subject: Significant concern with 640-unit development off Highway 68 I am a nearby resident of the proposed housing project for 640 units off of Highway 68 currently owned by the Monterey Peninsula School District. I'm shocked with the massive amount of development being proposed around the Airport/Hwy 68, including the Garden Court development, the 1324 units being proposed by the County, and the Boundary Road project with significant units in the Ryan Ranch area. Does anyone care about the cumulative effects of all these developments on an area that already is struggling with traffic, and was designated a scenic corridor? Many of us moved to this area to escape the urbanization and densification in other parts of California. While I support the need for additional residential development that is affordable to ensure hard working people can afford to live and work in Monterey County, several of the proposed sites are of particular concern especially given the high density.

The two I especially object to are the County's 1324 units being proposed off Olmsted Rd, and the City of Monterey's 640 units being proposed for land that was previously designated for education, also off of Olmsted Rd. Both of these projects violate the State of California's desire for infill on already developed land and pose significant risk, including:
*Traffic on Olmsted Road and Highway 68, including the proposed roundabout: It can be estimated that the City of Monterey's proposed development would generate up to 1600 extra cars per day, and the County's project - 3250 extra cars per day. This would be approximately 5000 more cars in an area already dense with traffic and backups, especially during commute windows. The assumption is 2.5 car trips per housing unit per day. The expansion of the airport facilities, and new apartments on Garden Rd, and proposed housing on South Boundary Rd, added to the current courthouse off Aguajito Rd., and Jack’s Peak County Park off Olmsted/Monhollan Rd, would make traffic even worse. Enormous costs of widening Hwy 68 would be paid for by taxpayers. There is currently no mass transit in the area. What is the plan to mitigate the impact of all this extra traffic? *Environmental impact and vanishing Greenbelt: The removal of this greenbelt is a significant adverse impact aesthetically, and a huge contrast from the scenic easement that gives this area such a special character. It is also a loss of habitat for many keystone animal species that can be observed on the subject parcel. Frequent observations occur of Apex/Keystone species such as Mountain Lion, Bobcat and Coyote, as well as many avian species of special interest. Do the City and County understand the ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2127, Packet Page 2455 3/18/24, 8:53 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/3 implications of eliminating this biological corridor? The current residential zoning in this area is one home per 10 acres to allow for new residential development, while still preserving the rural character of this beautiful area. How does such a high density (10-20 units per acre) fit into this environment? I don't understand how a designated scenic corridor can be turned into a high density set of houses and roads. That is not in the spirit of what California State criteria is for affordable housing. *Pedestrian and Bicycle safety: What is not clear is where the additional roads needed to support the 640-unit housing complex will be located. There would need to be at least two additional roads for entry and exit in to the development. Will the new road(s) open onto Olmsted Road- as the County's proposed 1324-unit development will? Olmsted Rd has already gone from a quiet rural road to a very busy urban one.

Even now the people that live, drive, walk, run, ride their bicycles, and walk their dogs on Olmsted/Monhollan Road are at risk! Thanks to cellular phone technology, Olmsted/Monhollan Road has become a “short cut” for drivers heading North on Hwy1 to Hwy 68, and for drivers heading West on Hwy 68 to Monterey. I invite you to take a walk, or better yet, ride your bicycle along Olmsted/Monhollan Road during peak traffic commute times, and experience what I am talking about: drivers speeding and tailgating along this winding stretch road, as if it was a race track! During peak traffic times walking or bicycling on Olmsted/Monhollan Road means putting your life at risk-and this is NOT an exaggeration! So, what is the plan for pedestrian and bicycle safety with a much greater volume of cars planned to use Olmsted Road? Or, are you planning to access the development directly from Highway 68? Which would also pose significant safety risks as well. *Flight Crash Risk. Two years ago, an airplane crashed into an unoccupied single-family home in the Monterra neighborhood. If such an incident were to occur in a high-density community such as those proposed, there would be a substantial loss of life.

Similar incidents have occurred in California (i.e. Truckee with a private jet, as well as Naples FLA recently). Has the City of Monterey and County consulted with Monterey Regional Airport on the flight crash risk specific to the subject property? *Fire Protection. The proposed development would come with extraordinary expense of added fire response personnel and equipment. Compounded by traffic jams adding to response times. Additionally, one of the important functions of the existing greenbelt zoning gives the entire community an important firebreak. CALFIRE depends on this parcel for fire protection of this whole region. These parcels were an important staging area for firefighters during the last fire just three years ago, and we would lose that critical capability if this land were to be developed. Does the City of Monterey, and the County of Monterey comprehend the magnitude of additional risk of wildfire this abandonment of firebreak will produce given the forest densities to the east and west? Is the City of Monterey and County of Monterey prepared to assume liability for a future wildfire disaster, which could have been prevented by preservation of this critical firebreak? Has the City and County consulted with CALFIRE on the details of how this firebreak is vital to community safety along the entire Hwy 68 corridor? ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2128, Packet Page 2456 3/18/24, 8:53 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 3/3 *Police Protection. This proposed rezoning will place an untenable burden on our existing police resources, which already are in critical shortage. This is not only a public safety threat, but also an extraordinary economic impact by placing 3000 new residents within the County's Olmsted development and ~1500 with the City Monterey's development in locations, which are not even conveniently serviced for the expected demand level. Has the Monterey County sheriff been consulted and are they prepared to handle this high density loading and increased risk?
*Air Quality. The additional traffic, especially considering the projected congestion and idling, will cause significant deterioration in local air quality, both to onsite residents of the new development, and to nearby existing populations. The specific pollutants of public health concern are sulfur dioxide, oxides of nitrogen, carbon monoxide and carbon fiber from tires. Are the City and County aware that approximately 20,000 deaths per annum occur in the United States from these air pollutants? How will this be mitigated for current and future residents?
*Quality and Availability of Water: If the moratorium on drilling wells is lifted, is there data to support that the onsite wells can provide sufficient healthy ground water for over 3000 new residents for the County development and ~1500 for the City of Monterey development without being a detriment to the current ground water supply? It is well established that there are a number of carcinogenic and toxic chemicals in the groundwater emanating from Fort Ord. It is also known that this subsurface water plume is presently moving in the direction of the proposed rezoning parcel, if not already present beneath the subject parcel. This is a serious threat to residents of the subject parcels, particularly to children who will predictably explore the soils of their neighborhood. See for example: Cancer cluster at Fort Ord: Sick vets wonder, are there more of us? (thecalifornian.com) .

I would encourage you to look at using ADUs and other infill strategies, using land that has already been developed and is not being fully utilized, such as empty lots next to MPC and Casa Verde, the old courthouse and hospital, as well as parcels around Cannery Row.

Thank you for including my input.

Sincerely,
Lisa Villafranca
Monterey, Ca 93940
[NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2129, Packet Page 2457 3/14/24, 4:57 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/3 (No subject)
Patricia Walton
Thu 3/14/2024 10:31 AM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Subject: Significant concern with 640 unit development off Highway 68 We are nearby residents of the proposed housing project for 640 units off Highway 68 currently owned by the Monterey Peninsula School District. I'm shocked with all the development being proposed all around the airport/68, including the Garden Court development, the 1324 units being proposed by the county, and the Boundary Road project with significant units in the Ryan Ranch area. Does anyone care about the cumulative effects of all these developments on an area that already is struggling with traffic and was designated a scenic corridor? Many of us moved to this area to escape the urbanization and densification in other parts of California. While I support the need for additional residential development that is affordable to ensure hard working people can afford to live and work in Monterey County, several of the proposed sites are of particular concern especially given the high density.

Has the city of Monterey and County consulted with Monterey Regional Airport on the flight crash risk specific to the subject property?
*Fire Protection. This development would come with extraordinary expense of added fire response personnel and equipment. This is compounded by traffic jams adding to response times. Additionally, one of the important functions of the existing greenbelt zoning gives the entire community an important firebreak. CALFIRE depends on this parcel for fire protection of this whole region. These parcels were an important staging area for firefighters during the last fire just three years ago and we would lose that critical capability if this land were to be developed.

Does the city of Monterey and County comprehend the magnitude of additional risk of wildfire this abandonment of firebreak will produce, given the forest densities to the east and west? Is the city of Monterey and County prepared to assume liability for a future wildfire disaster, which could have been prevented by preservation of this critical firebreak? Has the County consulted with CALFIRE on the details of how this firebreak is vital to community safety along the entire Hwy 68 corridor?
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2131, Packet Page 2459 3/14/24, 4:57 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 3/3 *Police Protection. This proposed rezoning will place an untenable burden on our existing police resources, which already are in critical shortage. This is not only a public safety threat, but also an extraordinary economic impact by placing 3000 new residents with the county's Olmstead development and ~1500 with Monterey's development in locations, which are not even conveniently serviced for the expected demand level. Has the Monterey County sheriff been consulted and are they prepared to handle this high density loading and increased risk? *Air Quality. The additional traffic, especially considering the projected congestion and idling, will cause significant deterioration in local air quality, both to onsite residents of the new development and to nearby existing populations.

The specific pollutants of public health concern are sulfur dioxide, oxides of nitrogen, carbon monoxide and carbon fibre from tyres. Is the County aware that approximately 20,000 deaths per annum occur in the United States from these air pollutants? How will this be mitigated for current and future residents? *Quality and Availability of Water: If the moratorium on drilling wells is lifted, is there data to support that the onsite wells can provide sufficient healthy ground water for over 3000 new residents for the County development and ~1500 for the Monterey city development without being a detriment to the current ground water supply? It is well established that there are a number of carcinogenic and toxic chemicals in the groundwater emanating from Fort Ord. It is also known that this subsurface water plume is presently moving in the direction of the proposed rezoning parcel, if not already present beneath the subject parcel. This is a serious threat to residents of the subject parcels, particularly to children who will predictably explore the soils of their neighborhood. See for example: Cancer cluster at Fort Ord: Sick vets wonder, are there more of us? (thecalifornian.com) .

I agree with all of Beth’s comments.

Respectfully submitted,
Patricia Walton
[NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2132, Packet Page 2460 3/18/24, 8:51 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/3 Comments Re: Draft EIR for the Monterey 2031 General Plan Update: Olmsted Road and Hwy 68 James Washington <[email protected]>
Sun 3/17/2024 3:04 PM
To:Christy Sabdo <[email protected]>
Cc:James Washington
You don't often get email from Learn why this is important Dear Ms. Sabdo:

I am writing to provide you with my comments regarding the Draft EIR for the Monterey 2031 General Plan Update.

The proposed housing plan for the City of Monterey includes developing a 50-acre parcel on Highway 68. Developing this parcel would have a significant negative impact on the Highway 68 Scenic Corridor and on the environment, in general, especially as it would increase traffic congestion on Highway 68 and the surrounding rural roads. The parcel is in an area that is labeled as a “highly sensitive viewshed.” There has already been extensive development in the Highway 68 Scenic Corridor as evidenced by the airport runway extension, the Highway 68 car condos, and the Montage Ohana building that was inexplicably allowed to loom over the highway. At least, the south side of the highway has maintained a scenic rural character. If that is now developed, the designation of Highway 68 as a scenic corridor would be in jeopardy.

PROPOSED PLAN BASED ON UNREALISTIC PROJECTIONS
The Proposed Plan outlined in the City of Monterey Document is based on what seem to be unrealistic projections of population growth and corresponding housing needs. The population of Monterey has actually decreased by 2.2% over the past 3 years and is projected to continue to decrease. The source of these projections, AMBAG, states that employment drives growth, but projected employment growth does not support the numbers used as the basis for the proposed housing development plan. The Proposed Plan assumes that, by 2031, employment in Monterey will grow by 8.3%, but population will grow by 37.6%, and somehow that necessitates a 41.9% growth in housing units. For each new job, it is proposed that approximately 5 people will move to Monterey. Is population growth outpacing employment growth due to the birth rate and/or due to the number of unemployed (potentially retired) people expected to move to Monterey? If it is the birth rate, it should be noted that children live in the same housing unit as their parents so there should not be a need for 3 times as many housing units as new jobs, as is proposed.

PROPOSED PLAN CONFLICTS WITH PROJECT OBJECTIVES
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2133, Packet Page 2461 3/18/24, 8:51 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/3 The Proposed Plan, which includes development of the 50-acre parcel on Highway 68, conflicts with six of the specific objectives, or goals, for the project as outlined in the report.

Goal 1 states that the plan should address the regional housing needs (RHNA) but, as mentioned above, Monterey appears to be planning for many more new units than are necessary to meet projected needs. It leads one to wonder if perhaps the Highway 68 parcel is included because an influential developer would like to build on it at the expense of the Highway 68 Scenic Corridor, the environment, and the general enjoyment and welfare of the community.

Goal 7, entitled “Maintain Existing Housing”, states that the city wants to “assure high quality maintenance, safety, and habitability of existing housing resources.” If this is so, why not have programs to rehabilitate and remodel existing housing, especially in core areas of the city? If you build an excess of new housing and significantly increase vacancy rates and decrease rental rates, it is well known that landlords will not be willing or able to maintain existing properties. The result will be some nice new buildings along Highway 68 while the appearance of Monterey's central district continues to degrade.

The parcel on Highway 68 does not meet this goal. It is not infill and would require residents to use cars to get to work and for all errands. It is not on a major transit route and it has a very low walk score.

Goal 12 states that the Proposed Plan should be consistent with the Airport Land Use Compatibility Plan (ALUCP) yet development of the 50-acre parcel blatantly violates this stated goal. According to ALUCP, the parcel is in Zone 3, where all residential development is prohibited, except low density and infill in already developed areas.

Goal 9 states that the Proposed Plan should “support a vibrant local economy.” This goal is what is used to promote the Proposed Plan over the “Increased Workforce Alternative Plan.” The City of Monterey report states that the Increased Workforce Alternative Plan is environmentally superior to the Proposed Plan as it avoids significant and unavoidable impacts to agricultural resources and air quality. However, the City of Monterey rejects the Increased Workforce Alternative Plan because it does not support local economic vitality to the same extent as the Proposed Plan does. This is in direct contradiction to the stated facts! Goal 9, which discusses economic vitality, states that there should be a balance of jobs and housing so that those who work in Monterey can afford to live in Monterey but the report also states that with the Proposed Plan, low wage hospitality and tourism workers would increase their vehicle miles traveled (VMT). So isn’t the Increased Workforce Alternative Plan better for low wage workers, better for the environment, and better for everyone else as it reduces traffic congestion and air pollution and maintains the scenic beauty of the Highway 68 Corridor?
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2134, Packet Page 2462 3/18/24, 8:51 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 3/3 Finally, why not embrace a hybrid plan? Development of the land on South Boundary Rd, as described in the Proposed Plan, makes sense as it’s within walking distance of jobs at Ryan Ranch. Why not implement part of the Increased Workforce Alternative Plan but also develop housing along South Boundary Rd? South Boundary Rd. is not part of a recognized scenic corridor and would be much less likely to add to traffic congestion on Highway 68. In keeping with the State of California’s guideline for higher density units that are infill, the City of Monterey could modernize and further develop areas that could use revitalization without destroying the natural beauty and rural character that attracts tourists to visit and retirees to relocate to the Monterey Peninsula.

Thank you for your time and consideration of my input.

Sincerely,
James Washington
Monterey, Ca 93940
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ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2135, Packet Page 2463 3/5/24, 9:36 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5coAAA… 1/1 Very Large Affordable Housing Proposal East of Olmsted
Guy Agrati < >
Fri 3/1/2024 3:32 PM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important I have been told that you are the point person on the receiving end of comments for the subject proposal. If not, please point me in the proper direction.

My concerns are legion:

1.Traffic Impact: There is already significant traffic on 68, which reaches critical numbers during commuting times. The addition of another 3000 cars, trucks, and safety vehicles to this current level from the proposal is very, very bad planning.

2. Water: Our area is already water stressed. Adding 1300+ units is madness.

3. Safety: Our area is now served by the Sheriff's Deprt, and CAL Fire at Laurels Grade. I have seen no plans to increase equipment or staffing.

4. Environmental Impact: The proposal would eliminate a beautiful pasture which is home to turkeys, coyotes, deer, mountain lions, and other wildlife, as well as a number of domestic animals. It also provides a natural buffer to noise from the highway and the airport.

5. Airport Expansion: Already underway, this will add exponentially to the issues outlined above, traffic, water, safety, etc.

In my opinion, this proposal would be a disaster, not only for my neighborhood, Oak Tree Views, but also for Fisherman Flats, Montera, Garden Road, and the 218 corridor. Surely, there are wiser, better planned proposals to meet the affordable housing crisis.

Thank you for your attention to these concerns.

Guy J. Agrati
Monterey, CA 93940
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ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2136, Packet Page 2464 3/19/24, 4:47 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/2 Objection to the Proposed Housing Plan for 50 Acres on Hwy 68 & Monterra Rd Gary Weitz
Tue 3/19/2024 2:30 PM
To:Christy Sabdo <[email protected]>
You don't often get email from . Learn why this is important Dear Ms. Sabdo,
I am writing to object to one of locations for the proposed housing plan for the Monterey 2031 General Plan Update. The proposed housing plan for the City of Monterey includes developing a 50 acre parcel on Highway 68 and Monterra Rd. Developing this parcel would have a significant negative impact on the Highway 68 Scenic Corridor and on our beautiful environment.

This proposed development plan would substantially increase traffic congestion on the already overcrowded Highway 68. This would be a horrific impact on sheriff and fire response time and cause major gridlocks that would impact all Monterey residents. This designated area is supposed to be a scenic corridor that would almost completely disappear should this new development be allowed in this location. This plan would devastate our wildlife, and the scenic land could never be recovered! The Proposed Plan, which includes development of the 50 acre parcel on Highway 68, conflicts with many of the specific objectives and goals for the project as outlined in this report. I list 4 goals below for this location (Hwy 68 & Monterra Rd.) that are completely misaligned to the plan's goals.

Goal 1 states that the plan should address the regional housing needs (RHNA) however, Monterey appears to be planning for many more new units than are necessary to meet projected needs. Population has been decreasing within the City of Monterey for the past 3 years, yet your plan has proposed a need for a 41% increase for new housing.

Goal 8 states that appropriate housing sites “are proximate to transportation, shopping and schools…” This goal is in line with the State of California’s goal to promote infill as a way to promote sustainability and minimize negative impacts on the environment. The parcel on Highway 68 does not meet this goal. It is not infill and would require residents to use cars to get to work and for all errands. There is not a mass transit route for this location, and none planned to my knowledge. Additional, this location has a very low walk ability score, and would be quite dangerous for any pedestrian.

Goal 12 states the Proposed Plan should be consistent with the Airport Land Use Compatibility Plan (ALUCP). Development of the proposed 50 acre parcel blatantly violates this goal. According to ALUCP, the parcel is in Zone 3, where all residential development is prohibited, except low density and infill in already developed areas.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2137, Packet Page 2465 3/19/24, 4:47 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/2 There is available land on South Boundary Rd. that makes more sense for development for this plan. Development of the land on South Boundary Rd., is within walking distance to jobs at Ryan Ranch. Boundary Rd. is not part of a recognized scenic corridor and would be much less likely to add to traffic congestion on Highway 68.

Thank you for your time and I hope you will consideration my input.

Best regards.

Gary Weitz
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ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2138, Packet Page 2466 3/19/24, 4:34 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/2 Objection to Housing Development for the 50 Acrea parcel on Hwy 68 & Monterra Rd.

Susan Weitz
Tue 3/19/2024 2:20 PM
To:Christy Sabdo <[email protected]>
You don't often get email from . Learn why this is important Dear Ms. Sabdo,
I am writing to object to one of locations for the proposed housing plan for the Monterey 2031 General Plan Update. The proposed housing plan for the City of Monterey includes developing a 50 acre parcel on Highway 68 and Monterra Rd. Developing this parcel would have a significant negative impact on the Highway 68 Scenic Corridor and on our beautiful environment.

First, this proposed development plan at the location of Hwy 68 & Monterra Rd. would substantially increase traffic congestion on the already overcrowded Highway 68. This would be a horrific impact on sheriff and fire response time and cause major gridlocks that would impact all Monterey residents. This designated area is a scenic corridor that would almost completely disappear should this new development be allowed in this location. This plan would devastate our wildlife, and the scenic land and loss of wildlife could never be recovered! The Proposed Plan, which includes development of the 50 acre parcel on Highway 68, conflicts with many of the specific objectives and goals for the project as outlined in this report. I list 4 goals below for this location (Hwy 68 & Monterra Rd.) that are completely misaligned to the plan's goals.

Goal 1 states that the plan should address the regional housing needs (RHNA) however, Monterey appears to be planning for many more new units than are necessary to meet projected needs. The population for the City of Monterey has decreased by 2.2% over the past 3 years and is projected to continue to decrease. The source of these projections, AMBAG, states that employment drives growth, but projected employment growth does not support the numbers used as the basis for the proposed housing development plan. The Proposed Plan assumes that, by 2031, employment in Monterey will grow by 8.3%, but population will grow by 37.6%, Your plan supports a 41.9% in new housing units which appear to be unsubstantiated.

Goal 6 states that the City of Monterey should “encourage new housing in locations supported by existing or planned infrastructure, while maintaining existing neighborhood character.” There is no existing infrastructure on the 50 acre Highway 68 parcel and the neighborhood character is low density residential and rural so the proposed plan does not in any way meet goal 6. Development at this location would be quite expensive to Monterey residents and there are other locations throughout the city that already have water and sewer in place.

Goal 8 states that appropriate housing sites “are proximate to transportation, shopping and schools”. This goal is in line with the State of California’s goal to promote infill as a way to promote sustainability and minimize negative impacts on the environment. The parcel on Highway 68 & Monterra Rd. does not meet this goal. It is not infill and would require residents to use cars to get to work and for all errands.

There is not a mass transit route for this location, and none planned to my knowledge. Additionally, this location has a very low walk ability score, and would be dangerous for all pedestrians.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2139, Packet Page 2467 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2140, Packet Page 2468 3/1/24, 11 :22 AM Mail - Christy Sabdo - Outlook
Proposed New Low Cost Housing for Olmsted Rd and Hwy 68 Susan Weitz
Thu 2/29/2024 1:31 PM
To:Christy Sabdo <[email protected]>
You don't often get email fro~ Learn wh\f this is im12ortant To: Monterey Panning Dept:

I suppo1i affordable housing in Monterey County, but the location proposed for 1300 new housing units off Olmsted Rd & Hwy 68 is not an acceptable location for the following reasons:
1) Environmental concerns and the negative impact on om wildlife and endangered species. 2) Traffic - dense housing of this scale will create a massive gridlock at the intersection of Olmsted Rd. and Highway 68. Highway 68 is aheady crowded and is the main arte1y from Monterey and Salinas .... we need to keep traffic moving, and not gridlocked due to an unmanageable number of vehicles on the roadways. This could create a longer response time for emergency vehicles. The Monterey Sheriffs ' depaiiment objects to this location.
3) The proposed site has a natural fire break. Once this fire break is gone, this can severely impact potential fires and the ability to control fires. The Monterey Fire Dept. objects to this location. 4) The Monterey Ai1po1i objects to this plan because of noise complaints which will come.

This proposed location has not been well thought out and there are other locations within the county that would be much better options.

Additionally, the increased cost to taxpayers for the cost of the infrastructure required to suppo1i this development would be huge! Regards.

Susan Weitz
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2141, Packet Page 2469 3/25/24, 4:29 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauC… 1/2 Objections to Proposed housing development off Highway 68 sandra wheatley
Mon 3/25/2024 4:07 PM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Dear Ms. Sabado
As a current resident I am writing to express my concerns with the the proposed housing project for 640 units off Highway 68 currently owned by the Monterey Peninsula School District.

This is just one of several proposals under review for development near the airport including along Garden Court, a county proposal for 1324 units along Olmsted Road and 640 units in Tarpy Flats. In particular, I’m objecting to the two projects that I especially object to are the County's 1324 units being proposed off Olmstead Rd and the city of Monterey's 640 units These proposed developments violate the Governor’s “30x30” initiative (https://www.californianature.ca.gov) and the Scenic Highway designation of Highway 68. My objections are based upon the following:

While in principle I support the development of affordable housing, the number of units being proposed are excessive and will create adverse environmental and traffic impact to the surrounding communities. *Traffic on Olmstead Road and Highway 68, including the proposed roundabout: The approximately 2000 additional housing units will likely produce 5000 additional car-trips through the already congested Olmstead-Highway 68 intersection. The expansion of the airport facilities and proposed housing on South Boundary Rd and the current courthouse off Aguajito Rd. would make traffic even worse. Enormous costs of widening Hwy 68 would be paid for by taxpayers. There is currently no mass transit in the area.
*Environmental impact and vanishing Greenbelt: The removal of this greenbelt is a significant adverse impact aesthetically and a huge contrast from the scenic easement that gives this area such a special character. It is also a loss of habitat for many keystone animal species that can be observed on the subject parcel. Frequent observations occur of Apex/keystone species such as Mountain Lion, Bobcat and Coyote as well as many avian species of special interest. The current residential zoning in this area is one home per 10 acres to allow for new residential development, while still preserving the rural character of this beautiful area.
*Flight Crash Risk. 2 years ago, there was a crash into an unoccupied single-family home in the Monterra neighborhood. If such an incident were to occur in a high-density community, there could be a substantial loss of life. Similar incidents have occurred in California (i.e. Truckee with a private jet, as well as Naples FLA recently). Has the city of Monterey and County consulted with Monterey Regional Airport on the flight crash risk specific to the subject property? *Fire Protection. This development would come with extraordinary expense of added fire response personnel and equipment. This is compounded by traffic jams adding to response times. Additionally, one of the important functions of the existing greenbelt zoning gives the entire community an important firebreak. CALFIRE depends on this parcel for fire protection of this whole region. These parcels were an important staging area for firefighters during the last fire just three years ago and we would lose that critical capability if this land were to be developed. Does the city of Monterey and County comprehend the magnitude of additional risk of wildfire this abandonment of firebreak will produce, given the forest densities to the east and west? Is the city of Monterey and County prepared to assume liability for a future wildfire disaster, which could have been prevented by preservation of this critical firebreak? Has the County consulted with CALFIRE on the details of how this firebreak is vital to community safety along the entire Hwy 68 corridor?
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2142, Packet Page 2470 3/25/24, 4:29 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauC… 2/2 *Air Quality. The additional traffic, especially considering the projected congestion and idling, will cause significant deterioration in local air quality, both to onsite residents of the new development and to nearby existing populations. The specific pollutants of public health concern are sulfur dioxide, oxides of nitrogen, carbon monoxide and carbon fiber from tires. Is the County aware that approximately 20,000 deaths per annum occur in the United States from these air pollutants? How will this be mitigated for current and future residents?
*Quality and Availability of Water: If the moratorium on drilling wells is lifted, is there data to support that the onsite wells can provide sufficient healthy ground water for over 3000 new residents for the County development and ~1000 for the Monterey city development without being a detriment to the current ground water supply? It is well established that there are a number of carcinogenic and toxic chemicals in the groundwater emanating from Fort Ord. It is also known that this subsurface water plume is presently moving in the direction of the proposed rezoning parcel, if not already present beneath the subject parcel. This is a serious threat to residents of the subject parcels, particularly to children who will predictably explore the soils of their neighborhood. See for example: Cancer cluster at Fort Ord: Sick vets wonder, are there more of us? (thecalifornian.com) .

I strongly encourage you to reconsider the current proposals in light of the above.

Kind regards,
Sandra Wheatley and Gary Smerdon
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2143, Packet Page 2471 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2144, Packet Page 2472 3/6/24, 1:25 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5coAAA… 2/3 The City is planning for 640 units on 50-acres south of Highway 68 as part of a Monterey Peninsula Unified School District Educational Workforce Housing overlay. The City's Draft Housing Element is here: https://haveyoursaymonterey.org/monterey2031/news_feed/45-daypublic-review-period-begins-for-the-draft-program-level-draft-environmental-impact-report-for-the-monterey-2031-general-plan-update-2 Best,
Christy
Christy Sabdo, AICP
Senior Associate Planner | City of Monterey
570 Pacific Street | Monterey, CA 93940
831-646-3885 (main) | 831-646-3758 (direct) |
[email protected] | have your say | city website
From: [email protected] <[email protected]>
Sent: Tuesday, March 5, 2024 11:59 AM
To: Christy Sabdo <[email protected]>
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2145, Packet Page 2473 3/6/24, 1:25 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5coAAA… 3/3 Cc: [email protected] <[email protected]> Subject: Monterey 2031 General Plan Update Draft EIR Comments You don't often get email from [email protected]. Learn why this is important Ms. Sabdo,
I would like to submit the attached comments regarding the General Plan update.

Respectfully,
Markus Woehler
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[NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2146, Packet Page 2474 3/25/24, 9:53 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/2 Re: Opposition to Olmsted development
Laura Zerbe
Fri 3/22/2024 8:27 PM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Dear Christy, I’d like to retract the email I sent earlier today and replace it with the message below. The details I had included were specific to a county planning project, and I learned that City of Monterey may have a separate planning project for the same area. Taking that into consideration, I am submitting my revised comments below:

Thank you,
Laura
Dear Christy,
Thank you for all you do for the residents of Monterey County. I’m reaching out to voice my concerns about the proposed housing development along Hwy 68 around Olmsted Road.

Adding housing to this location adds cars to the already-strained daily commute traffic on Highway 68. It puts more households in a HIGH wildfire risk area in an era when traditional fire insurance for new structures is no longer readily available to protect residents. It removes open land which currently serves us all by recharging and protecting groundwater supply. It doubles-down on this insult by adding to the consumption of our already challenged fresh water availability.

Traffic congestion, fire risk and freshwater supply are all existing challenges that as a community we have struggled to alleviate as it is. A project at this location can only make these problems worse. What then? We’re already in a hole- we need to put down the proverbial shovel and stop digging.

In the 2023 city of Monterey Community Survey Report, several potential new housing locations outranked the Hwy 68/olmsted area. One was Fort Ord, which has fewer environmental hazards and keeps traffic congestion away from Hwy 68. It also included Fremont, which has already been developed into a walk/bike friendly neighborhood. These areas seem more advantageous. Why not focus planning efforts on those areas instead?
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2147, Packet Page 2475 3/25/24, 9:53 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/2 Respectfully,
Laura Zerbe, City of Monterey Resident
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ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2148, Packet Page 2476 3/26/24, 8:16 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauC… 1/1 Hwy68/Olmsted development
Lindley Zerbe
Mon 3/25/2024 7:41 PM
To:Christy Sabdo <[email protected]>
You don't often get email from . Learn why this is important Dear Christy,
Thank you for all you do for the residents of Monterey County. I’m reaching out to voice my concerns about the proposed housing development along Hwy 68 around Olmsted Road.

Adding housing to this location adds cars to the already-strained daily commute traffic on Highway 68. It puts more households in a HIGH wildfire risk area in an era when traditional fire insurance for new structures is no longer readily available to protect residents. It also removes open land which currently serves us all by recharging and protecting groundwater supply.

In the 2023 city of Monterey Community Survey Report, several potential housing development locations outranked the Hwy 68/olmsted area. One was Fort Ord, which has fewer environmental hazards and keeps traffic congestion away from Hwy

68. It also included Fremont, which has already been developed into a walk/bike friendly neighborhood. These areas seem more advantageous. Why not focus planning efforts on those areas instead?
Respectfully,
Lindley Zerbe, City of Monterey Resident
Sent from my iPhone
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2149, Packet Page 2477 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
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ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2150, Packet Page 2478 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
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2.2 Master Responses
Numerous comments raised common concerns or questions that are most appropriately answered or clarified in one comprehensive or “master” response. For this Final EIR, the issues listed in Table 2-1 are addressed in Master Responses, lettered MR-1 and MR-2. The intent of the Master Responses is to give a single, comprehensive response to the recurring comments to improve readability of the document by avoiding repetition and multiple cross-references. Many of the individual responses refer back to these Master Responses.

Table 2-1 Master Response List
Master Response Title
MR-1 Cumulative Impacts of Development in South and Southeast Monterey MR-2 Lack of, or Inadequacy of, or Disagreement with Water Supply Analysis Master Response 1: Master Response on Cumulative Impacts of Development in South and Southeast Monterey
In its Draft 2023-31 Housing Element, the County of Monterey has identified four sites with a total projected capacity for 1,324 new homes adjacent to the City of Monterey in the unincorporated Monterra Ranch area. However, the County has not yet finalized its sites inventory and the location of the parcels that the County could ultimately designate to accommodate its RHNA obligations could change before the County’s Housing Element is adopted and it still must be approved by HCD. Therefore, the City has relied on the best publicly available information for its consideration of potential cumulative effects, but that analysis is inherently somewhat uncertain. Numerous comment letters received during the public review period for the DEIR expressed concerns for the cumulative environmental impacts of this housing in combination with development in the southeast of the City of Monterey. Most commenters specifically referenced the 50-acre Monterey Peninsula Unified School District (MPUSD) site within the Highway 68 Plan area identified as a housing opportunity site as part of the Proposed Plan; however, some commenters also referenced development at Fort Ord and in the Garden Road opportunity area in their comment letters.

Commenters cited concerns for cumulative impacts related to police and fire protection services, visual resources, air quality, airport hazards, pedestrian and bicycle safety, traffic congestion, and water supply.

This master response has been prepared to clarify where cumulative impacts are addressed in the DEIR and to confirm the adequacy of the related analysis.

Chapter 5 of the DEIR provides a cumulative analysis of the environmental impacts that could result from the Proposed Plan in combination with other reasonably foreseeable development in the surrounding area.

Consistent with CEQA Section 15064, for each resource category identified in the statute, the DEIR considers whether the cumulative impact is significant and whether the effects of the Proposed Plan are cumulatively considerable. In preparing the DEIR, the City coordinated with all Monterey Peninsula cities and the County to gather details of housing development projected in their respective 2023-31 Housing Elements and to incorporate that data into modeling to ensure a cumulative analysis that accounts for regional RHNA buildout in 2031. Accordingly, the technical analysis upon which the cumulative analysis of vehicle miles traveled, air quality, greenhouse gas emissions, and noise impacts are based on accounts for all projected RHNA development in all of Monterey County. Therefore, the cumulative analysis in the DEIR is adequate under CEQA. The City notes that subsequent to release of the DEIR, based on feedback from the California Department of Housing and Community Development (HCD) as a result of their review of the City's proposed 2023-31 Housing Element, the sites inventory was refined to reduce the number of units ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2151, Packet Page 2479 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
2-230
projected for the 50-acre MPUSD site and for the Fort Ord/Ryan Ranch area and increase the number of units projected on opportunity sites further to the northwest. As a result, while the total number of units projected citywide remains substantially similar, there are now 2,501 housing units representing a reduction of 314 fewer new housing units projected on sites in the Garden Road, Fort Ord/Ryan Ranch, and Highway 68 Plan areas than analyzed in the DEIR and any associated impacts localized to the southeastern part of the Planning Area would be commensurately reduced.

The following is a summary of how the specific issues commonly raised in comment letters are addressed in the DEIR:
• Police and Fire Protection Services are discussed in the DEIR Chapter 3.12 and Chapter 5. The Monterey Police Department (MPD) is able to adjust staffing to be appropriate with population levels in order to maintain standards of service. MPD has existing plans in place to increase staffing over the next five to ten years. MPD and MFD have plans to develop a new joint public safety facility. The planned facility would be sufficient to accommodate increased MPD staffing and equipment needed to accommodate the increase in calls for service anticipated with buildout of the Plan. Therefore, the DEIR appropriately determined the cumulative impacts related to police protection services would be less than significant.
• The Monterey Fire Department (MFD) does not have plans to increase staffing, equipment levels and to construct a new public safety facility to accommodate projected growth within its service area. The DEIR identified the need for a new fire station to serve the southeastern portion of the Planning Area, based on cumulative growth projections within its service area. While the location and design of this facility cannot be known at this time, the construction of the facility could potentially result in environmental impacts. Therefore, the DEIR incorporated Mitigation Measure MM-PF-1, which would reduce potential environmental impacts associated with construction of the new public safety facility to the maximum extent practicable. This mitigation measure requires measures to minimize disruption to natural resources; prevent pollution and soil erosion during construction; prevent soil erosion and sedimentation of nearby water bodies; to protect and preserve existing vegetation, including trees and native plants during construction; minimize noise and air pollution during construction; and require the use of fire-safe building materials and design features to limit the risk of damage or loss due to wildfire. Accordingly, the DEIR appropriately determined that cumulative impacts to fire and emergency medical services would be less than significant with mitigation.
• Visual resources are discussed on pages 5-5 through 5-7 of the DEIR, as well as in Chapter 3.1. The 2005 General Plan Urban Design Element includes numerous policies to ensure that new development pursuant to the Proposed Plan would not substantially degrade the scenic character of the Planning Area. New development within the Planning Area would primarily be focused into the previously developed areas, although the 50-acre MPUSD site within the Highway 68 Area Plan boundary is vacant. Monterey County's Sixth Cycle Housing Element identifies the capacity for 1,324 new homes on four sites immediately south of the Highway 68 Area Plan boundary and southeast of the 50-acre MPUSD site in unincorporated Monterey County at the time of publication of the DEIR. These County sites are located approximately 700 ‘ from potential development sites within the Planning Area, and implementation of proposed Housing Element Program 1-E would involve standards to integrate the new housing on the MPUSD site in a context-sensitive manner.

Therefore, in combination with 2005 Urban Design Element policies, implementation of Program 1-E would not substantially degrade scenic vistas along Highway 68 and associated impacts would be lessthan significant. With implementation of General Plan policies and existing City regulations, substantial adverse effects on scenic vistas and resources in and around the Planning Area would be minimized to the extent practicable and associated impacts would be less than significant.

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• Air quality is discussed in Chapter 3.3, as well as page 5-7 of the DEIR. Development under the Proposed Plan would include area-wide sources of criteria air pollutant emissions and may also result in the installation or operation of new stationary sources of TACs (e.g., emergency generators). Although it is unknown what specific sources would be installed or where they would operate, all new stationary sources would be subject to the permit authority of MBARD, and review of new sources are subject to BACT requirements. These regulatory mechanisms would ensure that cancer and health hazard impacts from stationary sources developed under the future projects would be less than significant. However, they may not be sufficient to address PM impacts if the source results in significant PM concentrations, especially given the existing nonattainment status for PM10 and the expected increase in PM emissions due to the Proposed Plan. As such, these impacts are conservatively assumed to be considerable.
• Airport hazards are discussed in Chapter 3.8, as well as page 5-13. Future development under the Proposed Plan would be required to comply with the safety zone land use compatibility standards in Table 4B Safety Criteria Matrix of the Airport Land Use Compatibility Plan (ALUCP) in order to protect and promote the safety and welfare of residents and airport users. The Safety Criteria Matrix establishes maximum densities, intensities, prohibited uses, and other development conditions for proposed development within the ALUCP safety zones to restrict the development of land uses that could pose particular hazards to the public or to vulnerable populations in case of an aircraft accident. Further, the proposed Land Use Element includes policies to minimize airport safety hazards and promote compatibility with airport operations, including Policy C.1 which requires that new development be compatible with the standards for land uses, density, and intensity specified in ALUCP for the Monterey Regional Airport. Therefore, compliance with the ALUCP and implementation of the Proposed Plan would reduce airport safety hazards potentially resulting from new development to the maximum extent practicable. Associated impacts would be less than significant.
• Pedestrian and bicycle safety is discussed on page 3.13-7 in Chapter 3.13. The proposed Circulation Element sets out a list of guidelines and considerations for Complete Streets in the City’s multimodal plan, which would maximize safety through design (Policy b.6), aligning with Move Monterey’s strategy to examine projects impact on safety for pedestrians and bicyclists.

Further, the proposed Circulation Element also requires development projects to provide on-site facilities such as bicycle parking and showers, to dedicate land to expand existing facilities or provide new facilities such as sidewalks/multi-use paths and/or bicycle lanes, and to ensure projects are designed to be efficiently served by bike routes and pedestrian connections (Policy c.9). As a result, the Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, particularly bicycle and pedestrian facilities, and the impact would be less than significant.
• Traffic congestion is discussed on page 3.13-8 of the DEIR which states that impacts relating to traffic congestion are no longer recognized or required under CEQA and thus, congestion is not analyzed in the DEIR. However, transportation is discussed on page 5-14 of the DEIR and in Chapter 3.13. Buildout of the Proposed Plan would result in increased development in the Planning Area and would generate additional vehicle trips on the local and regional roadway network.

Although the implementation of Mitigation Measure VMT-1 can be expected to reduce work VMT per employee generated in the Planning Area and reduce the magnitude of the impact, the precise mix of incentives offered by employers cannot be known at this time and their effectiveness cannot be accurately estimated now. Thus, this EIR conservatively assumes that Proposed Plan would result in a significant and unavoidable impact..
• Water supply is discussed on pages 5-16 and 5-17 of the DEIR and in Chapter 3.14. The analysis considers the cumulative impact of development from the Proposed Plan in combination with reasonably foreseeable development within the service areas of the two water providers that serve ATTACHMENT 1 / EXHIBIT A
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that Planning Area. As described more fully below in Master Response 2, the DEIR appropriately concluded that even after implementation of all feasible mitigation measures, associated impacts would remain significant and unavoidable.

Master Response 2: Master Response on Adequate Water Supply to Serve Projected Need A critical issue considered in the Draft Environmental Impact Report (DEIR) is the availability of water supply for new development. It is the primary constraint to development on the Monterey Peninsula. Most of the Planning Area is serviced by the California-American Water Company (Cal-Am); however, about 126.8 acres of land at Fort Ord is within the Marina Coast Water District (MCWD) future study area as shown on Figure 3.14-1 in the DEIR. Historically, the Carmel River provided the bulk of water supply to the Monterey Peninsula; however, in 1995, the State Water Resources Control Board (SWRCB) adopted Order WR 95-10, which found that Cal-Am was diverting about 10,730 acre-feet per annum of water from the Carmel River without a valid basis of right and directed that Cal-Am should diligently implement actions to terminate its unlawful diversion. The restrictions are in place to limit the amount of water diverted from the Carmel River to protect critical habitat and endangered species; however, this has effectively halted the development of housing in the region and severely impacted the development of workforce housing, resulting in workers who work on the Monterey Peninsula living far outside the community and enduring long and expensive commutes.

In this context, numerous comments on the DEIR questioned whether adequate water supply would be available to serve development under the Proposed Plan and cumulatively in the region. One commenter questioned the adequacy of the water supply analysis and the associated mitigation measures included in the DEIR. This master response has been prepared to clarify current and planned sources of water supply available to serve new development based on information provided by the water service providers that serve the Planning Area, to clarify the findings of the DEIR with respect to adequacy of the water supply to serve new development, and to correct mischaracterizations in the public comments regarding the adequacy of analysis and mitigation measures in the DEIR.

To inform the analysis in the DEIR, the City requested Water Supply Assessments from Cal-Am and the Monterey Peninsula Water Management District to evaluate whether total projected water supplies available during normal, single-dry and multiple-dry water years are sufficient to meet the projected water demand associated with the Proposed Plan. For the assessment of Marina Coast Water District (MCWD) water supply, the DEIR relied on information contained in the MCWD 2020 Urban Water Management Plan (UWMP) and asked MCWD to confirm current and future water supply for City of Monterey-owned properties on the former Fort Ord. A summary of the water supply and demand analysis in the DEIR based on information from the respective water service providers is presented below.

Summary of California-American Water Company Supply and Demand Analysis The findings of the Cal-Am WSA are incorporated into Chapter 3.14 of the DEIR and the full WSA is included in Appendix I. The WSA shows that under the normal year and single dry year scenarios, available supply would not be sufficient to serve total projected demand in 2025; however, if anticipated future supply from the Pure Water Monterey Expansion Project (which provides purified recycled water for injection into the Seaside Groundwater Basin and extraction for potable use) and the Monterey Peninsula Water Supply Project Ocean Desalination Plant become available by 2030, total available supply would exceed demand in 2031. The WSA also finds that with these additional future sources of supply, total available supply within the Cal-Am service area in 2031 under a multiple dry year scenario would exceed projected demand. Until the new supplies come online, Cal-Am will use its Water Shortage Contingency Plan measures to maintain demand below the available supply.

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Summary of Marina Coast Water District (MCWD) Supply and Demand Analysis Information from the MCWD 2020 UWMP was incorporated into Chapter 3.14 of the DEIR. The 2020 UWMP projects that available groundwater supply will be sufficient to meet demand in its service area through 2040, including a reliable supply of 9,620 acre-feet per year (AFY) of water from the Salinas Valley Groundwater Basin pursuant to the agreements under which MCWD and the former Fort Ord were separately annexed into Monterey County Zones 2/2A in 1996 and 1993, respectively. This supply is sufficient to meet a total demand of 9,574 AFY in the service area through 2040, including a projected demand from the City of Monterey. In 2022, the Association of Monterey Bay Area Governments (AMBAG) adopted a Regional Housing Needs Allocation Plan for the 2023-31 period which established the share of the regional housing need that each member jurisdiction must plan for in its General Plan Housing Element. As the 2020 UWMP was produced prior to the adoption of the AMBAG Regional Housing Needs Allocation Plan, it does not fully account for the RHNA allocations of the other communities served by MCWD, including the cities of Marina, Seaside, and Del Rey Oaks and unincorporated portions of Monterey County. However, the MCWD 2020 UWMP identifies actions to increase future supply, including reactivation of a MCWD pilot seawater desalination plant and participation in Phase 2 of the Pure Water Monterey Expansion Project, which would deliver sufficient additional water supply to meet projected demand within the MCWD service area in 2031. Reactivation of the MCWD pilot seawater desalination plant would add 300 AFY of additional supply, and MCWD will receive up to an additional 1,427 AFY of advanced treated recycled water from the Pure Water Monterey Project through an agreement with Monterey One Water signed on April 8, 2016. Assuming a factor of 0.25 AFY per unit consistent with the demand projections for typical residential uses in the 2020 UWMP, this would provide sufficient water for 6,908 units, which far exceeds the total projected residential buildout of all communities served by MCWD in 2031.

Summary of Environmental Determination in the DEIR
Although while the analysis indicates that adequate water supply will be available to serve projected need within each provider's service area in 2031, including demand from the Proposed Plan, the DEIR concludes that it cannot be determined with absolute certainty that the actions identified by each provider to increase supply will be completed as planned, and as a result the DEIR finds that a significant and unavoidable impact related to adequate water supply would result.

The DEIR incorporates Mitigation Measure UTIL-1, implementation of which would reduce water demand resulting from implementation of the Proposed Plan to the extent feasible; however, compliance with these standards alone would not be sufficient to offset the anticipated supply shortfall under average, single dry year, or multiple dry year scenarios if the planned supply expansions do not materialize. Further, the DEIR notes that Program 2-K of the proposed Housing Element calls for the City to continue to work with other jurisdictions and agencies to optimize the use of available supply in the short-term and to augment the existing water supply in the mid- to long-term by continuing to require as a condition of project approval that new development and remodels implement the Monterey Peninsula Water Management District's Rule 142 Water Efficiency Standards, as applicable, in order to minimize the use of water; supporting efforts by regional water service providers to expand the water supply, including future supply from the Pure Water Monterey Expansion Project and the Monterey Peninsula Water Supply Project Ocean Desalination Plant, anticipated to become available by 2030; and facilitating prioritization of adequate supply for affordable housing projects, in compliance with AB 1087. The DEIR also incorporates Mitigation Measure UTIL-2, involving actions MCWD has planned to expand its water supply, including reactivation of the pilot seawater desalination plant and procurement of additional supply from Phase 2 of the Pure Water Monterey Expansion Project. However, implementation of actions needed to increase supply is not within the jurisdiction of the City of Monterey to undertake.

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Considering that although Phase 2 of the Pure Water Monterey Expansion Project is anticipated to deliver an additional 2,250 AFY of water to the Seaside Basin that would be available to Cal-Am customers, the DEIR explains that the project has not been proven to provide the full 2,250 AFY, particularly during dry years. A 2022 analysis determined that the expansion can be reasonably expected to provide 2,001 to 2,234 AFY during normal conditions and 0 to 1,100 AFY during drought conditions. Further, funding for the Ocean Desalination Plant has not yet been identified and construction has not yet begun. As such, it cannot be said with certainty that the plant will be operational by 2030 as envisioned. No other feasible alternative sources of additional water supply have been identified by Cal-Am. Additionally, while the additional sources of supply identified in the MCWD 2020 UWMP could deliver sufficient water to meet projected demand from the Proposed Plan, MCWD does not currently have funding in place to reactivate the pilot seawater desalination plant or to procure additional supply from Phase 2 of the Pure Water Monterey Expansion Project. No other feasible alternative sources of additional water supply have been identified by MCWD. Accordingly, even after implementation of all feasible mitigation measures, it cannot be said with absolute certainty that the actions identified by each provider to increase supply will be completed as planned, and as such, the DEIR determined that a significant and unavoidable impact related to adequate water supply would result.

Therefore, the DEIR adequately analyzed the adequacy of water supply to meet the projected water demand associated with the Proposed Plan, in combination with the existing and planned future uses within each provider's service area and appropriately determined that the associated impact would remain significant and unavoidable even after implementation of all feasible mitigation.

Information from Monterey Peninsula Water Management District In August 2023, the City also requested a WSA from Monterey Peninsula Water Management District (MPWMD), the agency that regulates potable water use on the Monterey Peninsula. The City requested that MPWMD evaluate whether total projected water supplies available during normal, single-dry and multiple-dry water years would be sufficient to serve projected demand from the Proposed Plan, including up to 5,800 new housing units and 1,995 new jobs by 2031. In response, MPWMD sent a letter to the City in January 2024 asserting that a future Supply versus Demand analysis based on the AMBAG 2022 Regional Growth Forecast demonstrates existing and planned sources of supply would be sufficient to meet the region’s demand needs for over 30 years. However, the AMBAG 2022 Regional Growth Forecast does not fully account for the City's 2023-31 RHNA allocation and is not based on employment projections that accurately reflect the number of existing jobs in the City of Monterey in 2023. As such, the letter from MPWMD does not provide sufficient basis for assessing whether projected supply would be sufficient to meet the projected water demand associated with the Proposed Plan, in combination with the existing and planned future uses. The January 2024 MPWMD letter is also included in Appendix I.

2.3 Responses to Comments
As described above, this chapter includes responses to comments on environmental issues raised in the comment letters. Responses to written comments received during the public comment period are summarized in Table 2-3 below. The reference number and text of the comments are presented alongside the response for ease of reference. Where the same comment has been made more than once, a response may direct the reader to another numbered comment and response.

Responses focus on comments that raise important environmental issues or pertain to the adequacy of analysis in the Draft EIR or to other aspects pertinent to the potential effects of the Proposed Project on the environment pursuant to CEQA. Comments that address policy issues, opinions, or other topics beyond ATTACHMENT 1 / EXHIBIT A
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the purview of the Draft EIR or CEQA are noted as such for the public record. Where comments are on the merits of the Proposed Project rather than on the Draft EIR, these are also noted in the responses.

Where appropriate, the information and/or revisions suggested in the comment letters have been incorporated into the Final EIR. Where such revisions are warranted in response to comments on the Draft EIR, deletions are shown in strikethrough and additions are shown underlined in red in the matrix of comments and responses.

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Table 2-3: Responses to Comments Received on the Draft EIR Letter Commenter Date Comment Response
A1-1 Association of
Monterey Bay
Area
Governments
3/11/24 Thank you for the opportunity to review Draft
Environmental Impact Report (DEIR) and the Revised Draft Housing Element for the City of Monterey’s 2031 General Plan Update. The following comment is offered for your
consideration. In the 2023-31 Housing Element, AMBAG
requests the following revision:

On page 3-2 under section Regional Housing Needs
Allocation, it states, “Monterey’s Regional Housing Needs Assessment (RHNA) allocation for the 2023-31 planning
period has been determined by ABAG to be…” Please revise “ABAG” to “AMBAG.” Thank you for the opportunity to
review the DEIR for the 2031 General Plan Update. Please feel free to contact me at [email protected] or (831)
264-5086 if you have any questions.

The comment is noted.The Housing
Element Page 3-2 has been amended to
correct this issue. The comment pertains to
the Proposed Plan and is not related to the
adequacy of the DEIR; thus, no further
response is required.

A2-1 Department of
Toxic
Substances
Control
3/20/24 The Department of Toxic Substances Control (DTSC) received a DEIR for the Monterey 2031 General Plan Update.

The Proposed Plan is a targeted update to the Housing, Land Use, Safety, and Circulation Elements of the City of Monterey General Plan to respond to emerging issues and new State laws. It contains goals, policies, and programs to guide future development of up to approximately 5,800 units and 1,995 jobs within a Planning Area that encompasses approximately

8.67 square miles and 3.5 square miles of water. The Housing Element identifies suitable sites to accommodate the City's assessed share of the regional housing need through 2031 and incorporates strategies to remove barriers, further fair access to housing, and facilitate buildout of the sites. The Land Use Element introduces new land use designations and
policies to foster mixed use neighborhoods and promote
compatibility with airport and military operations. The Safety Element includes new data on natural hazards and climate change along with actions to strengthen community resilience and emergency evacuation capacity. The Proposed Plan also ensures consistency between the Land Use Element and
newly adopted Monterey Regional Airport Land Use
The comment is noted. The comment is an
introductory summary of the General Plan
Update and does not comment specifically
on the adequacy of the DEIR; thus, no
further response is required.

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Letter Commenter Date Comment Response
Compatibility Plan. The Circulation Element incorporates strategies for multi-modal mobility, roadway safety, and VMT reduction. Based on our project review, we request
consideration of the following comments:

A2-2 Department of
Toxic
Substances
Control
3/20/24 1. The proposed Project encompasses multiple active and nonactive mitigation and clean-up sites where DTSC has
conducted oversight that may be impacted as a result of this Project. This may restrict what construction activities are permissible in the proposed Project areas in order to avoid any impacts to human health and the environment.

The comment is noted. Please see also
response to comment A2-3, below.

A2-3 Department of
Toxic
Substances
Control
3/20/24 2. Due to the broad scope of the Project, DTSC is unable to determine the locations of the proposed sites,
whether they are listed as having documented
contamination, land use restrictions, or whether there is the potential for the sites to be included on a list of hazardous materials sites compiled pursuant to
Government Code Section 65962.5. Therefore, DTSC
recommends providing further information on the
proposed project and areas that may fall under DTSC's
oversight within future environmental documents. Once
received, DTSC may provide additional comments on the
future environmental documents as further information
becomes available. Please review the project area in
Envirostor; DTSC’s public-facing database.

The City notes that the Proposed Plan is a
long-range planning document that
establishes policies and standards to guide
development and conservation within the
Planning Area through 2031, but that it does
not propose development on any specific
site. While the Housing Element identifies
candidate sites to accommodate the City's
assessed share of the regional housing need
for the planning period, as noted on page 2-
22 "the designation of a site for a specific
land use in the Proposed Plan does not
guarantee that a site will be developed or
redeveloped at the assumed density during
the planning period, as future development
will rely primarily on each property owner’s
initiative." Accordingly, the analysis in this EIR
is completed at a programmatic level,
consistent with the nature of a long-range
planning document.

As discussed on page 3.8-3 of the Draft EIR,
the Planning Area includes 16 hazardous
materials sites (under oversight of the
Central Coast Regional Water Quality
Control Board (CCRWQCB) and the
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Letter Commenter Date Comment Response
DTSC), which are shown in Figure 3.8-1 and
detailed in Table 3.8-1. On page 3.8-27, the
Draft EIR notes that 11 of these 16 sites are
open cleanup program sites where
compliance with State and local regulations
would be required prior to redevelopment
to ensure that development, if proposed,
would not result in a significant hazard to
the public. Further, the Draft EIR discloses
the presence of unexploded ordnances
(UXO) on the site of the former Fort Ord
Military Base and incorporates Mitigation
Measure HAZ-1 which requires that, prior
to issuance of a building permit for
residential or mixed use development on
APN 031-191-018-000 (referred to as parcel
E29.1), the City shall require documentation
demonstrating that soil and water on the
parcel have been remediated consistent with
the Residential Quality Assurance (RQA)
process (or equal) and that the residential
restriction has been removed by DTSC. On
this basis, the Draft EIR finds that
compliance with existing regulations and
implementation of Mitigation Measure HAZ1 would reduce potential impacts to a less than significant level. This finding is
appropriate given the programmatic nature
of the Proposed Plan and the fact that no
specific projects are proposed at this time
and sufficient information to enable a
project-specific environmental analysis is not
available. At such time as developments are
proposed on specific sites subsequent to the
Proposed Plan, as noted on page 2-29 of the
Draft EIR, "projects will be reviewed by the
City for consistency with the Proposed Plan
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Letter Commenter Date Comment Response
and this EIR, and adequate project-level
environmental review will be conducted as
required under CEQA."
A2-4 Department of
Toxic
Substances
Control
3/20/24 DTSC believes the City of Monterey must address these comments to determine if any significant impacts under the California Environmental Quality Act (CEQA) will occur and, if necessary, avoid significant impacts under CEQA. DTSC recommends the department connect with our unit if any
hazardous waste projects managed or overseen by DTSC are discovered. Please refer to the City of Monterey EnviroStor Map for additional information about the areas of potential contamination.

DTSC appreciates the opportunity to comment on the
Monterey 2031 General Plan Update. Thank you for your
assistance in protecting California’s people and environment from the harmful effects of toxic substances. If you have any questions or would like any clarification on DTSC’s
comments, please respond to this letter or via email for additional guidance.

The summary comment is noted. Please see
also response to comment A2-3 above.

A3-1 California
Department of
Transportation
3/25/24 The California Department of Transportation (Caltrans), District 5, Development Review, has reviewed the City of Monterey General Plan DEIR which contains goals, policies, and programs to guide the future development of up to
approximately 5,800 units and 1,995 jobs within a planning area that encompasses approximately 8.67 square miles and

3.5 square miles of water. Caltrans offers the following comments in response to the DEIR:

1. Caltrans applauds the City of Monterey General Plan’s efforts to ensure that infrastructure is seamlessly
integrated, well-connected, and supports all modes and
users through a balanced multimodal transportation
network. These measures will help meet statewide goals
of reducing vehicle miles traveled and greenhouse gas
emissions while supporting an equitable transportation
network for all users.

The comment is noted. The comment is not
related to the adequacy of the DEIR; thus, no
further response is required.

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A3-2 California
Department of
Transportation
3/25/24 2. We support the City of Monterey in adopting Policy 1.2.

Increased densities affect the distance people travel and provide greater options for the mode of travel they
choose. Increasing residential density results in shorter and fewer trips by single- occupancy vehicles.

The comment is noted. The comment is not
related to the adequacy of the DEIR; thus, no
further response is required.

A3-3 California
Department of
Transportation
3/25/24 3. Caltrans appreciates the efforts to reduce employmentbased VMT based on the strategies of CAPCOA’s Handbook for Analyzing Greenhouse Gas Emissions
Reductions, Assessing Climate Vulnerabilities, and
Advancing Health and Equity. Incorporating multiple of
these strategies could result in an additional reduction in VMT under the proposed plan.

The comment is noted. The comment is not
related to the adequacy of the DEIR; thus, no
further response is required.

A3-4 California
Department of
Transportation
3/25/24 4. To continue to combat employment-based VMT, we encourage an increase in transit frequency on one or
more transit lines serving the community. Increased
transit frequency reduces waiting and overall travel times, improving the user experience and increasing transit
service attractiveness. This results in a mode shift from single occupancy vehicles to transit.

The comment is noted. The City does not
have jurisdiction over Monterey-Salinas
Transit (MST), and as such, increasing transit
frequency would be an infeasible mitigation
measure. However, as detailed on page 3.13-
20, the Proposed Plan incorporates
strategies to promote the development of
mixed use villages and transit-oriented
development within the City limit. Therefore,
overall implementation of the Proposed Plan
would support the delivery of frequent,
reliable transit and help attract new and
retain existing MST riders.

A3-5 California
Department of
Transportation
3/25/24 Figure 3.9-5 shows both the projected sea level rise and coastal hazards. Overlapping info makes it harder to identify anticipated conditions on the map. We suggest breaking this single map into two different maps: 1) sea level rise and 2) coastal hazards.

Thank you for the opportunity to review and comment on
the proposed project. If you have any questions or need further clarification on the items discussed above, please contact me at (805) 835-6543 or email
[email protected].

The comment is noted. Figure 3.9-5 has now
been separated into two figures, comprising
Figure 3.9-5A and Figure 3.9-5B.

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A4-1 County of
Monterey
3/19/24 Thank you for the opportunity to comment on the Draft EIR for the City of Monterey’s draft Housing, Land Use,
Circulation, and Safety Elements. We’ve provided our
comments below.

1. Planning Area: The planning area doesn’t appear to
contemplate any of the unincorporated areas that are
within Monterey’s sphere of influence. California
Government Code Section 65300 requires a city to
include in its General Plan all territory within the
boundaries of the incorporated area as well as “any land outside its boundaries which in the planning agency’s
judgment bears relation to its planning.” The Governor’s Office of Planning and Research (OPR) General Plan
Guidelines recommend that when establishing a planning
area, each city consider using it’s [sic] sphere of influence as a starting point, and building on that area based on other factors. As the sphere of influence is the probable physical boundaries and service area of the city (Gov.

Code § 56076), it seems that it would have some relation to Monterey’s planning. While a broader planning effort for these areas is likely out of the scope of this update, we would suggest acknowledging the unincorporated
sphere of influence in the planning area, and potentially land use element.

The comment is noted. As it does not
pertain to the merits of the environmental
analysis in the EIR, no further response is
required.

However, the City notes that the planning
area is defined in Chapter 1 of the General
Plan, and as shown on Map 1, includes both
land within the City limit and the City’s
Sphere of Influence (SOI) as established by
LAFCO. Further, the City notes that the
General Plan contains policies related to
conservation, open space, and visual
resources that account for land within the
SOI.

A4-2 County of
Monterey
3/19/24 2. Agricultural Mitigation: MM-AG-1 suggests participation in the Monterey County Agricultural Conservation
Mitigation Program. If this is in reference to the
agricultural mitigation program currently being
developed by the County, we don’t think that approach
would be feasible at this time. The program has not been adopted, and as drafted does not appear to apply to the plan update:
a. It only applies to the inland areas of the
unincorporated County.
b. The mitigation is for Grazing Land, while our draft
program defines Farmland to be Prime Farmland,
The comment is noted. As described on
page 3.2-11 of the Draft EIR, MM-AG-1
requires that, prior to approval of a
development project which would convert
land classified by the FMMP as Grazing Land
to non-agricultural uses, project applicants
offset the loss of such land at a 1:1 ratio,
either through the acquisition and dedication
of comparable Farmland within Monterey
County or through the acquisition and
dedication of a conservation easement on
comparable Farmland within Monterey
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Farmland of Statewide Importance, Unique
Farmland, or Farmland of Local Importance (similar
to CEQA Statute definition of Agricultural Land in
Public Resources Code section 21060.1.).
c. The draft applies to changes in land use designation from an agricultural designation to a nonagricultural designation, or certain discretionary entitlements on properties with an agricultural land
use designation and zoning.

County. Dedication of the land or
conservation easement shall be to an open
space trust or comparable entity acceptable
to the City. Alternately, compliance with this
mitigation measure may be achieved through
participation in the Monterey County
Agricultural Conservation Mitigation
Program, if it has been adopted by the time
the need for mitigation occurs.

The City notes that the Monterey County
Agricultural Conservation Mitigation
Program has not been adopted at this time;
however, this does not affect the feasibility of
MM-AG-1, as participation in the program (if
or when it is adopted) is an alternate
compliance method, not a requirement of
the mitigation measure.

A4-3 County of
Monterey
3/19/24 3. Marina Coast Water District: Mitigation Measure MMUTIL-2 states that the MCWD shall increase sources of water supply. Per CEQA Guidelines section
15126.4(a)(2), mitigation measures must be fully
enforceable. We strongly encourage you to coordinate
with the district if they are intended to be the party
ultimately responsible for implementing this mitigation.

Please contact me with any questions at (831) 784-5731
or [email protected].

The comment is noted. Please see response
to comment C1-11 and MR-2 regarding
water supply availability. The City has
communicated with MCWD and the
proposed mitigation measure is based on the
information made available to the City as of
the time of drafting the EIR, including these
responses to comments. As explained in the
DEIR and Master Response MR-2, however,
the City does not control MCWD and can
only encourage and recommend the actions
outlined in the mitigation measure, which, if
implemented, would be effective in
addressing the water supply constraints. No
other feasible mitigation has been identified
that the City could adopt and implement.

Therefore, the City concludes that in the
absence of its authority, the impact is
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significant and unavoidable, as allowed under
CEQA. (See CEQA Guidelines, § 15091,
subd. (a)(2).)
A5-1 MontereySalinas Transit3/25/24 Monterey-Salinas Transit District (MST) provides public transportation throughout the City of Monterey and
operates a transit hub at the Monterey Transit Plaza, which provides connections to neighboring communities. MST is happy to see the City of Monterey advancing its General Plan and we look forward to being a community asset that will support the City’s goal of establishing a pedestrian and transit- oriented city that is safe and equitable. MST has reviewed the Monterey 2031 General Plan Update Draft
Environmental Impact Report (DEIR) and Notice of
Availability (NOA) and would like to make the following comments for your consideration:

3.10 Land Use, Population, and Housing
To prevent substantial unplanned growth in areas of
Monterey, MST recommends the General Plan include
policies that would facilitate mixed-use and transit-oriented development within previously developed areas of Monterey.

MST led a Transit-Oriented Development (TOD) Planning
Study as a part of the planned SURF! Busway and Bus Rapid Transit project. The planning study identifies opportunities to increase TOD viability and ridership potential by enhancing multimodal connections within the SURF! Corridor through improved transit, bike and pedestrian facilities, and
Transportation Demand Strategies (TDM). The Study’s goal is to decrease greenhouse gas (GHG) emissions, reduce
vehicles miles traveled (VMT) from development, and make TOD more attractive for residents and developers in
Monterey County.

MST’s Planning Study identified opportunity sites for TOD five study areas including the Monterey and Seaside area.

These opportunity sites include sites in Laguna Del Rey, Del Monte Light Industrial, and North Fremont areas. MST
recommends that the City of Monterey use MST’s TOD
Planning Study as a resource to access potential for TOD. For The comment is noted. The comment
pertains to the Proposed Plan and is not
related to the adequacy of the DEIR; thus, no
further response is required.

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more information regarding MST’s TOD Planning Study, please visit MST’s website: mst.org/about-mst/planning-development/ A5-2 MontereySalinas Transit3/25/24 3.13 Transportation Planned Transportation Network Changes
MST is in support of the City’s proposed bicycle, pedestrian, crosswalk and American with Disabilities Act (ADA)
enhancements. 86% of MST passengers walk, bike, or scooter to access the bus. Therefore, it is crucial that all traffic calming, and active transportation enhancements be
compatible with transit. Bus stop layouts and designs are evaluated using MST’s Designing for Transit Guidelines (2020) and all stops should adhere to these guidelines to ensure adequate access pertinent to the standards of the American with Disabilities Act (ADA). In addition, transit buses have a width of 10 feet 6 inches, and therefore need a minimum travel lane width of 11 feet. Lane width narrower than 11 feet will preclude service by MST.

Transportation Demand Strategies
MST is in support of the Transportation Demand
Management (TDM) strategies included in the General Plan.

TDM Strategies play a critical role in reducing automobile dependency and improving mobility choices. MST’s TransitOriented Development (TOD) Planning Study outlines TDM measures that can be implemented at the project/site,
community/city, and transportation system management
levels. Some of these strategies include:
• Employer Transit Pass Subsidy
• Shared Mobility Parking
• Street Connectivity Improvements
• Advanced Bicycle and Pedestrian Detection
MST recommends the City of Monterey use the TOD Study’s recommended TDM strategies to further the reduction of
VMT.

The comment is noted. As detailed on page

3.13-21, while residential land uses would
not exceed the established threshold of
significance for either the No Project or the
Proposed Plan in 2031, employment-based
VMT would exceed the established
threshold for both scenarios. As such, only
employment-based VMT would require
mitigation under the Proposed Plan.

Therefore, MM-VMT-1, under which the City
would implement a Commute Trip
Reduction Program applicable to businesses
that employ 50 or more people in Monterey,
is required. The City acknowledges MST’s
TOD Study and will consult as it considers
specific projects and how projects can
further the reduction of VMT. The remainder
of the comment pertains to the Proposed
Plan and is not related to the adequacy of
the DEIR; thus, no further response is
required.

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A5-3 MontereySalinas Transit3/25/24 Impact 3.13-2
MST is in support of Mitigation Measure VMT-1: Implement Commute Trip Reduction Program, which will offer business resources and incentives to reduce the number of singleoccupancy vehicles (SOV) commuting to work. MST has programs available for individuals who are interested in using transit or vanpools for work. MST offers a Group Discount Program, which provides 31-Day MST GoPasses in bulk at a substantially reduced price. Businesses can enroll and offer bus passes to their staff to encourage transit use and reduce the number of SOVs.

MST recently partnered with Enterprise to offer vanpooling options for commuters traveling to or from Monterey
County. Vanpools are open to the public and must have a minimum of four riders to receive a van or SUV from
Enterprise. Participants can receive up to $450 monthly subsidy per vehicle if monthly ridership reports are
completed. MST encourages the City of Monterey to
participate in MST’s programs to extend VMT mitigation
efforts.

The comment is noted. The comment is not
related to the adequacy of the DEIR; thus, no
further response is required.

A5-4 MontereySalinas Transit3/25/24 Existing Transit System MST submits the following comments pertaining to Page

3.13-5 of the Draft EIR:

Monterey-Salinas Transit District (MST) is the principal transit service for the city and the surrounding communities. MST is a joint powers agency special district with a board of
directors that includes a representative from the City.

Thirteen Eleven MST routes currently serve the citizens of the community. The City-owned and maintained Simoneau
Plaza located in downtown Monterey is the transfer center for all routes serving the city. The MST Trolley is an example of a tourist serving transit line which promotes the City’s “Park Once” program encouraging visitors to park once and reduce high demand to the transportation network. Senior and disabled citizens can use the MST fixed-route and Direct Area Response Transit (DART). MST also operated the RIDES The comment is noted. The following edits
have been made:

DEIR p. 3.13-5:
"Monterey-Salinas Transit District (MST) is
the principal transit service for the city and
the surrounding communities. MST is a joint
powers agency special district with a board
of directors that includes a representative
from the city. Thirteen Eleven MST routes
currently serve the citizens of the
community. The City-Owned and maintained
Simoneau Plaza located in downtown
Monterey is the transfer center for all routes
serving the city. The MST Trolley is an
example of a tourist serving transit line
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program for disabled citizens. These routes operate on
weekdays and Saturdays from approximately 7:00 AM to
11:00 PM 6:00 AM to 10:00 PM, and from approximately 7:30 AM to 5:30 PM 7:00 AM to 9:00 PM on Sundays and holidays weekends, and certain routes operate from approximately 7:00 AM to 7:00 PM on holidays.

Please note that the Direct Area Response Transit (DART) has been discontinued.

Closing
As the Monterey 2031 General Plan moves forward, we ask that the City of Monterey continue to collaborate with MST to ensure public transportation is available to Monterey’s residents. If you have any questions about the above
comments, please do not hesitate to contact me at
[email protected] or 831-264-9288.
which promotes the City’s “Park Once”
program encouraging visitors to park once
and reduce high demand to the
transportation network. Senior and disabled
citizens can use the MST fixed-route and
Direct Area Response Transit (DART). MST
also operates the RIDES program for
disabled citizens. These routes operate on
weekdays and Saturdays from approximately
7:00 AM to 11:00 PM 6:00 AM to 10:00 PM,
and from approximately 7:30 AM to 5:30 PM
7:00 AM to 9:00PM on Sundays and holidays
weekends, and certain routes operate from
approximately 7:00 AM to 7:00 PM on
holidays."
This clarification does not constitute
significant new information requiring
recirculation pursuant to CEQA Guidelines
section 15088.5.

A6-1 Department of
the Navy
3/22/24 Thank you for the City of Monterey's (City) consideration of the military mission and potential impacts associated with City policy changes. We acknowledge receipt of the
notification and, currently, do not anticipate negative mission impact from your efforts.

We do, however, have minor suggested nomenclature
adjustments for your consideration and have discussed them with City staff. Primarily, references in text and on mapping products to the Naval Postgraduate School (NPS) should be changed to Naval Support Activity Monterey when
referencing the Navy's property itself (as we are proudly the home of, and therefore the physical location of, NPS).

Once the General Plan update is approved, we would
encourage the City to take advantage of the vast array of federal grant opportunities available to it because of its proximity to multiple military installations. The Office of Local Defense Community Cooperation (www.oldcc.gov) has
The comment is noted. All figures in the
DEIR have been updated to change any
references to the Naval Postgraduate School
to the Naval Support Academy. Any
reference to the Naval Post Graduate
School in the text of the DEIR is a minor
difference in nomenclature and does not
pertain to the adequacy of the
environmental analysis of the DEIR.

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already supported the Monterey Regional Compatible Use
Study and has several other programs, including the Defense Community Infrastructure Program (DCIP), that may prove to be of value in further General Plan policy implementation.

We recognize the immense undertaking of updating your
General Plan document and its impact of defining the City's long-term development goals and vision. ·We look forward to continuing to work with you on future projects and
partnership opportunities.

B1-1 California
Native Plant
Society
3/25/24 Thank you for the opportunity to comment on the City of Monterey’s 2031 General Plan Update Draft Environmental Impact Report (DEIR). The following comments are
submitted on behalf of the California Native Plant Society (CNPS), a non-profit environmental organization with over 12,500 members in 36 Chapters across California and Baja California, Mexico. CNPS’s mission is to protect California’s native plant heritage and preserve it for future generations through the application of science, research, education, and conservation. We work closely with decision- makers,
scientists, and local planners to advocate for well-informed policies, regulations, and land management practices.

The Monterey Bay Chapter of the California Native Plant Society (Chapter) supports the City of Monterey’s goal to adopt plans that provide opportunities for affordable housing development within the city as part of its proposed 2031 General Plan Update. Above all, the Chapter would like to see the City adopt a plan to streamline the development of
housing for those with extremely low and very low incomes, as well as for the special housing needs of people who are elderly or disabled, farmworkers, and people experiencing homelessness, to meet its State-mandated Regional Housing Needs Allocation (RHNA) and facilitate the construction of desperately needed affordable housing in the city from now through 2031.

The Chapter is compelled to advocate for affordable housing and, of course, for the protection of threatened and
endangered plant (and animal) species and incredibly rare and The comment is noted. The comment
summarizes the commenter’s purpose and
mission and introduces the commenter’s
subsequent comments. The introductory
comment is not related to the adequacy of
the DEIR; thus, no further response is
required.

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irreplaceable plant communities, including Maritime
Chaparral, Coastal Prairie, Monterey Pine Forest, vernal pools, riparian woodlands, and wetland meadows, that are currently slated for development by the City’s General Plan Update in its current form.

B1-2 California
Native Plant
Society
3/25/24 California Department of Fish and Wildlife-designated “Sensitive Natural Communities,” as listed above, and an astoundingly large number (39!) of special-status plant and animal species known to occur or with the potential to occur in the City’s Planning Area, would be eliminated or severely impacted by the City’s current plans for commercial
development and mostly non-affordable housing in the Ryan Ranch/Fort Ord and Garden Road/Airport/Highway 68
Opportunity Areas identified in the 2031 General Plan
Update. We need to be emphatically clear here, these are veritable biodiversity hotspots that are being planned for development within this document.

The comment is noted. As detailed on page

3.4-24 of the DEIR, there are 26 specialstatus plant species and 13 special-status wildlife species with potential to occur
within the Planning Area. However, buildout
of the Proposed Plan would focus future
development and redevelopment primarily
into previously developed areas of Monterey.

Many of the special-status species with
potential to occur in the Planning Area,
including seven plant species and six animal
species, have not been documented on or
near the Proposed Plan’s sites identified for
housing development. Even so, development
could contribute to the loss of natural lands
in the Planning Area, with potential effects on
special-status species. However, MM-BIO-1
would require site assessments by a qualified
professional for development applications
that may adversely affect sensitive biological
resources. MM-BIO-2 would require
implementation of a worker environmental
awareness training program to train
construction staff on the needs of protecting
sensitive biological resources and the
ramifications for not complying with
applicable laws. MM-BIO-3 would require the
installation of temporary flagging or barrier
fencing to protect sensitive biological
resources adjacent to the work area as
warranted based on the findings of the site
assessment completed pursuant to MM-BIOATTACHMENT 1 / EXHIBIT A Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2170, Packet Page 2498 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
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1. Further, MM-BIO-4 through BIO-12
outline additional construction requirements
to ensure the protection of special-status
plant species, nesting bird species, bat
species, the burrowing owl, Western bumble
bee, Northern California legless lizard,
Smith's blue butterfly, Monterey shrew, and
the American badger, as warranted based on
the findings of the site assessment.

Therefore, with implementation of MM-BIO1 through BIO-12 and adherence to existing policies and local regulations, as discussed
above, the impacts of future development
under the Proposed Plan on special-status
species would be less than significant.

B1-3 California
Native Plant
Society
3/25/24
These rare and irreplaceable habitats, and the threatened and endangered species they harbor, are protected by the
California Environmental Quality Act (CEQA), the California Natural Community Conservation Planning Act, the federal Endangered Species Act, the California Endangered Species Act, the California Native Plant Protection Act, the Clean Water Act, the Migratory Bird Treaty Act, the Natural
Community Conservation Planning Act, and the California Coastal Act. However, despite these facts, a comprehensive analysis of the anticipated impacts of implementing the City of Monterey’s 2031 General Plan Update, an essential
requirement of the CEQA process, is nearly completely
absent from this Draft Environmental Impact Report. This required comprehensive analysis of the impacts of the
General Plan Update is so lacking, that the Monterey CNPS Chapter’s analysis of the proposed General Plan Update DEIR in this comment letter has been significantly impeded and curtailed due to the lack of essential information in the document.

The DEIR's biological resources Regulatory
Setting, starting on page 3.4-13, details all
relevant federal, State, and local agencies and
regulations that any development pursuant
to the Proposed Plan would be required to
comply with. Pursuant to CEQA
requirements, the DEIR also sufficiently
analyzes impacts on biological resources at
an appropriate level of detail for a programlevel environmental assessment. As noted on page ES-1, the EIR is programmatic and
subsequent project-level CEQA analysis may
be required for specific projects as they are
proposed. As a programmatic EIR, the Draft
EIR cannot assess project specific details
because those details cannot be known at
this time, as no specific project is proposed
on the sites identified for possible
development. However, when a project is
proposed, to the extent that it would result
in any project-specific environmental impacts
not identified and mitigated in this EIR,
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project-specific CEQA review would be
required to identify any project specific
environmental impacts and feasible
mitigation to address them.

B1-4 California
Native Plant
Society
3/25/24 A partial list of the special-status plant and wildlife species found either occurring or with the potential to occur in the City’s Ryan Ranch/Fort Ord and Garden
Road/Airport/Highway 68 Opportunity Areas includes: the federally endangered Yadon’s rein orchid (Piperia yadonii), conservancy fairy shrimp (Branchinecta conservatio), the State and federally endangered Monterey clover (Trifolium trichocalyx), the State and federally threatened California tiger salamander (Ambystoma californiense), the federally threatened Monterey spineflower (Chorizanthe pungens var. pungens) and California red-legged frog (Rana draytonii), the federally endangered and state threatened Monterey gilia (Gilia tenuiflora ssp. arenaria), the federally endangered Smith’s blue butterfly (Euphilotes enoptes smithi), and many State Species of Special Concern including Monterey shrew (Sorex ornatus salarius), burrowing owl (Athene cunicularia), Monterey dusky-footed woodrat (Neotoma fuscipes luciana), Northern California legless lizard (Anniella pulchra), coast horned lizard (Phrynosoma blainvillii), two species of rare and endemic ceanothus, Monterey ceanothus (Ceanothus rigidus) and dwarf ceanothus (Ceanothus dentatus), and four species of rare and endemic manzanitas – Hooker’s (Arctostaphylos hookeri), Toro (Arctostaphylos montereyensis), Pajaro
(Arctostaphylos pajaroensis, and sandmat (Arctostaphylos pumila). Just the names alone tell you how rare, local, and essentially “Monterey” many of these species are.

Many important species with the potential to occur within the Planning Area are completely absent from the DEIR
including California tiger salamander, California red-legged frog, conservancy fairy shrimp, coast horned lizard, Monterey dusky-footed woodrat. These species are not mentioned nor evaluated.

The comment is noted. Information
regarding the potential occurrence of
special-status species in the vicinity of the
Planning Area was obtained from a query of
the CDFW’s California Natural Diversity
Database (CNDDB) and is summarized in
tables 3.4-1 and 3.4-2 and on Figure 3.4-2 of
the DEIR. The CNDDB is regularly updated
to track occurrences of previously
documented special-status species. In
addition, the CDFW submitted comments
identifying special status species that are
known to occur or have the potential to
occur in or near the Planning Area. All such
species identified by CDFW were included
in the DEIR's analysis. Further, as discussed
on pages 3.4-14 through 3.4-15 and 3.4-39
of the DEIR, the Installation-Wide
Multispecies Habitat Management Plan
(HMP) for Former Fort Ord management
establishes guidelines and specifications for
all parcels on the property that are designed
to promote the preservation, enhancement,
and restoration of habitat and populations of
HMP species while allowing development of
properties that promotes economic
recovery after closure of Fort Ord.

Development at Fort Ord pursuant to the
Proposed Plan would be required to comply
with the HMP, reducing the potential for
impacts to identified species.

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According to the HMP, the California tiger
salamander may occur in ponds and vernal
pools throughout former Fort Ord which
represents approximately less than one
percent of land at the site. Protection or
replacement for these waters of the will be
provided through implementation of the
federal Clean Water Act. Further, as stated
on page 3-21 of the HMP, if vernal ponds are
disturbed with development, mitigation and
habitat restoration plans will be required and
must include measures to minimize
disturbance to ponds and vernal pools. The
goal of restoration plans will be to restore
affected wetlands so that they are of the
same acreage and provide the same
functions as before development.

Restoration objectives would include
establishment of self-sustaining populations
of California Iinderiella, California tiger
salamander, and California red-legged frogs
similar to those that existed before
development. Therefore, at a programmatic
level, compliance with the HMP would
reduce impacts to California tiger
salamander to the maximum extent
practicable and impacts would be less than
significant.

The DEIR includes a comprehensive and
accurate list of potentially impacted specialstatus species based on the most up to date and comprehensive information from
CNDDB and CDFW, and the DEIR
appropriately referenced the HMP for the
Former Fort Ord. Nevertheless, to further
clarify and amplify the discussion of special
status species, including California tiger
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salamander, the DEIR is hereby revised as
follows:
• The following text is hereby added
to the end of the second full
paragraph on page 3.4-24: In
addition, according to the
Installation-Wide Multispecies
Habitat Management Plan (HMP)
for Former Fort Ord (1997), the
California tiger salamander may
occur in ponds and vernal pools
throughout former Fort Ord which
represents approximately less than
one percent of land at the site.

Protection or replacement for
these waters of the will be provided
through implementation of the
federal Clean Water Act.
• The following text is hereby added
to the end of the first full paragraph
on page 3.4-25 of the DEIR: Further,
as noted above, the InstallationWide Multispecies Habitat Management Plan (HMP) for
Former Fort Ord management
establishes guidelines and
specifications for all parcels on the
property that are designed to
promote the preservation,
enhancement, and restoration of
habitat and populations of HMP
species while allowing development
of properties that promotes
economic recovery after closure of
Fort Ord. Development at Fort
Ord pursuant to the Proposed Plan
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would be required to comply with
the HMP, reducing the potential for
impacts to identified species.
• The second paragraph of page 3.4-
30 is hereby amended as follows:

Further, Mitigation Measures BIO-4
through BIO-12 outline additional
construction requirements to
ensure the protection of specialstatus plant species, nesting bird species, bat species, the burrowing
owl, Western bumble bee, Northern
California legless lizard, California
tiger salamander, Smith's blue
butterfly, Monterey shrew, and the
American badger, as warranted
based on the findings of the site
assessment.

Further, out of an abundance of caution,
Mitigation Measure BIO-3 on page 3.4-26 is
hereby revised as follows to further reduce
potential impacts to California tiger
salamander, which with HCP compliance
would already be less than significant:

MM-BIO-3: Install Temporary Flagging
or Barrier Fencing to
Protect Sensitive
Biological Resources
Adjacent to the Work
Area. If required pursuant to
Mitigation Measure BIO-1, a
qualified biologist with prior
experience for subject
species in Monterey County
shall identify and flag or
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fence sensitive biological
habitat on-site to ensure it is
avoided during construction
and pre-construction
activities. Flagging or fencing
shall be installed prior to site
preparation activities and
remain in place for the
duration of construction
activities.

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• A USFWS-approved
biologist will
demarcate the limits
of the fence line.

The barrier will be
inspected and
repaired at least
weekly to ensure it
remains in place
during construction.
• A biological monitor
will survey suitable
habitat, including all
wetlands, prior to
grading or filling. If
either species is
located during
surveys, it will be
moved to an
approved off-site
location in
coordination with
the USFWS and
CDFW.

B1-5 California
Native Plant
Society
3/25/24 The Monterey Bay Chapter of the California Native Plant Society writes in strong opposition to the elements of the 2031 General Plan Update which would lead to the
destruction (i.e. being bulldozed) of the State-protected Sensitive Natural Communities found in the Ryan Ranch/Fort Ord and Garden Road/Airport/Highway 68 Opportunity
Areas, including Monterey Pine Forest, Maritime Chaparral, Coastal Prairie, vernal pools and wetlands. The Chapter, with science-driven understanding and expertise, calls on the Planning Commission to identify and remove these highly The comment is noted. As detailed on page

3.4-36, the Proposed Plan would not involve
development within any of the habitat
corridors identified in the HMP and would
only occur within locations identified as
development areas in the HMP, development
in the Fort Ord/Ryan Ranch opportunity
area would occur adjacent to the NorthSouth Road Conservation Area identified in the HMP and development on the 50-acre
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sensitive areas from current development plans before
approving the 2031 General Plan Update Draft Environmental Impact Report.

MPUSD site within the boundaries of the
Highway 68 Area Plan would occur adjacent
to a large area of natural open space.

Development in these areas may result in
disturbance to these movement habitats,
causing fragmentation of wildlife movement
corridors. However, Proposed Plan Programs
1-H and 1-I envision that new development
would be integrated into portions of these
areas while also preserving carefully selected
areas of natural open space and habitat. As
such, future development within the Planning
Area would be subject to the Proposed
Plan’s programs, local regulations, and
General Plan goals and policies related to
biological resources that involve preserving
and protecting open space; preserving
natural resources, including plant, animal, and
fish habitats; protecting wetlands; and
protecting and enhancing streams and
creeks. Compliance with these policies and
regulations would ensure the preservation of
natural resources in the Planning Area and
impacts would be less than significant.

B1-6 California
Native Plant
Society
3/25/24 The project will have significant and irreversible impacts to the aforementioned biological resources, and the DEIR has failed to adequately establish baseline conditions and analyze the impacts to biological resources in the Ryan Ranch/Fort Ord and Garden Road/Airport/Highway 68 Opportunity
Areas to justify, based on substantial evidence, that the proposed mitigation measures for biological impacts will be sufficient and effective. Below, we outline in greater detail the numerous issues related to the project in its current form and the deficiencies in the DEIR, and provide our conclusion that the project’s development plans and DEIR must be
substantially revised prior to approval.

The comment is noted. As detailed on page

3.4-23, the Proposed Plan’s Planning Area
was compared against existing biological
conditions to determine potential impacts
on biological resources that could result
from implementation of the Proposed Plan.

No field studies or other research were
conducted for preparation of this Draft EIR
because existing resources contained
information on all pertinent aspects of
biological resources in the Planning Area at
an appropriate level of detail for a programlevel environmental assessment. The CDFW ATTACHMENT 1 / EXHIBIT A
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submitted comments regarding baseline
natural resource information and special
status species that are known to occur or
have the potential to occur in or near the
Planning Area which informed the analysis.

Information regarding the occurrences of
these special-status species within the
boundaries of the Planning Area was
obtained from a query of the CDFW’s
California Natural Diversity Database
(CNDDB). Future project-specific detailed
biological surveys may be necessary to
confirm the presence or absence of sensitive
resources on future development sites.

Therefore, impacts associated with future
development as a result of the Proposed
Plan implementation are analyzed adequately
and qualitatively at a program level pursuant
to CEQA requirements.

B1-7 California
Native Plant
Society
3/25/24 Ryan Ranch/Fort Ord Opportunity Area
The DEIR mentions that there is “a cluster of underutilized commercial properties north of Upper Ragsdale Road which presents opportunities for redevelopment.” DEIR mapping shows this over 150-acre strip of former Fort Ord lands zoned as “Mixed Use Neighborhood” (Figure 2-4: General
Plan Land Use) and “Mixed Income” (Figure 2-6: Sites
available for Housing) housing opportunity sites. However, these former Fort Ord lands contain some of the rarest and most imperiled habitat in the State, habitat that is found nowhere else on the planet – Central Coast Maritime
Chaparral. The specific type of Central Coast Maritime
Chaparral along Upper Ragsdale Road and in the City’s plan for development is “Sandmat Manzanita Chaparral” and
“Monterey Manzanita Chaparral.”1 These two extremely
sensitive natural communities have the most imperiled
California Department of Fish and Wildlife Sensitive Natural Community State ranking of “S1,” meaning that there are The comment is noted. Please see response
to comment B1-5. In addition, adherence to
MM-BIO-3 would ensure that any sensitive
biological habitat on-site is flagged or fenced
and avoided during construction and preconstruction activities. Further, adherence to MM-BIO-4 would ensure avoidance or
minimized disturbance to special-status plant
species and their associated habitats. As
such, these impacts are less than significant.

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fewer than six viable occurrences of these plant communities in existence in California. Sandmat manzanita (Arctostaphylos pumila) and Monterey manzanita (Arctostaphylos
montereyensis), after which both plant communities above are named, are both native shrubs endemic (limited) to the Central Coast of California and both have a CDFW
California Rare Plant Rank of 1B.2 (rare, threatened, or endangered in California and elsewhere).

B1-8 California
Native Plant
Society
3/25/24 However, with the exception of one DEIR map identifying Maritime Chaparral north of Upper Ragsdale Road, the
mention of Maritime Chaparral in the text of the DEIR is completely and stunningly absent! The City of Monterey is planning on developing (i.e. bulldozing) one of the rarest and most imperiled habitats in California and there is absolutely no discussion of it in the California Department of Fish and Wildlife Vegetation Classification and Mapping Program’s List of Sensitive
Natural Communities, California Department of Fish and
Wildlife’s California Natural Diversity Database, California Native Plant Society Manual of California Vegetation DEIR, let alone a comprehensive review, analysis, and full mitigation program to address the project’s anticipated impacts on this sensitive natural community, and the 39 special-status plant and animal species with the potential to occur here, as required by the California Environmental Quality Act2,3.

Much like Coast Redwood Forest, the Central Coast
Maritime Chaparral plant community thrives within the zone of coastal summer fog – a local meteorological phenomenon with which it evolved and depends on, along with wildfire, for its continuance. Mixed within the Maritime Chaparral are patches of Coast Live Oak woodland, another sensitive
natural community. The Maritime Chaparral ecosystem is
characterized by endemic species of Arctostaphylos
(manzanita) and Ceanothus, which mostly reproduce by seed rather than resprouting and require fire to regenerate.

The comment is noted. Maritime Chaparral
is identified as a habitat type in the Planning
Area in Figure 3.4-1 as well as described on
page 3.4-5. Please see response to comment
B1-7. Impacts on sensitive habitats would be
less than significant.

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B1-9 California
Native Plant
Society
3/25/24 Animal species that are present in Central Coast Maritime Chaparral include: Monterey dusky- footed woodrat
(Neotoma fuscipes luciana) a State Species of Special
Concern, California deer mouse (Peromyscus californicus), brush rabbit (Sylvilagus bachmani), California quail (Callipepla califonica), Heerman kangaroo rat (Dipodomys heermanni), California ground squirrel (Spermophilus beecheyi), California mule deer (Odocoileus hemionus californicus), raccoon
(Procyon lotor), bobcat (Lynx rufus), red-tailed hawk (Buteo jamaicensis), and northwestern fence lizard (Sceloporus occidentalis occidentalis)
Insect species, such as beetles, ants, bumble bees, flies, moths, and butterflies are abundant in maritime chaparral and some species function as important pollinators for the flowering shrub species. Ground-inhabiting beetles include species from the Carabidae and Staphylinidae families, which prey on small arthropods and other organisms, and species from the
Tenebrionidae family, which are mostly scavengers. Seedgathering ants are an important part of the chaparral ant population. The flower-visiting insects consist of the bees, flies, moths, butterflies, and some beetles.

The comment is noted. Please see responses
to comments B1-2 and B1-4.

B1-10 California
Native Plant
Society
3/25/24 The Central Coast Maritime Chaparral is highly threatened by coastal residential development, urbanization, and
agricultural development, along with fire suppression which prevents reproduction and eliminates stands. Common
stressors and threats include fragmentation of the habitat by housing and roads, and nearby housing and agriculture may make utilization of prescribed fire nearly impossible. Exotic, invasive weeds, including pampas grass, iceplant, French broom, and blue gum eucalyptus also threaten many
occurrences of Central Coast Maritime Chaparral. Maritime Chaparral is likely more densely invaded by exotics than other chaparral types because it is more densely fragmented by roads and thus closer to human disturbance and sources of exotic seeds7. The California Coastal Commission
estimates that only 1700 acres of Central Coast Maritime The comment is noted. The comment
presents background information and is not
related to the adequacy of the DEIR; thus, no
further response is required.

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Chaparral remains in California and has adopted a policy that seeks to “ensure that Central Coast Maritime Chaparral is protected and allowed to thrive.”
B1-11 California
Native Plant
Society
3/25/24 In addition to the extremely rare Central California Maritime Chaparral present in the Ryan Ranch/Fort Ord Opportunity Area, the site supports Monterey Pine Forest, another
sensitive Natural Community considered rare by the
California Department of Fish and Wildlife. Monterey Pine Forest occurs naturally in the state in only three coastal populations and the local Monterey stands support a number of special status species, including the federally endangered Yadon’s piperia (Piperia yadonii). This orchid and two other native orchid species (Piperia elongata and Piperia michaelii) have been documented by the Chapter in the Monterey Pine Forest habitat south of South Boundary Road in the former Fort Ord.

The comment is noted. The comment
presents background information and is not
related to the adequacy of the DEIR; thus, no
further response is required.

B1-12 California
Native Plant
Society
3/25/24 Although the Central Coast Maritime Chaparral and Monterey Pine Forest lands are not part of proposals
currently in the City’s pipeline for housing development, the Draft Housing Element calls for the “[P]reparation of a specific plan to guide future residential and mixed-use development in the Fort Ord/Ryan Ranch area, identify
infrastructure needs and financing mechanisms, and establish measures to ensure sustainable development and adequate resource protection.” The City has long hoped to develop the Maritime Chaparral and Monterey Pine Forest lands between South Boundary Road and Upper Ragsdale Road. This land
was transferred to the City by the U.S. Army as part of the Fort Ord Base Reuse Plan as a nominal means to offset
economic losses incurred by the base closure. However, this does not preclude the need to conduct a full CEQArequired comprehensive review, analysis, and full mitigation program to address the project’s anticipated impacts on the biological resources of the Central Coast Maritime Chaparral and Monterey Pine Forest. Nor does it preclude the public’s ability to decide if they still want to develop this biodiversity The comment is noted. Please see responses
to comments B1-3 and B1-5.

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hotspot in the face of an unprecedented and unfolding
extinction crisis.

B1-13 California
Native Plant
Society
3/25/24 Garden Road/Airport/Highway 68 Opportunity Areas The Garden Road/Airport/Highway 68 Opportunity Area
includes the highly scenic Tarpey Flats, the visually stunning and historically significant gateway to the Monterey Peninsula from Highway 68. Tarpey Flats is the last remaining
undeveloped marine terrace in the Monterey Peninsula region and must be appropriately considered in the Scenic Vistas and visual resources section of the DEIR. The scenic Tarpey Flats area provides visually important vistas across undeveloped Coastal Prairie towards the Monterey Pine Forests of Jacks Peak and the Joyce Stevens Monterey Pine Preserve.

The comment is noted. Please see responses
to comments C1-1 and Master Response
MR-1 regarding scenic impacts and
cumulative development in the southeast
and south Monterey. Further, as detailed on
page 3.1-17, the DEIR analyzes the scenic
entryways, corridors, and scenic vistas as
identified in the 2005 General Plan Urban
Design Element. With implementation of
General Plan policies and existing City
regulations, substantial adverse effects on
scenic vistas and resources in the Planning
Area would be minimized to the extent
practicable and associated impacts would be
less than significant.

B1-14 California
Native Plant
Society
3/25/24 The Garden Road/Airport/Highway 68 Opportunity Area (north and south of Highway 68) contains rare Coastal
Prairie, Vernal Pool, Monterey Pine Forest, wetland, and riparian habitats. Yet the DEIR not only fails to specifically locate and identify these “Sensitive Natural Communities” on DEIR maps but also fails to review, analyze, and mitigate the City’s housing and development plan’s anticipated impacts as required by the California Environmental Quality Act. The DEIR mentions that “both valley needlegrass grassland and coastal prairie occur within the Planning Area” but no analysis or mitigation is given. Analysis and mitigation is also missing for all sensitive natural communities within the 2031 General Plan Update DEIR.

The comment is noted. Please see responses
to comments B1-5 and B1-7 regarding
sensitive habitat. Figure 3.4-1 illustrates all
identifiable habitat types in the Planning Area.

See also Impact 3.4-2 for analysis on
sensitive habitats pursuant to CEQA
guidelines. Impacts would be less than
significant.

B1-15 California
Native Plant
Society
3/25/24 In the truncated biological resources impact analysis, the DEIR states that “a significant impact would occur if the Proposed Plan would have a substantial adverse effect on State or federally protected wetlands, including, but not limited to, marsh, vernal pool, coastal [sic], etc.), through direct removal, filling, hydrological interruption, or other The comment is noted. On page 3.4-35,
impacts on wetland habitat are less than
significant for the following reasons. First,
future development under the Proposed
Plan would take place primarily in previously
developed areas of the city, which limits the
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means.” Yet, despite mentioning the presence of wetlands within the Planning Area, and the fact that development of these wetlands would likely lead to their elimination, Impact

3.4-3 of the DEIR, addressing State or federally protected wetlands, states that project impacts would be “less than significant” and no mitigation measures are required. These are irrefutable and egregious violations of the California Environmental Quality Act and State and federal laws
protecting wetlands.
potential for disruption to undeveloped
wetland habitat in the Planning Area. Future
development under the Proposed Plan
would also be subject to the requirements of
Clean Water Act Section 404 and 401
permitting requirements, which would limit
and/or mitigate impacts from projects that
would discharge pollutants or dredged or fill
materials into waters of the state, including
wetlands. Future development would also be
subject to the CDFW Lake and Streambed
Alteration Program, which would require any
project that could substantially divert or
obstruct the flow of, substantially change or
use any material from, or deposit debris into
a river, stream, or lake to agree to measures
that would protect existing fish or wildlife
resources. Additionally, General Plan Open
Space Element policies a.2, d.1, d,2, d.3, and
e.1 require the protection and preservation
of the marine habitats of Monterey Bay as
well as the lakes, streams, and waterways in
the Planning Area. Further, Conservation
Element Policy b.4 requires the retainment
and restoration of wetlands, riparian areas,
and other habitats, which provide
remediation for degraded water quality.

B1-16 California
Native Plant
Society
3/25/24 One of the many ways in which the DEIR has failed to adequately analyze the General Plan Update’s anticipated impacts to botanical resources is the fact that recent, comprehensive protocol-level floristic surveys for specialstatus plants and sensitive natural communities have not been performed (along with special-status wildlife surveys) in the Coastal Prairie, Monterey Pine Forest, Oak Woodland and wetland habitats that occur in the Tarpey Flats area south of Highway 68. The DEIR’s only means to address the impacts to special-status species is “Mitigation Measure BIO-1: Conduct The comment is noted. Please see responses
to comment B1-3 and B1-6. See also
response to comment B1-2 regarding
mitigation measures for special-status
species. As detailed on page 3.4-25,
implementation of MM-BIO-1 is the
responsibility of the project applicant.

Additionally, the report required in MM-BIO1 shall outline where species and/or habitatspecific mitigation measures (as required ATTACHMENT 1 / EXHIBIT A
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Preconstruction Surveys for Special Status Species.” These last minute assessments would presumably be an individual developer’s responsibility. The responsible parties are not specified in the DEIR nor are the subsequent required
mitigation measures required by State and federal
environmental protections laws should special-status species or sensitive natural communities be identified on a
development site.
under Mitigation Measures BIO-2 through
BIO-12) are required. This report will
provide the basis for any applicable permit
applications and consultations with
regulatory agencies where incidental take
may occur.

B1-17 California
Native Plant
Society
3/25/24 Relying on preconstruction surveys to determine the presence or absence of special-status species that the DEIR has identified as having the potential to occur on the site is entirely inadequate.

Deferring biological studies until after project approval in this manner prevents public comment and oversight over the
protection of these species, and runs afoul of CEQA’s
requirement that the lead agency analyze and disclose a project’s impacts to the public before the project is approved.

The lack of botanical and wildlife surveys also precludes the development of species-specific mitigation measures that have been reviewed and vetted by the responsible agencies and the public prior to the approval of the project, a core requirement of CEQA.

The comment is noted. Given that this is a
programmatic DEIR, no specific
developments are actually being proposed
under the Plan. Any development that will
occur will happen incrementally over an
eight-year period. The DEIR utilizes currently
available information such as the CNDDB to
disclose and evaluate potential impacts at
the programmatic level. Requiring
preconstruction surveys is the best way to
ensure that later-implemented projectspecific avoidance and minimization measures are based on current information,
rather than information that may not be as
reliable several years after the Plan is
adopted. See also responses to comments
B1-3 and B1-6.

B1-18 California
Native Plant
Society
3/25/24 Floristic surveys are the only way to confirm the presence or absence of special-status species within the project area, and are the only way to ensure that the full scope of impacts to special- status plants is being captured in the City’s analysis.

By not performing protocol-level surveys in the face of the evidence that numerous special-status plants have potential to occur on the project site, the City has failed to establish the environmental setting. This is a fundamental flaw in the DEIR for the 2031 General Plan Update. EIRs, programmatic or not, are required to describe the baseline physical
conditions on the project site through which the lead agency The comment is noted. Please see responses
to comments B1-3, B1-6, and B1-17.

Preconstruction surveys for special-status
species will be a requirement for all
developments.

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will determine whether an impact is significant (CEQA
Guidelines, § 15125(a)(1)). The failure to conduct floristic surveys, as well as special-status wildlife surveys, precludes the City from being able to accurately establish the baseline physical conditions, and thereby prevents the EIR from
meeting CEQA’s mandate of making an evidence-based
determination of the project’s impacts to botanical resources and mitigating those impacts if they are significant.

B1-19 California
Native Plant
Society
3/25/24 Protocol-level surveys for evaluating impacts to Sensitive Natural Communities, also required by CEQA, are not even mentioned in the DEIR9. Additionally, the need to obtain mandatory Incidental Take Permits from the U.S. Fish and Wildlife Service and the California Department of Fish and Wildlife for “take” (harm or kill) of listed species is not discussed in the DEIR, nor is the need for a fully developed and approved Habitat Conservation Plan that ensures that the effects of the authorized incidental take are adequately minimized and mitigated for the listed species.

The approval of a U.S. Fish and Wildlife Habitat Conservation Plan requires extensive baseline biological surveys of listed species on the project site to support the conservation strategy, including multi-year floral surveys of listed plant species10. The Habitat Conservation Plan will also mandate expensive compensatory mitigation for impacts to these
species and their habitat as permits require the preparation and implementation of a long-term mitigation and monitoring plan including a take assessment, compensatory mitigation lands, success criteria, and funding assurances along with mitigating impacted sensitive natural community habitat offsite at a minimum 3:1 ratio through preservation,
restoration,11 and/or a conservation bank.12,13
The comment is noted. Please see response
to comments B1-3 and B1-6. Under the
Regulatory Setting section on page 3.4-14,
the DEIR does note that Section 9 of FESA
prohibits the “take” of any wildlife species
listed as endangered and most species listed
as threatened. Any development pursuant to
the Proposed Plan must comply with
associated USFWS regulations. Further, there
are no Habitat Conservation Plans in
Monterey County and the Proposed Plan is
not required to develop a Habitat
Conservation Plan. The Installation-Wide
Multispecies HMP for Former Fort Ord
applies to the Fort Ord/Ryan Ranch
opportunity area. This opportunity area is
within the Development category, where
there are no management restrictions.

Program 1-H in the proposed Housing
Element would involve preparation of a
specific plan to integrate mixed use
development in a portion of the First
Ord/Ryan Ranch opportunity area while also
preserving carefully selected areas of natural
open space and habitat. Page 3.4-39 states
that the Proposed Plan and any subsequent
development that it permits would be
required to be consistent with the HMP,
including its management guidelines and
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specifications. Therefore, no impact related
to conflicts with the provisions of an
adopted habitat conservation plan, natural
community conservation plan would occur.

B1-20 California
Native Plant
Society
3/25/24 This programmatic DEIR is insufficient with the fact that in terms of the program’s impact on special status plants and sensitive natural communities, this DEIR is not
“programmatic,” as it should be, at all. The California Code of Regulations Section 15168 states that a program EIR should “provide a description of planned activities that would implement the program and deals with the effects of the program as specifically and comprehensively as possible. With a good and detailed project description and analysis of the program, many later activities could be found to be within the scope of the project described in the program EIR, and no further environmental
documents would be required.”
The comment is noted. Please see response
to comments B1-3 and B1-6. The DEIR does
satisfy CEQA requirements for analysis of
environmental impacts by including a
complete and comprehensive programmatic
evaluation of the physical impacts of
adopting and implementing the Proposed
Plan.

B1-21 California
Native Plant
Society
3/25/24 Instead of describing in this DEIR the potential or likely effects of the City’s development plans on special-status plants and sensitive natural communities as specifically and comprehensively as possible and requiring the City to
develop a Habitat Conservation Plan for impacts to specialstatus species and Sensitive Natural Communities in order to obtain required Incidental Take Permits from the U.S. Fish and Wildlife Service and the California Department of Fish and Wildlife, this “programmatic” DEIR dodges its responsibility of streamlining affordable housing and presumably directs subsequent individual project developers to obtain their own Incidental Take Permits for development projects instead of tiering from this General Plan Update (again, with no mention of extensive biological studies, habitat conservation plans, compensatory mitigation, funding assurances, monitoring, and the need for “No Surprises” assurances).

The comment is noted. Please see responses
to comments B1-3 and B1-6. The DEIR does
satisfy CEQA requirements for analysis of
environmental impacts by including a
complete and comprehensive programmatic
evaluation of the physical impacts of
adopting and implementing the Proposed
Plan.

B1-22 California
Native Plant
Society
3/25/24 To be serious about streamlining affordable housing, as required by the State of California Housing Element Law, this 2031 General Plan Update Draft EIR must direct the City to The comment is noted. Please see response
to comment B1-19. The DEIR would adhere
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work with the U.S. Fish and Wildlife Service and California Department of Fish and Wildlife to develop a conservation plan and obtain take permits for potentially occurring specialstatus species in a holistic and comprehensive manner. It is very unlikely that the wildlife agencies will allow piecemeal biological studies and permitting on these very sensitive Central Coast Maritime Chaparral, Coastal Prairie, Monterey Pine Forest, vernal pool, wetland and riparian habitats. to all biological resource regulatory
requirements as detailed on page 3.4-13.

B1-23 California
Native Plant
Society
3/25/24 While the 1997 Habitat Management Plan provides a framework for species and habitat conservation on former Fort Ord, it does not meet U.S. Fish and Wildlife Service or California Department of Fish and Wildlife standards or requirements for an application soliciting the issuance of Incidental Take Permits. The more recent Fort Ord MultiSpecies Habitat Conservation Plan, drafted but never adopted, was intended to fulfill those requirements by
combining key components of the Habitat Management Plan with additional elements to ensure compliance with the
Endangered Species Act and the California Endangered
Species Act, thereby serving as a basis for issuance of basewide Incidental Take Permits by the U.S. Fish and Wildlife Service and California Department of Fish and Wildlife.

The comment is noted. Please see response
to comment B1-19.

B1-24 California
Native Plant
Society
3/25/24 Additional constraints to using the former Fort Ord properties to meet the City’s housing goals are numerous and generally beyond the scope of CNPS expertise and
analysis, however we feel compelled to address the issues of Unexploded Ordnance (UXO), toxic soils, and environmental justice. Unexploded Ordnances, including bombs, artillery, mortar, rocket and small arm ammunitions, mines, demolition charges, pyrotechnics, grenades, high explosives, and
propellants, are still potentially on the project site within the Ryan Ranch/Fort Ord Opportunity Area. This site is also seriously constrained by a “State Covenant to Restrict Use of Property with the Army” that the City is currently bound by.

It is likely that the Fort Ord lands were never sufficiently cleared of UXO and hazardous materials to allow housing The comment is noted. Please see response
to comment A2-3
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development.

A major constraint to any housing development, the existing covenant prevents the following types of use for the former Fort Ord properties: residential use, day care facilities that do not have measures to prevent contact with soil, schools for persons under 21 years of age, and hospitals (other than veterinary hospitals). To allow housing development, the covenant needs to be lifted by the California Department of Toxic Substances Control (DTSC). The DEIR fails to mention any correspondence with the DTSC in preparing the
document and whether they may be willing to lift the
covenant, what environmental studies might still be needed to do so, what type of cleanup is needed, and what kind of timeline any or all of this may take.

A comment letter from DTSC to the City concerning the
2031 General Plan Update DEIR, dated March 20, 2024
(Clearinghouse #2023080034), states that “[D]ue to the
broad scope of the Project, DTSC is unable to determine the locations of the proposed sites, whether they are listed as having documented contamination, land use restrictions, or whether there is the potential for the sites to be included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. Therefore, DTSC
recommends providing further information on the proposed project and areas that may fall under DTSC's oversight within future environmental documents.” The letter concludes
“DTSC believes the City of Monterey must address these
comments to determine if any significant impacts under the California Environmental Quality Act (CEQA) will occur and, if necessary, avoid significant impacts under CEQA.”
The very real possibility that DTSC and the binding covenant will ultimately not allow housing development is reason enough to remove the former Fort Ord lands along Upper
Ragsdale Road and South Boundary Road from their list of housing opportunity sites in the General Plan Update. A UXO and hazardous materials cleanup by DTSC to a level
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sufficient for future families to live in health and safety may actually be an impossibility.

B1-25 California
Native Plant
Society
3/25/24 California State Senate Bill 100014 – Environmental Justice in Local Land Use Planning – requires local governments to identify environmental justice communities (called
"disadvantaged communities") in their jurisdictions and address environmental justice in their general plans and housing elements. The State’s Attorney General is working to ensure local governments comply with Senate Bill 100015.

The DEIR does not even mention environmental justice or address the very real environmental justice issue of planning housing for very low income households on lands that
potentially have UXO and hazardous materials not sufficiently cleaned up on them. The potential environmental injustice that this program represents needs to be fully analyzed and resolved. The undetermined and unspecified time needed to resolve these constraints within the Housing Element’s eight year planning period are not discussed in the DEIR and run afoul of State Housing Element Law.

Former military bases are some of the most polluted and toxic sites in the country. The entire former Fort Ord is still on the Superfund list, a “list of sites of national priority among the known releases of hazardous substances, pollutants, or contaminants throughout the United States.”17 It is fairly well known that hazardous and toxic waste materials at the
former Fort Ord consist of a wide variety of materials
including industrial chemicals, petrochemicals, domestic and industrial wastes (landfills), asbestos and lead paint in buildings, above- and underground storage units, and
ordnance and explosives.

Planning to build affordable housing for the poorest families in the community on land where housing is still prohibited due to insufficient clearing of UXO and hazardous wastes would be a newsworthy example of environmental injustice in the State’s Housing Element program. It appears unknown to anyone if or when the DTSC will ever be able to clean up the The comment is noted. Environmental
justice is a not a topic required for analysis
within Appendix G of the CEQA State &
Guidelines Handbook. Additionally, there are
no designated “disadvantaged communities”
within the City pursuant to SB535; therefore,
the City of Monterey is not required to
prepare an Environmental Justice Element.

Nevertheless, the Housing Element included
an 86-page Appendix D that analyzes
conditions for disadvantaged groups and
Chapter 4 Housing Action Plan incorporates
numerous programs that seek to improve
environmental, economic, and educational
opportunities for disadvantaged and
marginalized residents. Please see also
response to comment A2-2. The
environmental impacts typically highlighted
by environmental justice concerns, such as
air pollution and hazardous materials, are
already analyzed and disclosed in the DEIR.

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former Fort Ord lands to a level where children can safely play ball in their yards or neighborhood parks.

B1-26 California
Native Plant
Society
3/25/24 The Monterey Bay Chapter of the California Native Plant Society respectfully urges the City to comprehensively revise the 2031 General Plan Update and Draft Environmental
Impact Report to adequately identify, review, analyze, and mitigate the project’s anticipated impacts on State and federally protected plant and wildlife species and the rare habitats they depend upon, as an essential requirement of the California Environmental Quality Act.

A close examination of this DEIR points to the conclusion that the City cannot use the Ryan Ranch/Fort Ord and
Garden Road/Airport/Highway 68 Opportunity Areas as
housing opportunity sites to meet its RHNA requirements, principally because of the large number of environmental constraints (many of which may potentially be irresolvable) that prohibit the streamlining of affordable housing
development.

The summary comment is noted.The
foregoing responses demonstrate that the
EIR already comprehensively addresses the
commenter’s concerns about biological
resources, hazardous materials, and others,
at a level of detail that is appropriate for a
program-level analysis. The commenter’s
information does not support the need for
any substantive revisions in the Draft EIR.

B1-27 California
Native Plant
Society
3/25/24 The California Department of Housing and Community Development states the “For each policy, procedure, or
requirement identified as a constraint, the housing element must include programs to address and remove or mitigate the constraint.” However, the Housing Element Update and DEIR do not even clearly identify many of these constraints and offer no sufficient measures or realistic timelines to remove or mitigate the constraints.

The comment is noted. The DEIR does
identify potentially significant environmental
impacts and presents mitigation measures to
reduce impacts to a less-than-significant
level. Otherwise, significant and unavoidable
environmental impacts are disclosed in the
DEIR. Please see Table ES-2 for a summary of
impacts and mitigation measures.

B1-28 California
Native Plant
Society
3/25/24 With so many environmental constraints to development, many potentially irresolvable, the Ryan Ranch/Fort Ord and Garden Road/Airport/Highway 68 Opportunity Areas should be removed from the 2031 General Plan Update as
opportunity sites for future development. We request that the City conduct the appropriate studies to determine if the public would be best served by conserving these sensitive natural communities for current and future generations to appreciate and treasure.

Thank you for the opportunity to comment on the Monterey The comment is noted. The comment
pertains to the Proposed Plan and is not
related to the adequacy of the DEIR; thus, no
further response is required.

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2031 General Plan Update and Draft Environmental Impact Report. We would welcome any opportunity to meet with
the Planning Commission and further discuss the issues we have raised on the inadequacies of the Draft Environmental Impact Report’s analysis of potential impacts of the plan on biological resources.

B2-1 LandWatch 3/21/24 LandWatch Monterey County supports a housing element that provides dense, infill housing in existing urbanized areas affordable to those who live and work in the City of
Monterey. Environmental justice demands affordable housing that minimizes environmental harms. Accordingly, LandWatch urges the City to adopt the Relocated Housing Alternative. which would provide denser infill housing sufficient to meet the City's 6th Cycle Regional Housing Needs Allocation
(RHNA) while avoiding significant environmental impacts to the City's natural lands in the former Fort Ord. While we appreciate inclusion of the Relocated Housing Alternative in the draft EIR (DEIR), the DEIR is inadequate under CEQA. It fails to disclose the scope of the water supply and biological resource impacts that the proposed project would cause in the former Fort Ord. Moreover, the DEIR presents an
inadequate analysis of the Relocated Housing Alternative. It erroneously fails to find this alternative environmentally superior despite the ElR's own detailed comparisons of its impacts. It also erroneously concludes that it would provide insufficient lower income housing.

Our detailed comments are attached. LandWatch staff and consultants would be delighted to meet with you to review our comments and analysis.

The introductory comment is noted. Please
see responses to comments B2-2, B2-3, and
B2-4 as well as Master Response MR-2.

B2-2 LandWatch 3/21/24 LandWatch Monterey County supports a housing element that provides dense, infill housing in existing urbanized areas affordable to those who live and work in the City of
Monterey. Environmental justice demands affordable housing that minimizes environmental harms.Accordingly, LandWatch urges the City to adopt the Relocated Housing Alternative, which would provide denser infill housing sufficient to meet The comment is noted.As discussed on page
4-22 of the Draft EIR, the Relocated Housing
Growth Alternative has a nominally reduced
number of significant impacts compared to
the Proposed Plan; however, it would have a
worse impact on an already significant and
unavoidable impact related to water supply
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the City’s 6th Cycle Regional Housing Needs Allocation
(RHNA) while avoiding significant environmental impacts to the City’s natural lands in the former Fort Ord.
and it would not permit the City to meet its
RHNA obligations under State law because
it would not demonstrate adequate capacity
for Moderate Income housing and because it
would assume development of housing to
meet the needs of Low and Very Low
Income households on sites that do not
meet the criteria established in State law for
Low and Very Low Income RHNA units.

B2-3 LandWatch 3/21/24 While we appreciate inclusion of the Relocated Housing Alternative in the draft EIR (DEIR), the DEIR is inadequate under CEQA. It fails to disclose the scope of the water supply and biological resource impacts that the proposed project would cause in the former Fort Ord.

Please see Master Response MR-2 regarding
water supply and responses to comments
BI-6 regarding impacts to biological
resources at Fort Ord that could result from
implementation of the Proposed Plan. The
Draft EIR appropriately concludes that
impacts related to adequate water supply
would remain significant and unavoidable
even after implementation of all feasible
mitigation and appropriately concludes that
impacts related to biological resources
would be less than significant with mitigation
incorporated.

B2-4 LandWatch 3/21/24 Moreover, the DEIR presents an inadequate analysis of the Relocated Housing Alternative. It erroneously fails to find this alternative environmentally superior despite the EIR’s own detailed comparisons of its impacts. It also erroneously concludes that it would provide insufficient lower income housing.

The comment does not provide any
substantiation for the claim that the analysis
of the Relocated Housing Alternative is
inadequate. Further, the comment
incorrectly states that the DEIR concludes
that the Relocated Housing Alternative
would provide insufficient lower income
housing. In fact, on page 4-22, the DEIR
states that the Relocated Housing
Alternative would “not meet the City’s
RHNA obligations.” Specifically, as noted in
response to comment B2-11, the Relocated
Housing Growth Alternative, which is based
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on a parcel-based set of projections
prepared by LandWatch (see FEIR Appendix
2), does not demonstrate adequate capacity
to meet Moderate Income RHNA and it
assumes development of housing to meet
the needs of low and very low income
households that do not meet the criteria
established in State law, including that parcels
be at least 0.5 acres in size and free from
environmental constraints. Further, the
LandWatch parcel-based projections assume
development at densities that exceed past
performance in Monterey and surrounding
jurisdictions, which conflicts with State
guidance described in the Housing Element
Site Inventory Guidebook produced by
HCD.

The DEIR found that the Relocated Housing
Growth Alternative would result in 11
significant and unavoidable impacts, 9 less
than significant impacts with mitigation, and
46 less than significant impacts (a clerical
error in the DEIR was caught during review
for the FEIR and corrected in the errata).

For the Increased Workforce Housing
Alternative, 10 impacts were significant and
unavoidable, 10 impacts were less than
significant with mitigation, and 46 impacts
were less than significant (a clerical error in
the DEIR was caught during review for the
FEIR and corrected in the errata). Given that
the Increased Workforce Housing
Alternative avoids the Proposed Plan’s
significant and unavoidable impact pertaining
to agricultural resources and reduces the
severity of significant and unavoidable
impacts related to air quality, the City
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appropriately exercised its discretion to
conclude based on these factors that the
Increased Workforce Housing Alternative is
the environmentally superior alternative.

B2-5 LandWatch 3/21/24 The DEIR’s water supply analysis does not meet CEQA’s legal requirement to provide an accounting of supply and demand.

The mandatory SB 610 Water Supply Analysis simply omits the demand from the Marina Coast Water District (MCWD)
service area in Fort Ord. The DEIR’s reliance on MCWD’s 2020 Urban Water Management Plan (UWMP) instead cannot
cure this error because it does not constitute a valid Water Supply Analysis and because the now dated 2020 UWMP
admittedly fails to include the proposed new demand for residential water supplies from the City. The 2020 UWMP also omits new demand from other jurisdictions in the
former Fort Ord. Because the DEIR does not provide an
accurate accounting of the Fort Ord demand and supply for this project or other cumulative projects, it does not and cannot disclose the magnitude of the water supply shortfall.

Please see Master Response MR-2 regarding
water supply. For the analysis of adequate
water supply within the California American
Water Company (Cal-Am) service area that
includes the majority of the City of
Monterey except for the former Fort Ord
site, the DEIR appropriately relies on a
Water Supply Assessment (WSA) prepared
for the Proposed Plan by Cal-Am. The WSA
establishes that available water supply would
not be sufficient to serve total projected
demand in 2025, but that with future supply
from the Pure Water Monterey Expansion
Project and the Monterey Peninsula Water
Supply Project Ocean Desalination Plant
become available by 2030, total available
supply would exceed demand in 2031.

For the analysis of adequate water supply
within the Marina Coast Water District
(MCWD) service area that includes the
portion of the former Fort Ord site located
within the City of Monterey, the DEIR relies
on the MCWD 2020 Urban Water
Management Plan (UWMP). On page 3.14-
28, the DEIR acknowledges that 2020
UWMP does not fully account for the
RHNA allocations of the other communities
served by MCWD; however, as discussed on
pages 3.14-7 and 3.14-8 of the DEIR, the
MCWD 2020 UWMP identifies actions to
increase future supply, including reactivation
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of the MCWD pilot seawater desalination
plant and participation in Phase 2 of the Pure
Water Monterey Expansion Project, which
would deliver sufficient additional water
supply to meet projected demand within the
MCWD service area in 2031. By way of a
letter to the City of Monterey dated March
8, 2024 and included in FEIR Appendix 1,
MCWD confirmed this conclusion.

Therefore, the DEIR accurately disclosed
available sources of supply from Cal-Am and
MCWD and analyzed the adequacy of water
supply to serve development pursuant to the
Proposed Plan, based on current information
from the water suppliers.

B2-6 LandWatch 3/21/24 The DEIR’s water supply analysis for Fort Ord also fails to acknowledge and assess two critical constraints on the City’s access to water for Fort Ord. First, the DEIR fails to disclose that, under its settlement agreement with LandWatch and Keep Fort Ord Wild, MCWD cannot provide new residential hookups for Fort Ord housing development because it is
bound by a 6,160-unit cap on new residential hookups, a limitation that has already been reached. Second, the DEIR fails to disclose that the City’s entitlement to MCWD
groundwater is limited to 65 AFY, an amount that is woefully inadequate to supply the 1,660 houses the proposed project would locate in Fort Ord.

The assertion that the “DEIR fails to disclose
that the City’s entitlement to MCWD
groundwater is limited to 65 AFY, an amount
that is woefully inadequate to supply the
1,660 houses the proposed project would
locate in Fort Ord” is inaccurate. On page

3.14-7, the DEIR states "With the closure of
Ford Ord, an allotment of 65 AFY of water
was conveyed to the City of Monterey."
Additionally, Table 3.14-5 in the DEIR shows
an allocation of 65 AFY of water to the City
of Monterey as planned in the MCWD 2020
UWMP. As discussed on pages 3.14-7 and

3.14-8 of the DEIR, the MCWD 2020
UWMP identifies actions to increase future
supply which would deliver sufficient
additional water supply to meet projected
demand within the MCWD service area in
2031. However, as noted on page 3.14-28 of
the DEIR, while these additional sources of
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supply could deliver sufficient water to meet
projected demand from the Proposed Plan,
MCWD does not currently have a plan or
funding in place to reactivate the pilot
seawater desalination plant or procure
additional supply from Phase 2 of the Pure
Water Monterey Expansion Project. No
other feasible sources of additional water
supply have been identified. Therefore, the
DEIR appropriately concluded that impacts
related to adequate water supply to serve
future development within the MCWD
service area would be significant and
unavoidable even after implementation of all
feasible mitigation.

With respect to the referenced settlement
agreement between MCWD and LandWatch
and Keep Fort Ord Wild, the City of
Monterey is not a party to nor is it bound by
said agreement.

B2-7 LandWatch 3/21/24 The DEIR proposes illusory water supply mitigation in the form of an unenforceable directive to MCWD, an
independent agency, that MCWD provide more water by
resuming production from its mothballed desalination facility and by undertaking a new water supply project.

The DEIR also inconsistently concludes that there will be no impacts from new water supply facilities, even though the Mitigation Measure UTIL-2 purports to demand that MCWD
provide a new facility.

Please see Master Response MR-2 regarding
water supply and responses to comments
B2-5 and B2-6 above. By way of a letter to
the City of Monterey dated March 8, 2024,
and included in FEIR Appendix 1, MCWD
confirmed that the actions to increase future
supply discussed on pages 3.14-7 and 3.14-8
of the DEIR are feasible.

The assertion that the DEIR is inconsistent
in its conclusions regarding new water
supply facilities is incorrect. On page 3.14-29,
the DEIR identifies the construction of new
regional water facilities that Cal-Am and
MCWD have planned for in order to
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increase water supply to serve future needs
in their respective service areas and
appropriately concludes that associated
impacts would be less than significant
because implementation of the Proposed
Plan would not require new construction or
expansion of existing regional water facilities
over and above existing and planned
facilities.

B2-8 LandWatch 3/21/24 The EIR admits that MCWD has no funding or plan to provide additional water supplies to Fort Ord and that no other feasible water supply source has been identified. In light of this admission, the City cannot legally include the Fort Ord housing units in its Housing Element. The Housing Element Law requires that an adequate water supply for proposed units must “be included in an existing general plan program or other mandatory program or plan, including a program or plan of a public or private entity providing water or sewer service.” (Gov. Code, § 65583.2(b)(5)(B).) This requirement is not met.

This comment pertains to the content of the
Proposed Plan and not to the adequacy of
the environmental analysis. No further
response is required.

However, the City notes that this assertion
is incorrect. As discussed on pages 3.14-7
and 3.14-8 of the DEIR, the MCWD 2020
UWMP identifies actions to increase future
supply which would deliver sufficient
additional water supply to meet projected
demand within the MCWD service area in
2031.The 2020 UWMP is a State-mandated
plan prepared by MCWD. Therefore, the
requirement of Gov. Code, §
65583.2(b)(5)(B) is met. Please see also
Master Response MR-2 regarding water
supply and responses to comments B2-5, B2-
6, and B2-7 above.

B2-9 LandWatch 3/21/24 The DEIR’s discussion of biological resource impacts is inadequate because it lacks essential environmental setting information as to the locations and extent of sensitive species and fails to acknowledge the presence of sensitive natural communities in the majority of the lands proposed for
development. It also fails to disclose the extent of wetlands and the additional constraints on development imposed by federal protection of upland areas used by the California Tiger Salamander. It also relies on outdated and incomplete Figure 3.4-1 in the DEIR shows habitat types
within the Planning Area, including wetlands,
based on data from a Biological Assessment,
prepared for the 2004 General Plan Update.

Further, on page 3.4-11 the DEIR describes
estuary systems that support (or have the
potential to support) seasonal wetlands and
notes that, while not currently shown in
available data, additional wetlands may be
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data sources that fail to disclose that the City’s Fort Ord land is a major wildlife corridor. Without this setting information, the EIR cannot and did not assess the significance of impacts or the feasibility of avoidance and minimization measures that would be required for development, including the likelihood that impacts would remain unavoidably significant because mitigation is simply infeasible.
identified in future site-specific studies.

Tables 3.4-1 and 3.4-2 in the DEIR list special
status plan and wildlife species and Figure

3.4-2 shows occurrences of special-status
species in the vicinity of the Planning Area
from the California Department of Fish and
Wildlife's California Natural Diversity
Database (CNDDB). The DEIR also
incorporates mapping and information on
California Essential Habitat Connectivity
(CEHC) areas as designated by CDFW
within and surrounding the Planning Area
obtained from CDFW’s Biogeographic
Information and Observations System
Habitat Connectivity Viewer in December
2023. Therefore, the DEIR appropriately
documented the environmental setting
within the Planning Area based on the latest
available data from State agencies. The
commenter does not identify alternate,
more accurate sources of information or
substantiate the assertion that the DEIR
"lacks essential environmental setting
information." Please see also response to
comment B1-4 above.

B2-10 LandWatch 3/21/24 The DEIR assesses two substantive alternatives to the proposed project. The Increased Workforce Housing
Alternative would increase housing units but forgo
development of 50 acres of grazing land. The Relocated
Housing Alternative would forgo Fort Ord development and increase the density of development in already-urbanized areas to replace this housing. The DEIR’s comparison of these two alternatives is flawed. Its conclusion that the Increased Workforce Housing Alternative is environmentally superior is directly contradicted by its detailed comparisons of the proposed project and the alternatives. The Relocated Housing Alternative reduces more significant impacts than the
The DEIR analyzes three alternatives to the
Proposed Plan. As discussed on pages 4-21
and 4-22 of the DEIR, the No Project
Alternative reduces the greatest number of
environmental impacts; however, as the
CEQA Guidelines require another
environmentally superior alternative other
than the No Project Alternative to be
identified, the DEIR identifies the Increased
Workforce Housing Alternative as the
environmentally superior alternative because
it avoids the Proposed Plan’s significant and
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Increased Workforce Housing Alternative (seven rather than five), and it causes no increase in the severity of other significant impacts, whereas the Increased Workforce Housing Alternative aggravates four other significant impacts. Clearly, the Relocated Housing Alternative is environmentally
superior.
unavoidable impact pertaining to agricultural
resources and reduces the severity of
significant and unavoidable impacts related
to air quality. Please see also responses to
comments B2-2, B2-3, and B2-4.

B2-11 LandWatch 3/21/24 Finally, the EIR’s conclusion that the Relocated Housing Alternative would not provide sufficient lower income units to meet the City’s RHNA obligation is unsupported and
incorrect. The Relocated Housing Alternative is supposed to increase densities in five already urbanized areas in order to relocate the Fort Ord units. But the EIR unaccountably
assumes that the Fort Ord units would not be relocated
despite the increased density. In fact, the increased densities of the areas already identified for lower income units in these five urbanized areas under the proposed project would
provide 388 more lower income units, more than making up for the 220 lower income units proposed for Fort Ord.

The DEIR analyzed a Relocated Housing
Growth Alternative projected to result in
approximately 8,115 new residents, 4,183
housing units, and 1,991 new jobs in
Monterey by 2031. Projected housing growth
for this alternative was based on a parcelbased set of projections prepared by LandWatch (see FEIR Appendix 2). The
LandWatch parcel-based projections do not
demonstrate adequate capacity to meet
Moderate Income RHNA and they assume
development of housing to meet the needs
of low and very low income households that
do not meet the criteria established in State
law, including that they be zoned to
accommodate housing, and have appropriate
development standards as needed to
facilitate the development of a variety of
housing products suitable for all income
levels. Further, the LandWatch parcel-based
projections assume that individual parcels
will be built to the maximum density
permitted under City zoning regulations and
as such do not represent a realistic
projection of capacity based on past
performance as required under Government
Code Section 65583.2(c). Therefore, the
conclusion on page 4-22 of the DEIR that
the Relocated Housing Growth Alternative
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would not meet the City’s RHNA
obligations is valid and correct.

B2-12 LandWatch 3/21/24 Indeed, it is the proposed project that would not provide sufficient lower income units, because the EIR admits that only 240 market rate units could be developed during the 6th Cycle, which would provide only 24 lower income units
under the proposed inclusionary housing ordinance. Unlike the Relocated Housing Alternative, the proposed project would therefore fall short of the RHNA goal for lower
income units.

This statement is incorrect and inaccurate.

The DEIR assumes 10,125 new residents,
5,800 new housing units, and 1,995 new jobs
at buildout in 2031, including up to 1,660
new homes in the Ryan Ranch and Fort Ord
area, 220 of which would be made available
to low-income households, 220 of which
would be made available to moderateincome households.

B2-13 LandWatch 3/21/24 Our detailed comments follow. LandWatch staff and consultants would be delighted to meet with you to review our comments and analysis.

A. Fort Ord lacks sufficient water supplies for the proposed housing, and the DEIR’s water supply analysis is inadequate.

The project description includes capacity for 5,787 residential units, of which 1,660 would be in the Fort Ord/Ryan Ranch area. (DEIR, pp. 2-10, 2-15.) Buildout of these 5,787 units is assumed by the horizon year 2031. (DEIR, p. ES-4, 2-21, 2-25.) Water supply for the Fort Ord area would be provided by Marina Coast Water District (MCWD) and for the rest of
the project by Cal-Am. (DEIR, pp. 3.14-1, 3.14-6.)
Even though Fort Ord and Ryan Ranch would have different water suppliers, the EIR and the Site Inventory treat the Fort Ord/Ryan Ranch area as a unit. (DEIR, p. 2-15, GPU, Appendix A, Sites Inventory [listing 1,660 units for six parcels identified as within “Ryan Ranch/Fort Ord”].) However, it appears that the bulk of the combined Ryan Ranch/Fort Ord housing site – three City owned parcels totaling 93.69 acres - is in fact in Fort Ord. It appears that the other three privately owned parcels totaling 3.3 acres may be in Ryan Ranch. If the Fort Ord housing units on 93.69 acres were at the same density as the Ryan Ranch units on 3.3 acres, then 94% of the units – or 1,555 units – would be on Fort Ord land and be serviced by MCWD.

The assertion that MCWD has insufficient
water supply to serve projected
development at Fort Ord under the
Proposed Plan is inaccurate. Please see
Master Response MR-2 regarding water
supply and responses to comments B2-5, B2-
6, and B2-7 above.

Further, the City notes that the Proposed
Plan (specifically Program 1-H in the
Housing Element) calls for the preparation
of a specific plan "to establish a clear vision
for the area and to guide future
development and conservation, identify
infrastructure needs and financing
mechanisms, and establish measures to
ensure sustainable development and
adequate resource protection." The
Proposed Plan states that the Specific Plan
should prioritize housing and mixed-use
development on any combination of the
parcels shown on Map 3-10 Sites Available
for Housing, which includes parcels at Fort
Ord and in the Ryan Ranch opportunity area;
however, it does not require residential
development on any specific parcel or on all
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Preliminarily, we note that the EIR’s failure to disaggregate unit counts by water supplier renders the project description inadequate to support necessary analysis. Furthermore, the site inventory’s identification of at most 96.99 acres of housing site land in the combined Ryan Ranch/Fort Ord area is inconsistent with the description in the EIR of Fort Ord as containing “approximately 127 acres of vacant land . . . potentially available for development with housing and other uses.” (DEIR, p. 2-14.)
parcels identified. The locations for housing
would be determined with community input
during the course of the specific plan
process. As discussed in Master Response
MR-2 regarding water supply and responses
to comments B2-5, B2-6, and B2-7 above, a
WSA prepared by Cal-Am determined that
there would be sufficient supply to meet
projected demand within its service area -
including on any parcels at Ryan Ranch - in
2031, and by way of a letter, dated March 8,
2024, to the City of Monterey included in
FEIR Appendix 1 MCWD has confirmed it is
pursuing the actions identified in the DEIR
to increase supply to meet projected need in
2031 and will plan to provide 530 AFY, which
is more than sufficient to serve the
development envisioned for Fort Ord in the
Proposed Plan.

B2-14 LandWatch 3/21/24 CAL-AM SERVICE AREA: Based on a Water Supply Assessment from Cal-Am, the EIR concludes that the water supply impact in the Cal-Am service area would be significant and unavoidable because, Cal-Am claims that without its proposed desalination project demand would exceed supply in some years. (DEIR, pp. 3.14-24 to 3.14-27.) The EIR does not disclose that Cal-Am’s supply and demand analysis is contested by the Monterey Peninsula Water Management
District, MCWD, and Monterey One Water and that the
California Public Utilities District is in the midst of proceedings in which these public agencies are challenging Cal-Am’s supply and demand analysis.

This statement is incorrect. On page 3.14-23,
the DEIR explains that in August 2023, the
City requested a WSA from the MPWMD to
evaluate whether total projected water
supplies available during normal, single-dry
and multiple-dry water years would be
sufficient to serve projected demand from
the Proposed Plan, including up to 5,800 new
housing units and 1,995 new jobs by 2031. In
response, MPWMD sent a letter to the City
in January 2024 asserting that a future
Supply versus Demand analysis based on the
AMBAG 2022 Regional Growth Forecast
demonstrates existing and planned sources
of supply would be sufficient to meet the
region’s demand needs for over 30 years.

However, the AMBAG 2022 Regional
Growth Forecast does not fully account for
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the City's 2023-31 RHNA allocation and is
not based on employment projections that
accurately reflect the number of existing
jobs in the City of Monterey in 2023. As
such, the letter from MPWMD does not
provide sufficient basis for assessing whether
projected supply would be sufficient to meet
the projected water demand associated with
the Proposed Plan, in combination with the
existing and planned future uses. The January
2024 MPWMD letter is also included in
Appendix 1 to the DEIR.

B2-15 LandWatch 3/21/24 MCWD SERVICE AREA: Based on the 2020 MCWD Urban Water Management Plan, the EIR concludes that the
water supply impact in the MCWD service area, i.e., Fort Ord, would be significant and unavoidable because
MCWD “does not currently have a plan or funding in
place” to provide sufficient water supplies. (DEIR, p. 3.14-

28.)

1. Inclusion of Fort Ord sites in the Site Inventory violates the Housing Element Law because there is no existing or mandatory plan or program for providing water.

The Housing Element Law requires that an adequate
water supply must “be included in an existing general
plan program or other mandatory program or plan,
including a program or plan of a public or private entity providing water or sewer service. ” (Gov. Code, §
65583.2(b)(5)(B).) Whereas Cal-Am does have a program
or plan to supply water, albeit in unnecessary quantities, the EIR admits that MCWD does not. In particular, the
EIR states that “MCWD does not currently have a plan
or funding in place to reactivate the pilot seawater
desalination plant or procure additional supply from
Phase 2 of the Pure Water Monterey Expansion Project.

No other feasible sources of additional water supply
have been identified. Therefore, this impact is considered The assertion that “Inclusion of Fort Ord
sites in the Site Inventory violates the
Housing Element Law” is incorrect. Please
see response to comment B2-8 above.

With respect to MCWD water supply
planning, please see Master Response MR-2
regarding water supply and responses to
comments B2-5, B2-6, and B2-7 above. By
way of a letter to the City of Monterey
included in FEIR Appendix 1 MCWD has
confirmed it is pursuing the actions
identified in the DEIR to increase supply to
meet projected need in 2031 and will plan to
provide 530 AFY, which is more than
sufficient to serve the development
envisioned for Fort Ord in the Proposed
Plan.

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significant and unavoidable.” (DEIR, pp. 3.14-28 to 3.14-

29.)
Furthermore, as discussed below, MCWD has never
planned to supply more than 65 AFY to Monterey. Also,
as discussed below, MCWD is barred from providing
more than 6,160 hookups for new residential units and
MCWD has already committed to those hookups.

B2-16 LandWatch 3/21/24 2. The Water Supply Assessment is inadequate under SB 610 and CEQA.
a. Legal requirements under CEQA and SB 610 for
supply and demand accounting
An agency proposing a development of more than 500
residential units must prepare or have prepared a Water Supply Assessment (WSA). (Water Code, § 10912(a)(1).)
The WSA must disclose “whether the total projected
water supplies, determined to be available by the city or county for the project during normal, single dry, and
multiple dry water years during a 20-year projection,
will meet the projected water demand associated with
the proposed project, in addition to existing and planned future uses, including agricultural and manufacturing
uses.” (Water Code, § 10910(c)(3), (4).) CEQA case law
also requires that an agency disclose the sufficiency of available supply to meet demand from a project, existing users, and foreseeable future users. The California
Supreme Court has held that a “discussion of total
supply and demand is necessary to evaluate ‘the longterm cumulative impact of development on water supply.’” (Vineyard Area Citizens for Responsible
Growth, Inc. v. City of Rancho Cordova (2007) 40
Cal.4th 412, 441.) Vineyard holds that it is not sufficient to cite demand and supply data in related planning
documents without reconciling their inconsistencies
with the EIR’s assumptions and presenting a clear
picture of the sufficiency or insufficiency of the water supply to meet the demand identified in the EIR for the The comment asserts that the WSA
prepared by Cal-Am for the Proposed Plan
is inadequate and discusses the findings of
the Vineyard Area Citizens for Responsible
Growth, Inc. v. City of Rancho Cordova
(2007) case; however, the comment does not
explain how the findings of this case relate
to the content of the WSA prepared by CalAm or substantiate its assertion of inadequacy.

Please see Master Response MR-2 regarding
water supply and responses to comments
B2-5, B2-6, B2-7, B2-14, and B2-15 above.

The DEIR provided an appropriate analysis
of water supply and demand in 2031 as
required under CEQA, and supported by the
WSA and UWMP prepared by Cal-Am and
MCWD covering their respective service
areas. The DEIR’s analysis complies with the
holding of the Vineyard opinion by
thoroughly documenting currently available
water supplies and the water agencies’ plans
for future supplies, and reaches a
conservative conclusion about the potential
significance of the impacts associated with
water supply, based on the uncertainties
disclosed by the WSA, UWMP, and other
supporting evidence regarding the
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project. While an EIR may ultimately conclude that the
water supply is uncertain, it must provide a consistent and coherent account of project demand and how that
demand is reflected in the related planning documents
on which it relies. The Vineyard EIR failed to meet the obligation to show at least a rough balance between
water supply and demand because it failed to explain
and reconcile the differing water demand assumptions in a related planning document on which it relied, the
Water Forum FEIR, and the demand assumptions in the
project EIR itself. (Vineyard at 439.) Such “factual
inconsistencies and lack of clarity” preclude substantial evidence to support conclusions about water supply and
demand. (Id.) It is not sufficient for informed decision making to present “seemingly inconsistent figures for
future total area demand and surface water supply, with no plainly stated, coherent analysis of how the supply is to meet the demand.” (Id. at 445; see also 447 [failure to show how inconsistent supply and demand figures
“match up” “results in a lack of substantial evidence”].) development of future supplies. The DEIR
also acknowledges that there are no other
potentially feasible water supply alternatives.

The Vineyard decision, consistent with
CEQA’s overarching principles encouraging
public disclosure, requires good faith,
thorough analysis of any discrepancies
between future demands and available
supplies, which the DEIR provides.

B2-17 LandWatch 3/21/24 Where there is an adverse impact due to a shortfall in water supplies, it is not sufficient simply to label this impact significant and unavoidable; the EIR must contain “some information about how adverse the adverse impact will be.” (Santiago County Water District v. County of Orange (1981) 118 Cal.App.3d 818, 831.)
In sum, SB 610, Vineyard, and Santiago hold that an accurate accounting of projected supply, demand, and any resulting shortfall is mandatory.

Please see Master Response MR-2 regarding
water supply and responses to comments
B2-5, B2-6, B2-7, B2-14, and B2-15 above.

The DEIR relies on a WSA prepared by CalAm for the Proposed Plan and information in the MCWD 2020 UWMP, the accuracy of
which MCWD confirmed in a letter to the
City of Monterey included in FEIR Appendix

1. The WSA and UWMP provide an
accounting of water supply and demand in
normal, single dry, and multiple dry year
scenarios and identify contingency plans in
the event of shortages, which information is
referenced and discussed in the DEIR.

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Further, the City notes that both Cal-Am
and MCWD have identified additional
sources of water supply to serve total
projected need within their service areas in
2031. However, the DEIR appropriately
concluded that impacts with respect to
water supply would remain significant and
unavoidable even after implementation of all
feasible mitigation because it cannot be said
with certainty that the sources identified by
the water providers will be available in 2031.

B2-18 LandWatch 3/21/24 Finally, SB 610 permits an agency preparing a WSA to rely on the supply and demand data in an Urban Water Management Plan, but only “if the projected water demand associated with the proposed project was accounted for in the most recently adopted urban water management plan.” (Water Code, §
10910(c)(3), (4).)
The comment is noted.

B2-19 LandWatch 3/21/24 The WSA provided as Appendix I to the EIR fails to include the water supply and demand for the MCWD service area.

This WSA is the only WSA provided for the project, but it omits the MCWD demand for the 1,660 Fort Ord units, or, as we proposed to disaggregate the Fort Ord units from the Ryan Ranch units above based on relative acreage, at least 1,555 units. Thus, the WSA fails on its face to provide the total projected water supplies and demand for the project, and it fails to address or answer the question whether there will be sufficient supplies for the entire project over average, single dry, and multiple dry years.

The City notes that State law does not
require Cal-Am to consider supply and
demand outside its service area and that to
do so would be inappropriate. Please see
Master Response MR-2 regarding water
supply and responses to comments B2-5, B2-
6, B2-7, B2-14, and B2-15 above with respect
to the adequacy of the analysis of MCWD
supply and demand in the DEIR.

B2-20 LandWatch 3/21/24 If a water supplier does not provide a WSA, then the CEQA lead agency must provide the analysis itself. (Water Code, § 10910(b).) The DEIR does not purport to provide a WSA for the MCWD service area. Instead, its discussion relies on the 2020 MCWD UWMP. (DEIR, pp. 3.14-6 to 3.14-8, 3.14-26 to

3.14-29.) Not only is the UWMP not a WSA, but the EIR
admits that “the 2020 UWMP does not fully account for the RHNA allocations of the other communities served by
Please see Master Response MR-2 regarding
water supply and responses to comments
B2-5 and B2-6 above. The DEIR adequately
analyzed MCWD water supply in relation to
projected demand in 2031 and by way of a
letter the City of Monterey included in FEIR
Appendix 1, MCWD has confirmed the
conclusions of the DEIR are appropriate.

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MCWD, including the cities of Marina, Seaside, and Del Rey Oaks and unincorporated portions of Monterey County.”
(DEIR, p. 3.14-28.)
B2-21 LandWatch 3/21/24 In fact, the 2020 MCWD UWMP assumes that the water demand from the City of Monterey through 2040 would be
only 130 AFY, for which only 65 AFY is actually allocated. (DEIR, p. 3.14-28, Table

3.14-5; see also MCWD 2020 UWMP, pp. 23, 27.) Since the EIR admits that the 65 AFY allocation is sufficient for only 240 housing units, the 130 AFY demand figure in the 2020 UWMP represents demand from at most 480 units. Thus, the demand projection in the MCWD 2020 UWMP omits at
least the demand for 1,180 to 1,075 housing units (depending on whether the Fort Ord area is planned for 1,660 units or 1,555 units). Based on the assumption that 65 AFY are
required for 240 units, the omitted demand is at least 320 to 291 AFY for the omitted 1,180 to 1,075 housing units.

Please see Master Response MR-2 regarding
water supply and responses to comments
B2-5, B2-6, and B2-20 above. The DEIR
adequately analyzed MCWD water supply in
relation to projected demand in 2031 and in
a letter the City of Monterey included in
FEIR Appendix 1, MCWD has confirmed the
conclusions of the DEIR are appropriate.

B2-22 LandWatch 3/21/24 As the DEIR admits (DEIR, p. 3.14-28), the 2020 UWMP omits portions of the 6th Cycle RHNA demand for other
jurisdictions now planning to increase previously planned Fort Ord development to meet RHNA targets. For example, the
City of Seaside is now planning through its Seaside 2040 General Plan Update to include 995 housing units and 2.6 million square feet of employment space supporting 2,051 jobs in “Seaside East,” a development area within the former Fort Ord that would have to be served by MCWD. (Seaside GPU DEIR, App. B, Tables 1, 15, and 16.1) This demand is also not included in the MCWD 2020 UWMP, which is based on
assumptions about growth that were included in Seaside’s planning documents as of 2020. (MCWD UWMP, pp. 22-26,
App. C [Seaside growth projections are based on existing plans, including 5th Cycle General Plan Housing Element].) The proposed Seaside 2040 General Plan Update projects
substantially more growth than Seaside’s general plan as of 2020. (Seaside GPU DEIR, App. C, Hexagon December 7,
2022, p. 1, Table 1, Land Use Comparison [comparing
On page 3.14-7 and 3.14-8, the DEIR
discusses actions identified in the MCWD
2020 UWMP to increase future supply,
including reactivation of the MCWD pilot
seawater desalination plant and participation
in Phase 2 of the Pure Water Monterey
Expansion Project. As noted in the DEIR,
reactivation of the MCWD pilot seawater
desalination plant would add 300 AFY of
additional supply, and MCWD will receive up
to an additional 1,427 AFY of advanced
treated recycled water from the Pure Water
Monterey Project through an agreement
with Monterey One Water signed on April 8,
2016. Assuming a factor of 0.25 AFY per unit
consistent with the demand projections for
typical residential uses in the 2020 UWMP,
this would provide sufficient water for 6,908
units, which far exceeds the total projected
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households, jobs, and population for 2015, the current
General Plan buildout, and the year 2040 proposed general plan buildout].) The DEIR here fails to account for any of this foreseeable demand that was not included in the 2020
UWMP.
residential buildout of all communities
served by MCWD in 2031.

Accordingly, to further clarify and
substantiate the findings of the DEIR with
respect to future MCWD water supply, the
following amendments are hereby made to
the DEIR:
(i) The third sentence on p. 5-16 of
the DEIR is hereby amended as
follows:Water to the majority of
the Planning Area is supplied by
California American Water (CalAm) and managed by the Monterey Peninsula Water Management
District (MPWMD).
(ii) The following text is added before
the first full paragraph on p. 5-17:

Marina Coast Water District (MCWD) is the
water service provider for the portion of
Fort Ord which is within the Monterey City
limit. MCWD's 2020 UWMP projects that
available groundwater supply will be
sufficient to meet demand in its service area
through 2040, including a reliable supply of
9,620 acre-feet per year (AFY) of water
from the Salinas Valley Groundwater Basin
pursuant to the agreements under which
MCWD and the former Fort Ord were
separately annexed into Monterey County
Zones 2/2A in 1996 and 1993, respectively.

This supply is sufficient to meet a total
demand of 9,574 AFY in the service area
through 2040, including a projected demand
from the City of Monterey. In 2022, the
Association of Monterey Bay Area
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Governments (AMBAG) adopted a Regional
Housing Needs Allocation Plan for the 2023-
31 period which established the share of the
regional housing need that each member
jurisdiction must plan for in its General Plan
Housing Element. As the 2020 UWMP was
produced prior to the adoption of the
AMBAG Regional Housing Needs Allocation
Plan, it does not fully account for the RHNA
allocations of the other communities served
by MCWD, including the cities of Marina,
Seaside, and Del Rey Oaks and
unincorporated portions of Monterey
County. However, the MCWD 2020 UWMP
identifies actions to increase future supply,
including reactivation of a MCWD pilot
seawater desalination plant and participation
in Phase 2 of the Pure Water Monterey
Expansion Project, which would deliver
sufficient additional water supply to meet
projected demand within the MCWD
service area in 2031. Reactivation of the
MCWD pilot seawater desalination plant
would add 300 AFY of additional supply, and
MCWD will receive up to an additional
1,427 AFY of advanced treated recycled
water from the Pure Water Monterey
Project through an agreement with
Monterey One Water signed on April 8,
2016. Assuming a factor of 0.25 AFY per unit
consistent with the demand projections for
typical residential uses in the 2020 UWMP,
this would provide sufficient water for 6,908
units, which far exceeds the total projected
residential buildout of all communities
served by MCWD in 2031.

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Through Mitigation Measure UTIL-2,
described in Chapter 3.14 of the DEIR,
MCWD would implement planned actions
to expand its water supply, including
reactivation of the pilot seawater
desalination plant and procurement of
additional supply from Phase 2 of the Pure
Water Monterey Expansion Project.

However, while the additional sources of
supply identified in the MCWD 2020
UWMP could deliver sufficient water to
meet projected demand from the Proposed
Plan, MCWD does not currently have
funding in place to reactivate the pilot
seawater desalination plant or to procure
additional supply from Phase 2 of the Pure
Water Monterey Expansion Project. No
other feasible alternative sources of
additional water supply have been identified
by MCWD. Accordingly, even after
implementation of all feasible mitigation
measures, it cannot be said with absolute
certainty that the actions identified by
MCWD to increase supply will be
completed as planned, and as such, a
significant and unavoidable impact would
result from the implementation of the
Proposed Plan in combination with other
reasonably foreseeable projects in the
MCWD service area and the contribution of
the Proposed Project Plan would be
cumulatively considerable.

Please see also Master Response MR-2
regarding water supply and responses to
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comments B2-5, B2-6, B2-7, B2-14, and B2-15
above.

B2-23 LandWatch 3/21/24
These increased and competing demands for new
development water supply from MCWD, above the demand
levels assumed in the 2020 UWMP, are well known to the
local jurisdictions. (See Monterey County Weekly, “Despite obstacles, Monterey and Del Rey Oaks plan to use Fort Ord land for housing,” Oct. 5, 2023.2) It is unreasonable for the DEIR not to have disclosed these new sources of water
demand in the MCWD Fort Ord service area. This nondisclosure vitiates both the noncumulative and cumulative water supply analyses. Both a WSA and a valid cumulative analysis must account for all cumulative demand that would be met by the project’s supplier. The EIR simply fails to provide what SB 610 and CEQA case law require: an
accounting of the relation of supply and demand in the
MCWD service area for Fort Ord and a disclosure of just how adverse the impact to water supplies would be. These omissions are material since the EIR assumes that the
undisclosed shortfall in MCWD supplies could be addressed with as little as 300 AFY from resumption of the mothballed desalination facility or an undisclosed supply from “Phase 2 of the Pure Water Monterey Project,” both projects for which the EIR admits there is neither a plan nor funding. (DEIR, pp.

3.14-28.) Even if there were a plan or funding, the evidence indicates that the shortfall is much greater than 300 AFY.

Please see response to comment B2-22
above. As noted, Chapter 3.14 of the DEIR
identifies additional sources of supply that
could provide 1,727 AFY, which would
provide sufficient water for 6,908 residential
units, a number that far exceeds the total
projected residential buildout of all
communities served by MCWD in 2031.

Please see Master Response MR-2 regarding
water supply and responses to comments
B2-5, B2-6, B2-7, B2-14, and B2-15 above
regarding the adequacy of the water supply
analysis in the DEIR.

The assertion that the DEIR "assumes that
the undisclosed shortfall in MCWD supplies
could be addressed with as little as 300 AFY"
is inaccurate and incorrect. The DEIR makes
no such assumption. As discussed in
response to comment B2-22, the DEIR
discusses additional sources of supply
identified in the MCWD 2020 UWMP that
could yield an additional 1,727 AFY.

Nevertheless, while these additional sources
of supply could deliver sufficient water to
meet projected demand from the Proposed
Plan, MCWD does not currently have a plan
or funding in place to reactivate the pilot
seawater desalination plant or procure
additional supply from Phase 2 of the Pure
Water Monterey Expansion Project, and
given that no other feasible sources of
additional water supply have been identified,
the DEIR appropriately concludes that the
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associated impact would remain significant
and unavoidable.

B2-24 LandWatch 3/21/24 The EIR fails to disclose that MCWD cannot provide new residential hookups for Fort Ord housing development
because it is bound to honor a 6,160-unit cap on new
hookups, a limitation that has already been reached. The Draft EIR makes no mention of a critical constraint on a water supply for areas served by MCWD, including all of the former Fort Ord area.

As part of the Fort Ord Reuse Plan, the Fort Ord Reuse
Agency imposed a 6,160-unit cap on new residential
development in order to protect groundwater resources.3 Although FORA ceased to exist in 2020, MCWD is
committed to honor the 6,160-unit cap under the terms of a settlement agreement between MCWD, LandWatch, and
Keep Fort Ord Wild. The 6160-unit cap applies to units
served with groundwater. All of MCWD’s potable water
supply is groundwater. (MCWD UWMP, p. 37.) In order to
ensure that land use jurisdictions did not approve
entitlements for new residential development in excess of the cross-jurisdictional 6,160 cap on new units, FORA required that each land use jurisdiction report annually the number of new residential units for which it had granted entitlements.5 Based on those entitlements, it is clear that there is no scope to approve additional projects reliant on groundwater in Fort Ord without violating the 6,160-unit cap.

The most recent systematic accounting of the unit cap,
prepared by the City of Seaside in 2020 in connection with the Campus Town project in Seaside and based on current FORA records, indicated that all but ten of the 6,160 units had already been entitled. Furthermore, that accounting likely undercounts approved new residential units by up to 608 units, which would mean that no additional units can be entitled without further overcommitting the unit cap. The omission of this information renders the description of the The comment is noted. Please see response
to comment B2-6.

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environmental setting and the analysis of water supply and demand inadequate.

B2-25 LandWatch 3/21/24 The EIR fails to disclose that the City’s entitlement of MCWD groundwater is limited to 65 AFY. MCWD has
jurisdiction as the sole water supplier in the former Fort Ord.

The allocation of groundwater supplies in the former Fort Ord to each land use jurisdiction is spelled out in Appendix E to the MCWD 2020 Urban Water Management Plan
(“UWMP”).8 The UWMP acknowledges that the “[p]otable
water supply for the former Fort Ord (MCWD Ord
Community service area) comes from the Monterey Subbasin of the Salinas Valley Groundwater Basin (SVGB).”9 The
UWMP explains that MCWD owns and operates the Ord
Community groundwater system and underlying groundwater extraction rights.10 The UWMP explains that the rights to use groundwater were allocated among the land use
jurisdictions.11 For example, the City of Monterey was
allocated only 65 AFY.12 The UWMP explains that MCWD
will issue a water supply verification required by SB 221 or a will-serve letter for a final subdivision map only “up to the point where a given land use jurisdiction’s allocation is fully allocated to projects.”13 Thus, once a land use jurisdiction has exhausted its groundwater allocation through approval of previous projects, MCWD will not commit to provide
additional groundwater. MCWD’s UWMP reflects this fact by identifying the difference between Monterey’s assumed 130 AFY demand and its 65 AFY allocation as a “shortage.”
(UWMP, p. 62, Table 5.3, “Ord Community Groundwater
Shortfalls.”) The EIR’s water supply discussion fails to disclose that the 65 AFY allocation represents a firm limit on planned or available potable water supply for Fort Ord
development.14 Instead, the EIR’s project description section implies that the 65 AFY allocation is merely a near-term housing opportunity, not a long-term limitation on feasible development in Fort Ord, as follows:

Further, with the closure of Fort Ord, an allotment of 65- acre-feet of water was set aside for the City (an amount The assertion that the DEIR "fails to disclose
that the City’s entitlement of MCWD
groundwater is limited to 65 AFY" is
inaccurate and incorrect. Table 3.14-5 in the
DEIR shows that the MCWD 2020 UWMP
projects a total need of 130 AFY in 2030 and
that an allocation of 65 AFY has been made,
reflecting the fact that an allotment of 65
AFY of water was conveyed to the City of
Monterey with the closure of Ford Ord, as
explained on page 3.14-7 of the DEIR.

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sufficient for 240 new homes), potentially making Fort Ord one of the more feasible locations for housing development in the near term. (DEIR, p. 2-15.) The failure to disclose the 65 AFY allocation as a limitation on available supplies renders the description of the environmental setting and the analysis of water supply and demand inadequate.

B2-26 LandWatch 3/21/24 The EIR fails to disclose the magnitude of the water supply shortfall. The only reference to the magnitude of a water supply shortfall for Fort Ord development is an entirely unexplained figure in Mitigation Measure UTIL-2, which
purports to direct MCWD to increase water supply and
states that these “measures shall be sufficient to generate an additional 199.2 AFY by 2030, as needed to support new
development within the City of Monterey that will be served by MCWD.” (DEIR, p. 3.14-29.) Nowhere does the EIR
explain how this 199.2 AFY figure was derived. A 199.2 AFY shortfall cannot represent the actual magnitude of MCWD’s total shortage or the shortage in water allocated to
Monterey.

Please see Master Response MR-2 and
response to comment B-22 above. The
MCWD 2020 UWMP identifies additional
sources of water which would increase supply
by 1,727 AFY, providing sufficient water for
6,908 units, far in excess of the total
projected residential buildout of all
communities served by MCWD in 2031.

Subsequent to the publication of the DEIR,
the City revised the Housing Element sites
inventory and reduced the number of units
projected at Fort Ord from 1,660 to 1,200
units. Assuming a factor of 0.25 AFY per unit
consistent with the demand projections for
typical residential uses in the 2020 UWMP,
300 AFY of water would be needed to serve
the new residential development. In the letter
of March 8, 2024 (see FEIR Appendix 1),
MCWD clarified that an allotment of 65 AFY
for development at Fort Ord within the City
of Monterey has already been planned in the
2020 UWMP. Therefore, an additional 235
AFY of water would be needed to serve
future development at Fort Ord within the
City of Monterey and accordingly Mitigation
Measure UTIL-2 is hereby revised to reflect
the residential development projections in
the revised Draft Housing Element published
on April 18, 2024:

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MM-UTIL-2: Expand MCWD Sources of
Supply. MCWD shall implement measures
to increase sources of water supply, including
reactivation of the pilot seawater desalination
plant and Indirect Potable Reuse of advanced
treated water from the Pure Water Monterey
project. The measures shall be sufficient to
generate at least an additional 199.2 235 AFY
by 2030, as needed to support new
development within the City of Monterey
that will be served by MCWD.

This revision to Mitigation Measure UTIL-2
represents a clarification to the information
in the DEIR but does not change the finding
of significance for impacts related to adequate
water supply, which remain significant and
unavoidable even after implementation of all
feasible mitigation because MCWD does not
currently have a plan or funding in place to
reactivate the pilot desalination plant or
procure additional water from M1W.

B2-27 LandWatch 3/21/24 First, a 199.2 AFY shortfall cannot represent MCWD’s total shortfall in 2030. As discussed above, MCWD has service responsibility for the whole of the Fort Ord area, including service to other jurisdictions that are now planning to increase their development in Fort Ord beyond the levels assumed in the MCWD UWMP. The EIR provides no
assessment of the total increase in cumulative demand across jurisdictions for MCWD water supplies, but it admits that the UWMP does not include Monterey’s current RHNA demand.
(DEIR, p. 3.14-28.) And, as discussed above, other jurisdictions are planning substantially more development in Fort Ord than assumed in the MCWD 2020 UWMP, which the EIR admits.

Accordingly, if the 199.2 AFY figure was derived in reliance on supply and demand projections in the MCWD UWMP, it is
Please see Master Response MR-2 and
response to comment B2-26.

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not accurate and certainly understates the cumulative
shortfall. Second, a 199.2 AFY shortfall cannot represent the shortfall of water allocated to Monterey. As discussed, Monterey’s allocation is only 65 AFY. Monterey plans at least 1,555 units, and perhaps 1,660 units, on Fort Ord, and the EIR assumes that each unit requires 0.27 AFY. (65 AFY divided by 240 units – see DEIR, p. 2-15.) This implies a water demand of from 421 AFY to 448 AFY, which is 356 to 383 AFY short of the 65 AFY allocation.

B2-28 LandWatch 3/21/24 Proposed water supply mitigation is inadequate. Mitigation Measure UTIL-2 to address the lack of a water supply
provides:

MCWD shall implement measures to increase sources of
water supply, including reactivation of the pilot seawater desalination plant and Indirect Potable Reuse of advanced treated water from the Pure Water Monterey project. The measures shall be sufficient to generate an additional 199.2 AFY by 2030, as needed to support new development within the City of Monterey that will be served by MCWD. (DEIR, p.

3.14-29.)
This mitigation measure is inadequate under CEQA because it is not enforceable. (CEQA Guidelines, § 15126.4(a)(2).) The measure is legally infeasible because the City of Monterey does not have authority to require MCWD, an independent special district, to implement measures to provide additional water supply. The measure is also inadequate because, as the EIR admits, MCWD has no plan or funding to implement this mitigation.

As discussed below, the elimination of proposed development on Fort Ord lands is feasible mitigation and a feasible project alternative since needed RHNA development can in fact be relocated elsewhere in the City not dependent on MCWD
water supplies. The EIR should propose this feasible
mitigation instead.

With respect to the enforceability of
Mitigation Measure UTIL-2, as discussed on
pages 3.14-7 and 3.14-8 of the DEIR the
MCWD 2020 UWMP identifies actions to
increase future supply which would deliver
sufficient additional water supply to meet
projected demand within the MCWD
service area in 2031, including reactivation of
the MCWD pilot seawater desalination plant
and participation in Phase 2 of the Pure
Water Monterey Expansion Project. Further,
as discussed in the DEIR and the 2020
UWMP, MCWD has determined these
actions to be feasible, as confirmed by the
letter MCWD sent to the City on March 8,
2024 (see FEIR Appendix 1). Mitigation
Measure UTIL-2 calls for MCWD to
implement the feasible measures identified in
its 2020 UWMP to increase water supply to
serve the projected demand at Fort Ord in
2031 and does not attribute any authority to
the City of Monterey that the City does not
have.

With respect to the assertion that "the
elimination of proposed development on
Fort Ord lands is feasible mitigation," the
City notes that this would be a change to
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the project description and would not
constitute mitigation. Please see also
response to comment B2-11 above. The
Reallocated Housing Alternative would not
permit the City to meet its RHNA
obligation and would not comply with State
Housing Element law and as such is
infeasible.

B2-29 LandWatch 3/21/24 The EIR fails to disclose the impacts of new water supply facilities. The EIR concludes that, with respect to water supplies for the MCWD service area, the project
would not result in “relocation or construction of new or expanded water . . . facilities, the construction or relocation of which could cause significant environmental effects.” (DEIR, p.

3.14-29.) The stated rationale for this conclusion is that “MCWD owns a pilot desalination plant which if reactivated could provide 300 AFY of additional water supply to meet additional demand within its service area, including additional demand from new development at Fort Ord as part of the
Proposed Plan. Therefore, implementation of the Proposed Plan would not require the construction of new or the
expansion of existing regional water facilities over and above existing and planned facilities.” (DEIR, p. 3.14-29.)This claim is inconsistent with Mitigation measure UTIL-2, which directs MCWD to reactivate its mothballed desalination plant and to implement a new project it calls “Indirect Potable Reuse of advanced treated water from the Pure Water Monterey
project.” Because indirect potable reuse is not an existing facility, its implementation may cause significant environmental effects, which the EIR must be revised to disclose.

Please see also response to comment B2-7.

On page 3.14-29, the DEIR identifies the
construction of new regional water facilities
that Cal-Am and MCWD have planned for in
order to increase water supply to serve
future needs in their respective service areas
and appropriately concludes that associated
impacts would be less than significant
because implementation of the Proposed
Plan would not require the construction of
new or the expansion of existing regional
water facilities over and above existing and
planned facilities.

The comment appears to conflate the
desalination plant and advanced treated
water from M1W, which is incorrect. These
are two separate and feasible actions to
increase MCWD supply identified in the
2020 UWMP.

B2-30 LandWatch 3/21/24 The existing indirect potable reuse of 3,500 AFY of treated water supplied by Pure Water Monterey discussed in the EIR is not water for the MCWD service area; it is for the Cal-Am service area. (DEIR, p. 3.14-6.) The EIR identifies a possible MCWD indirect potable reuse project as one of the potential This comment inaccurately characterizes the
content of the DEIR. On pages 3.14-7 and

3.14-8 of the DEIR, the MCWD 2020
UWMP identifies actions to increase future
supply which would deliver sufficient
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projects and management actions described in the
Groundwater Sustainability Plan for the Monterey Subbasin that MCWD may pursue in the future. (DEIR, p. 3.9-23, citing Marina Coast Water District Groundwater Sustainability
Agency & Salinas Valley Basin Groundwater Sustainability Agency, Groundwater Sustainability Plan Monterey Subbasin, 2022 (Monterey Subbasin GSP)15; see also DEIR, p. 2.9-27.) The EIR admits that indirect potable reuse for the MCWD service area has so far only undergone a feasibility study and that it is neither funded nor planned. (DEIR, pp. 3.14-8, 3.14- 28 to 3.14-29.) The Monterey Subbasin Groundwater
Sustainability Plan confirms that this project has not yet been selected for implementation, funded, or undergone CEQA
review. (Monterey Subbasin GSP, pp. 9-36 to 9-44.)
Accordingly, it would be a new project, and if this project depends on its implementation, the DEIR must disclose its environmental impacts.
additional water supply to meet projected
demand within the MCWD service area in
2031, including reactivation of the MCWD
pilot seawater desalination plant and
participation in Phase 2 of the Pure Water
Monterey Expansion Project. These are two
separate actions to increase MCWD supply
identified in the 2020 UWMP as feasible.

Mitigation Measure UTIL-2 would not
require the construction of new or the
expansion of existing regional water facilities
over and above existing and planned
facilities. Please see also responses to
comments B2-28 and B2-29.

B2-31 LandWatch 3/21/24 Biological resources
In general, the DEIR is inadequate because it fails to conduct any local field studies or analyses to evaluate the feasibility of even a general program of anticipated biological impacts mitigation measures relating to the City's lands on the former Fort Ord. Without this environmental setting information, the EIR does not and cannot assess the significance of impacts.

As noted on page ES-1 of the DEIR, the
Monterey 2031 General Plan EIR is a
program EIR that examines the potential
effects resulting from implementing
designated land uses and policies in the
Proposed Plan. The DEIR appropriately relies
on a review of publicly available data on
biological resources and existing conditions
to provide the necessary data for a programlevel analysis of impacts. Please see also response to comment B2-9. The DEIR
provides adequate environmental setting
information.

B2-32 LandWatch 3/21/24 Furthermore, if mitigation is not demonstrably feasible, mitigation measures may not be deferred. Here, the evidence is that mitigation is so uncertain that the EIR must specify the mitigation now. That specification must address more than mitigation ratios and protocols but the uncertainty itself, which requires disclosure of the geographic location and As noted on page ES-1 of the DEIR, the
Monterey 2031 General Plan EIR is a
program EIR. While the Proposed Plan will
facilitate development subsequent to its
adoption, no specific developments are
proposed on any site as part of the
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extent of the covered species and natural communities as well as the availability of mitigation lands.

Proposed Plan. Therefore, the specific details
of subsequent projects, such as square
footage, building placement, heights, and site
design, cannot be known at this time.

Accordingly, the DEIR appropriately analyzed
potential impacts to biological resources at a
programmatic level, considering the probable
location of future development in relation to
the location of biological resources as
documented on the basis of publicly available
information from State agencies and
proposing mitigation accordingly. Further, the
DEIR notes on page ES-1 that "to the extent
that any future development project made
possible by the Proposed Plan may have
individual, site-specific impacts not addressed
in this program EIR, such projects would be
subject to separate, project-level
environmental review, as required by State
law." Moreover, the commenter does not
provide any substantial evidence
demonstrating that the mitigation to avoid
significant impacts on biological resources is
infeasible or ineffective; rather, they merely
speculate. The analysis and mitigation
measures contained in the DEIR are
adequate and appropriate for a programlevel analysis of a General Plan, the highest and broadest tier of the planning hierarchy.

Please see also respond see to comments
B2-9 and B1-3.

B2-33 LandWatch 3/21/24 Sensitive species
Contrary to what is stated in the DEIR, Impact 3.4-1 would not be mitigable to a less than significant level because mitigation MM-BIO-4 would be infeasible. The City's former Fort Ord lands include occurrences of sensitive species and sensitive plant communities whose extent is great enough Please see also responses to comments B2-
9, B2-31, and B2-32 as well as B1-6 and B1-

14. The DEIR is a program EIR that does not
and cannot consider the specific
environmental impacts of subsequent
development projects. Further, as noted in
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that the anticipated project-level avoidance and minimization would be infeasible, rendering the future projects unviable.

These limitations should be identified with a program level analysis in the EIR that includes field-based quantification of the distribution of the species.
response to comment B2-13, Program 1-H
in the proposed Housing Element calls for
the preparation of a specific plan to guide
future development and conservation in the
Fort Ord/Ryan Ranch area and stipulates
that the specific plan should prioritize
housing and mixed-use development on any
combination of the parcels shown on Map 3-
10 of the Draft Housing Element, but does
not require residential development on any
specific parcel or on all parcels identified.

Therefore, the DEIR appropriately
incorporated mitigation measures, including
Mitigation Measure Bio-4, considering the
probable location of future development in
relation to the location of biological
resources as documented on the basis of
publicly available information from State
agencies. Further, as noted on page ES-1 that
"to the extent that any future development
project made possible by the Proposed Plan
may have individual, site-specific impacts not
addressed in this program EIR, such projects
would be subject to separate, project-level
environmental review, as required by State
law."The “level of detail contained in a first
tier EIR need not be greater than that of the
program, plan, policy, or ordinance being
analyzed.” (CEQA Guidelines, § 15152(b);
see also subdivision (c) [“the development of
detailed, site-specific information may not be
feasible, but can be deferred, in many
instances, until such time as the lead agency
prepares a future environmental document
in connection with a project of a more
limited geographical scale, as long as the
deferral does not prevent adequate
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identification of significant impacts of the
planning approval at hand.”].)
B2-34 LandWatch 3/21/24 Examples of special status species on former Fort Ord lands with within-City extents large enough to be unavoidable to development projects include: (1) sandmat manzanita, (2) Monterey ceanothus, and (3) Yadon's piperia, an endangered orchid. The EIR’s description of the environmental setting is inadequate, and its conclusions about the feasibility of mitigation, are unfounded without documentation of the
range and extent of these species.

Please see response to comment B2-33. The
analysis and mitigation in the DEIR are
adequate and appropriate for a program EIR.

Any development pursuant to the Proposed
Plan would be required to comply with MMBIO-4, which would avoid and minimize disturbance to any special-status plant
species to a less-than-significant level. As
noted on page ES-1 that "to the extent that
any future development project made
possible by the Proposed Plan may have
individual, site-specific impacts not addressed
in this program EIR, such projects would be
subject to separate, project-level
environmental review, as required by State
law.”
B2-35 LandWatch 3/21/24 Sensitive communities The DEIR is inadequate in stating that Impact 3.4-2 on sensitive natural communities would be less than significant because the DEIR is incorrect - at least on the former Fort Ord - when it states that such areas "are located primarily in the open space designations for the Planning Area and do not overlap with proposed sites for development." (DEIR, p. 3.4-33.) The entire area of the City's former Fort Ord lands are designated for Mixed Use Development under the proposed plan update, and the majority of this area is currently occupied by sensitive plant communities, including:
(1) sandmat manzanita maritime chapparal, (2) woolly leaf manzanita maritime chaparral, (3) Toro manzanita maritime chaparral, (4) vernal pools and other wetlands.

Please see also responses to comment B2-

34. The specific location and design of future
development at Fort Ord would be
determined with community input during
preparation of a specific plan, per Program
1-H of the proposed Housing Element. To
the extent that future development is
proposed in areas where special status
species, including special status plant species,
are known to be present or are potentially
present, compliance with state and local
regulations and MM-BIO-4 would be
required. Further, as noted on page ES-1 that
"to the extent that any future development
project made possible by the Proposed Plan
may have individual, site-specific impacts not
addressed in this program EIR, such projects
would be subject to separate, project-level
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environmental review, as required by State
law." Additionally, the City notes that the
statement on page 3.4-33 specifically
references that riparian/wetlands and
USFWS-designated critical habitat do not
overlap with proposed sites for
development.

B2-36 LandWatch 3/21/24 Wetlands
The DEIR is inadequate in stating that Impact 3.4-3 on
wetlands would be less than significant because it fails at a programmatic level to evaluate the distinct possibility that no development projects may be feasible in the City's former Fort Ord lands while complying with all applicable laws, regulations, policies, and agreements relating to wetlands, vernal pools, and runoff. The west edge of the City's former Fort Ord lands includes a vernal pool complex with
numerous native wetland species and - via a sequence of USFWS Biological Opinions - a federally regulated role in protecting habitat for endangered California Tiger Salamander.

Impacts to this area are unmitigable as no sufficient mitigation habitat exists. The area and required setbacks could not be developed. Federally mandated restrictions also exist relating to runoff reaching the Frog Pond Natural Area Expansion, immediately downstream from City land. Any flow detention infrastructure relating to this requirement would need to be in areas outside the vernal pool complex and associated setbacks. Such areas are occupied by sensitive upland species and communities. This presents the possibility that none of the City's former Fort Ord lands are feasibly developed under the Mixed Use designation. Such constraints should be evaluated at a programmatic level, and not left to future project proposals, because they have wide-reaching impacts for the remainder of the City's General Plan, particularly relating to attainment of housing targets.

According to data from a Biological
Assessment prepared for the 2004 General
Plan Update mapped on Figure 3.4-1, there
are no wetlands identified in the Fort
Ord/Ryan Ranch opportunity area. As stated
on page 3.4-11, the Planning Area is
dissected by a number of small creeks and
streams that flow directly or indirectly to
Monterey Bay. Lake El Estero and Del Monte
Lake are receiving bodies for several of the
streams that flow through the city. These
features support (or have the potential to
support) seasonal wetland vegetation within
their beds and riparian vegetation along their
banks; however, this does not preclude
future identification of wetlands during sitespecific studies. In the event of a future identification of a wetland, development
would be required to adhere to existing
regulations, as discussed on page 3.4-33, and
accordingly the impacts of future
development under the Proposed Plan on
riparian habitat or sensitive natural
communities would be less than significant.

Please see also response to comment B1-4
above regarding California tiger salamander.

According to the HMP for the Former Fort
Ord, the California tiger salamander may
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occur in ponds and vernal pools throughout
former Fort Ord which represents
approximately less than one percent of land
at the site. Protection or replacement for
these waters of the will be provided through
implementation of the federal Clean Water
Act. Further, as stated on page 3-21 of the
HMP, if vernal ponds are disturbed with
development, mitigation and habitat
restoration plans will be required and must
include measures to minimize disturbance to
ponds and vernal pools. The goal of
restoration plans will be to restore affected
wetlands so that they are of the same
acreage and provide the same functions as
before development. Restoration objectives
would include establishment of selfsustaining populations of California Iinderiella, California tiger salamander, and
California red-legged frogs similar to those
that existed before development. Therefore,
at a programmatic level, compliance with the
HMP would reduce impacts to California
tiger salamander to the maximum extent
practicable and impacts would be less than
significant.

Nevertheless, out of an abundance of
caution, Mitigation Measure BIO-3 on page

3.4-26 of the DEIR is hereby revised as
follows to further reduce potential impacts
to California tiger salamander, which with
HCP compliance would already be less than
significant:

MM-BIO-3: Install Temporary Flagging
or Barrier Fencing to Protect Sensitive
Biological Resources Adjacent to the
Work Area. If required pursuant to
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Mitigation Measure BIO-1, a qualified
biologist with prior experience for subject
species in Monterey County shall identify
and flag or fence sensitive biological habitat
on-site to ensure it is avoided during
construction and pre-construction activities.

Flagging or fencing shall be installed prior to
site preparation activities and remain in
place for the duration of construction
activities.

Additionally, in the event that California Tiger
Salamander is identified as occurring or
having potential to occur in the work area
pursuant to Mitigation Measure BIO-1, then
the following measures will be implemented:
• Vernal pools and other potentially
suitable wetland habitat will be
avoided to the extent feasible
during construction to minimize the
potential loss of breeding sites for
Califonia Tiger Salamanders.
• Measures to protect water quality,
will be implemented to reduce
habitat degradation in adjacent
areas.
• A USFWS-approved biologist will
demarcate the limits of the fence
line. The barrier will be inspected
and repaired at least weekly to
ensure it remains in place during
construction.
• A biological monitor will survey
suitable habitat, including all
wetlands, prior to grading or filling.

If either species is located during
surveys, it will be moved to an
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approved off-site location in
coordination with the USFWS and
CDFW.

B2-37 LandWatch 3/21/24 Habitat Connectivity
The DEIR is inadequate in stating that Impact 3.4-4 to
movement corridors would be less than significant because in making this determination, it primarily relies on information that is completely inappropriate for habitat connectivity analysis in relation to City’s former Fort Ord lands. The analysis relied primarily on the California Essential Habitat Connectivity (CEHC) project (Spencer et al. 2010), and a version of it available through the CDFW BIOS Habitat
Connectivity Viewer. CEHC was a state-wide analysis, with Monterey-area information so coarse, inaccurate, and
outdated that it failed to recognize the former Fort Ord as a substantially natural and conserved area (CEHC 2010 Figures

2.1, 2.2, 2.5), despite it being one of the most important conserved natural areas in the California Central Coast Region. CEHC essentially assumed that Fort Ord was still an Army base. This led to a failure in the CEHC analysis to recognize Fort Ord as a habitat node (Fig. 2.7) or even as a conserved area (Fig. 2.9) despite the existence of the Fort Ord National Monument and its predecessor, the Fort Ord Natural Resource Management Area (designated in 1997
under the Fort Ord Habitat Management Plan). These are
fundamental errors that undermine any attempt to use
CEHC to analyze the role of the City’s lands in maintaining habitat connectivity. For example, because of the deficiencies in CEHC, Figure 3.4-3 of the DEIR incorrectly obscures
habitat connectivity near the Ryan Ranch Disc Golf Course between the Santa Lucia Range and the former Fort Ord
region via Jacks Peak; failing to even recognize Jacks Peak Regional Park and Fort Ord National Monument as “Natural Areas”.

As detailed on page 3.4-9, the California
Essential Habitat Connectivity Project: A
Strategy for Conserving a Connected
California was designed to support land use
planning and transportation. The report was
produced by a multidisciplinary team of
representatives from 62 agencies, along with
a smaller technical advisory team and
steering committee. The report includes a
statewide essential habitat connectivity map,
data collected to delineate areas shown on
the map, recommendations for correcting
the fragmentation caused by roads, and
guidance for developing and implementing
local and regional connectivity plans. Analysis
was conducted to determine where
mitigation would be most effective and how
best to enhance connectivity while lessening
vehicle/wildlife collisions. Therefore, the
DEIR assessed and detailed biological
resource impacts with the most up-to-date
and accurate information available at the
time of publication. The commenter does
not identify alternate, more accurate sources
of information.

B2-38 LandWatch 3/21/24 The DEIR also cited the Fort Ord Habitat Management Plan (1997) as designating no habitat corridors in the City's Please see response to comment B2-37. The
Installation-Wide Multispecies HMP is the
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former Fort Ord lands. This also was a misuse of inapplicable information; the HMP corridor parcels were only designated to connect habitats within Fort Ord, not between Fort Ord and outside areas. (HMP, p. 2-13.) In fact, when one views the original 1996 Land Use Concept approved by the Fort Ord Reuse Authority (not the unapproved 2001 republication), a corridor of "open space/recreation" and "habitat
management" is designated through City of Monterey land between areas to the south and what is now the Fort Ord National Monument. The other two documents cited were
municipal planning documents from the 1980s, hardly viable sources of habitat information within a contemporary
planning framework. A much more granular analysis is
required. No previous analysis is fully adequate. One of the most recent analyses was commissioned by TAMC in relation to Highway 68, and it was also flawed. For example, the only sensitive species reported as roadkill by this survey was an American badger killed where there is an existing habitat corridor on City of Monterey land near the Ranch Disc Golf course. But the TAMC analysis failed to recognize this and instead focused on the numerically greater detection of mule deer using culverts, which in turn was biased by the fact that remote cameras are more easily installed in culverts than along un-culverted sections of highway such as exist where the badger was killed. The reality is that the physically largest habitat corridor between Fort Ord and areas to the south (Monterra, Jacks Peak, and the broader Santa Lucia Range) occurs through City of Monterey lands on the former Fort Ord, and sensitive mammals such as badger (which are found on Fort Ord) are using this corridor. The existing general plan (2005-2016) rightly designates this entire corridor for parks, recreation, and open space. The proposed update retains the designation for the non-Fort Ord lands (where the Ranch Disc Golf Course is located). It should also retain the designation for the adjacent Fort Ord lands. Only this would likely support the DEIR's conclusion of less than significant impact.
only applicable HMP for the Planning Area.

See also response to comment B2-37 and
B1-5. The CDFW BIOS mapping system
represents the most up-to-date and accurate
information available at the time of
publication. The commenter does not
identify alternate, more accurate sources of
information. Therefore, the analysis in the
DEIR is adequate.

The comment regarding the retention of the
open space land use designation from the
current General Plan at Fort Ord is noted.

Please see response to comments B2-13 and
B2-33. Program 1-H of the proposed
Housing Element calls for the preparation of
a specific plan to guide future development
and conservation at Fort Ord, the
overarching objective of which is to foster
the creation of a mixed-use village on a
portion of the site to provide housing, jobs,
schools, shops, services and recreation for
future residents while also preserving
carefully selected areas of natural open
space and habitat.

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B2-39 LandWatch 3/21/24 Alternatives
Other than the obligatory no-project alternative, the EIR assesses two alternatives. The Relocated Housing Alternative, designed to avoid significant water supply, biological, and hazardous materials impacts at Fort Ord, would relocate the proposed 1,660 units of Ryan Ranch/Fort Ord housing to the existing urbanized portions of the City by increasing
permitted density and heights in the downtown area and key commercial corridors, including North Fremont Street,
Lighthouse Avenue, Del Monte Avenue, Garden Road, Pacific Avenue, Munras Avenue, and Abrego Street. (DEIR, p. 4-3.) The DEIR assumes that the Relocated Housing Alternative would result in only 4,183 housing units instead of the 5,787 units under the proposed plan. (DEIR, p., 4-4, Table 4-1.). The Increased Workforce Housing Alternative, designed to avoid the loss of 50 acres of grazing land and reduce VMT impacts, would replace office and visitor-serving uses with high density housing in the Downtown, Cannery Row, Lighthouse Avenue, North Fremont Street, Pacific Avenue, Munras Avenue, and Abrego Street locations; transform Del Monte Avenue into a high-density residential corridor; and increase multifamily housing at Fort Ord. (DEIR, p. 4-3.) The development of the 50-acre MPUSD site would not proceed. The Increased
Workforce Housing Alternative would increase the number of housing units to 9,830 and reduce the number of new jobs to better balance jobs and housing to reduce VMT. (DEIR, pp. 4-3 to 4.4.)
Please see responses to comments B2-2, B2-
4, and B2-11 above. The Relocated Housing
Growth Alternative does not avoid a
significant and unavoidable impact related to
water supply; in fact, it exacerbates an
already significant and unavoidable impact on
water supply in the Cal-Am service area as it
would result in 4,183 additional housing
units in the Cal-Am service area by 2031.

B2-40 LandWatch 3/21/24 The DEIR finds that the Increased Workforce Housing Alternative is environmentally superior “because it avoids the Proposed Plan’s significant and unavoidable impact pertaining to agricultural resources and reduces the severity of
significant and unavoidable impacts related to air quality.” (DEIR, p. 4-22.) The DEIR acknowledges that the Relocated Housing Alternative reduces “the number of impacts
compared to the Proposed Plan, although it would have a worse impact on an already significant and unavoidable
Please see responses to comments B2-2, B2-
4, and B2-11 above. On page 4-22, the DEIR
states that the Relocated Housing
Alternative would “not meet the City’s
RHNA obligations.” While the Relocated
Housing Growth Alternative has a nominally
reduced number of significant impacts
compared to the Proposed Plan, it would
have a worse impact on an already significant
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impact on water supply.” The DEIR also claims that the
Relocated Housing Alternative would not meet the RHNA
objective to provide sites for the City’s share of Very Low and Low income housing units. (DEIR, p. 4-22.) The DEIR lacks substantial evidence for these conclusions, each of which is directly contradicted by the evidence in the EIR itself. The EIR demonstrates that the Relocated Housing Alternative would not have a “worse impact” on water supply but would
entirely avoid the water supply impact in the MCWD service area; would reduce seven significant impacts compared to the proposed project; and would not increase the severity of any significant impacts. By contrast, the Increased Workforce Housing Alternative would reduce only five significant impacts compared to the proposed project; and would increase the severity of four significant impacts. Finally, there is no evidence that the Relocated Housing Alternative would not provide sites for the RHNA share of very low and low
income units and substantial evidence it would provide more lower income units than the proposed project. These points are discussed below.
and unavoidable impact related to water
supply and it would not permit the City to
meet its RHNA obligations under State law
because it would not demonstrate adequate
capacity for Moderate Income housing and
because it would assume development of
housing to meet the needs of Low and Very
Low Income households on sites that do not
meet the criteria established in State law for
Low and Very Low Income RHNA units.

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Please see response to comments B2-2, B2-
4, B2-11, and B2-39 above. The Relocated
Housing Alternative does not avoid a
significant and unavoidable impact related to
water supply; in fact, it exacerbates and
already significant and unavoidable impact on
water supply in the Cal-Am service area.

B2-41 LandWatch 3/21/24 The Relocated Housing Alternative is environmentally superior because it reduces seven significant impacts and increases none, whereas the Increased Workforce Housing Alternative reduces only five and increases four. The EIR’s alternatives comparison table indicates for each potential impact caused by the proposed project whether it is of no impact (NI), less than significant without mitigation (LTS), potentially significant but less than significant with mitigation (LTSM), or unavoidably significant even with mitigation (SU). (DEIR, pp. 4.2-22 to 4.2-25, Table 4-2.) The table then indicates for each alternative whether its impacts are less than, the same as, or greater than the impacts of the
proposed project. Alternatives should be designed to reduce significant impacts that would otherwise require mitigation or that are significant and unavoidable despite mitigation. Thus, the efficacy of the alternatives should be assessed with reference to whether they avoid or reduce the proposed
project’s LTSM or SU impacts. Considering just the LTSM and SU impacts of the proposed project, Table 4-2 indicates that the Relocated Housing Alternative would avoid or reduce the following seven impacts, five of which are SU and two of which are LTSM:
• 3.3-1 Air Quality Plan (SU -)
• 3.3-2 Increase in Criteria Pollutant (SU -)
• 3.3-3 Sensitive Receptors (SU -)
• 3.4-1 Special-Status Species (LTSM -)
• 3.8-4 Hazardous Materials Site (LTSM -)
• 3.14-1 Relocation or Expansion of Utilities (SU -)
Please see response to comment B2-4. The
DEIR found that the Relocated Housing
Growth Alternative would result in 11
significant and unavoidable impacts, 9 less
than significant impacts with mitigation, and
46 less than significant impacts. For the
Increased Workforce Housing Alternative, 10
impacts were significant and unavoidable, 10
impacts were less than significant with
mitigation, and 46 impacts were less than
significant. Given that the Increased
Workforce Housing Alternative avoids the
Proposed Plan’s significant and unavoidable
impact pertaining to agricultural resources
and reduces the severity of significant and
unavoidable impacts related to air quality, the
DEIR appropriately concludes that the
Increased Workforce Housing Alternative is
the environmentally superior alternative.

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• 3.14-2 Water Supply (SU -)
The Relocated Housing Alternative would not increase any LTSM or SU impacts compared to the proposed project. By contrast, the Increased Workforce Housing Alternative
reduces only the following five LTSM and SU impacts of the proposed project, four of which are SU and one of which is LTSM:
• 3.2-3 Farmland Conversion (SU-)_
• 3.6-2 Conflict with an Applicable Plan, Policy, or
Regulation [re Energy, GHG, Climate Change] (SU-)
• 3.13-2 VMT (SU-)
• 3.15-1 Emergency Response/Evacuation [wildfire]
(SU-)
• 3.15-3 Infrastructure [Wildfire] (LTSM-)
And the Increased Workforce Housing Alternative aggravates four LTSM or SU impacts of the
proposed project, three of which are SU and one of which is LTSM:
• 3.6-1 Generate GHG Emissions (SU+)
• 3.12-1 Fire, Police, Schools, Parks, or Other Public
Facilities (LTSM+)
• 3.14-1 Relocation or Expansion of Utilities (SU+)
• 3.14-2 Water Supply (SU+)
Thus, by the EIR’s own accounting, the Relocated Housing Alternative reduces more SU impacts and more LTSM
impacts than the Increased Workforce Housing Alternative does. And the Relocated Housing Alternative does not
increase any SU or LTSM impacts, whereas the Increased
Workforce Housing increases three SU impacts and one
LTSM impact. There is no substantial evidence that the
Increased Workforce Housing Alternative is environmentally superior. The evidence in the EIR itself is that the Relocated Housing Alternative is environmentally superior.

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B2-42 LandWatch 3/21/24 The EIR errs in its conclusion that the Relocated Housing Alternative would not meet the objective of accommodating very low and low income RHNA units. The EIR’s discussion of the Relocated Housing Alternative concludes that it would not meet the objective to accommodate the City’s very low and low income RHNA. (DEIR, p. 4-22.) The EIR states that the Relocated Housing Alternative would provide only 4,183 units, which is 1,604 units fewer than the proposed project’s 5,787 units. The 1,604-unit reduction represents nearly all of the projected 1,660 units for the Ryan Ranch/Fort Ord area in the proposed project.

The fact that the total number of units is reduced by
essentially all of the proposed Fort Ord units indicates that the EIR preparers have simply ignored the provision in the Relocated Housing Alternative intended to relocate housing from Fort Ord to the urbanized portions of the City by
increasing “permitted density and heights in the downtown area and key commercial corridors, including North Fremont Street, Lighthouse Avenue, Del Monte Avenue, Garden Road, Pacific Avenue, Munras Avenue, and Abrego Street.” (DEIR, p. 4-3.) It makes no sense to have included provisions in the Relocated Housing Alternative intended to relocate housing through increased density if those provisions were assumed to be ineffective. Notably, the Increased Workforce Housing analysis assumes that its density increases would be effective in increasing housing units: it is assumed to increase housing units from 5,787 units to 9,830 units by provisions to “replace office and visitor-serving uses with high density housing the Downtown, Cannery Row, Lighthouse Avenue, North
Fremont Street, Pacific Avenue, Munras Avenue, and Abrego Street locations; transform Del Monte Avenue into a highdensity residential corridor; and increase multifamily housing at Fort Ord.” (DEIR, pp. 4-3 to 4-4.) If such increased density provisions are effective for the Increased Workforce Housing Alternative, they should be effective for the Relocated Housing Alternative. The EIR offers no analysis, and thus no evidence, to support its conclusion that the Relocated
Please see responses to comments B2-2, B2-
4, and B2-11 above. On page 4-22, the DEIR
states that the Relocated Housing
Alternative would “not meet the City’s
RHNA obligations.” While the Relocated
Housing Growth Alternative has a nominally
reduced number of significant impacts
compared to the Proposed Plan, it would
have a worse impact on an already significant
and unavoidable impact related to water
supply. The Relocated Housing Growth
Alternative would not permit the City to
meet its RHNA obligations under State law
because it would not demonstrate adequate
capacity for Moderate Income housing and
because it would assume development of
housing to meet the needs of Low and Very
Low Income households on sites that do not
meet the criteria established in State law for
Low and Very Low Income RHNA units.

Buildout projections for the Relocated
Housing Growth Alternative are based on
parcel-based projections prepared by
LandWatch. The LandWatch parcel-based
projections do not demonstrate adequate
capacity to meet Moderate Income RHNA
and they assume development of housing to
meet the needs of low and very low income
households that do not meet the criteria
established in State law, including that they
be of adequate size, and have appropriate
development standards as needed to
facilitate the development of a variety of
housing products suitable for all income
levels. Further, the LandWatch parcel-based
projections assume that individual parcels
will be built to the maximum density
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housing alternative would not provide sufficient very low and low income units to meet the City’s RHNA. It appears that the EIR simply neglected to assess the effect of the increased densities and height limits. Information in the Site Inventory section of the Housing Element indicates that increased height limits and permitted densities would in fact provide enough additional very low and low income
units in the North Fremont Street, Lighthouse Avenue, Del Monte Avenue, Garden Road, Pacific Avenue, Munras Avenue, and Abrego Street areas to more than make up for the loss of the projected 220 units of very low and low income units in Fort Ord. The Site Inventory identifies relevant constraints for lower income units and provides that all sites meeting these constraints were counted toward the lower income
unit RHNA. First, the Site Inventory points out that sites for lower income units must “be of appropriate size, be free from environmental constraints, be zoned to accommodate
housing, have appropriate development standards, and be served by public facilities.” (Housing Element p. 3-2.) The Site Inventory states that “[s]ites meeting the criteria established in State law for lower income RHNA sites were counted
toward the City's Low and Very Low Income RHNA
allocation; other sites were attributed to the City's Above Moderate RHNA allocation.” (Housing Element, p. 3-10,
emphasis added.) Generally, the State law safe harbor criteria for very low and low income sites are met if the Site
Inventory (1) provides by-right development for sites used in prior RHNA cycles, (2) zones or proposes to zone at Mullin density, which for Monterey County is 20 units per acre, and (3) counts only parcels that meet the parcel size limitations, which are over ½ acre and under 10 acres. (HCD, Site
Inventory Handbook, June 10, 2020, pp, 11-18.16) The site inventory further clarifies that “Low and Very Low RHNA capacity has been attributed to sites that meet the suitability criteria outlined in State law, including parcel size, location, and zoning. Infill sites that do not meet the established suitability criteria are assumed to develop with market rate permitted under City zoning regulations and
as such do not represent a realistic
projection of capacity based on past
performance as required under Government
Code Section 65583.2(c). Therefore, the
conclusion on page 4-22 of the DEIR that
the Relocated Housing Growth Alternative
would not meet the City’s RHNA
obligations is valid and correct.

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housing and that capacity has been assigned to above
moderate income households. However, the City has adopted an Inclusionary Ordinance which requires that 20 percent of new units in projects of six or more units be affordable to moderate and low income households and through Program
2-I in the Housing Action Plan (Chapter 4), the ordinance will be revised to specify that 10 percent of the units provided must be affordable to moderate income households and 10 percent must be affordable to low income households.

Accordingly, 10 percent of the total above moderate infill development capacity has been reallocated to moderate
income RHNA, and 10 percent to lower income RHNA.”
(Housing Element, p. 3-29.) In short, any parcel identified for lower income units in the Site Inventory can be assumed to meet the criteria for lower income units. Following these criteria, and based on the assumed permitted densities at various sites, the Site Inventory determines that 973 lower income units can be provided at North Fremont Street,
Lighthouse Avenue, Del Monte Avenue, Garden Road, Pacific Avenue, Munras Avenue, and Abrego Street areas. For
example, the Site Inventory assumes that the Garden Road area would be zoned to permit 50 units per acre and then calculates that, at this density, 515 lower income units could be developed. (Housing Element, p. 3-15.) If the allowed density of these units were increased from 50 to 60 units per acre, i.e., a 20% density increase, then the number of lower income units on the same areas already assumed to meet the criteria to accommodate lower income units could be
increased 20%, i.e., 103 units. The table below applies the percentage increases in allowed density to each of the five areas that would be upzoned in the Relocated Housing
Alternative. The table demonstrates that, if the various densities assumed for the areas already identified as eligible for lower income units were increased to 60 units per acre, an additional 388 lower income units could be provided.

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can be seen to provide 388 more lower income units than the proposed project, the upzoning would more than
compensate for the elimination of Fort Ord housing. An
additional benefit of the upzoning is that it would provide more moderate income and above moderate income units as well.

B2-43 LandWatch 3/21/24 The Housing Element overcounts potential affordable units at Fort Ord because it mischaracterizes the inclusionary
housing ordinance and ignores site development constraints that cannot be resolved in the 6th Cycle. The Housing
Element claims that 220 of the 1,660 units proposed for Ryan Ranch/Fort Ord would be made available to lower income
families and 220 made available to moderate income families “consistent with the City’s inclusionary ordinance.” (Housing Element, p. 3-19.) This is inaccurate. As set out in proposed Program 2-I, the current and planned inclusionary housing ordinance only mandates 20% of total units be made
affordable, 10% for lower income and 10% for moderate
income units. (Housing Element, p. 4-14.) Thus, of the 1,660 total units planned for Ryan Ranch/Fort Ord, at most 166 would be required to be made affordable to lower income households, and at most 166 made affordable to moderate income households – not the 220 lower income and 220
moderate income units. Furthermore, counting all of these 166 lower income units and 166 moderate income units in Fort Ord toward the 6th Cycle RHNA is inconsistent with the admission in the Housing Element that at most 240 total units could be developed before 2031 due to water supply constraints and the timeline for remediation of hazardous materials. (Housing Element, pp. 2-14 to 2-15.) Under the inclusionary housing ordinance, only 10% of the units or 24 units must be affordable to lower income households and only 10% or 24 units must be affordable to moderate income households. Thus, the Housing Element overcounts affordable units by 196 units (220 counted units less the 24 units actually required and feasible in the 6th Cycle). The 196-unit overcount of lower income units exceeds the 161-unit buffer The City notes that LandWatch urges
certification of the EIR on the basis of the
Relocated Housing Alternative. The assertion
that the analysis of biological resources and
water supply in the DEIR is inadequate and
the recirculation is required is inaccurate.

Please see Master Response MR-2 regarding
water supply and responses to comments
B2-5, B2-6, B2-7, B2-14, B2-15, and B2-20
through B2-30 above with respect to the
adequacy of the analysis of water supply and
demand in the DEIR. Please see responses to
comments B2-3, B2-9, and B2-31 through
B2-37 regarding the adequacy of the analysis
of impacts to biological resources in the
DEIR.

With respect to the comment that the DEIR
"overcounts potential affordable units at
Fort Ord," the City notes that this comment
does not pertain to the adequacy of the
environmental analysis and that accordingly
no further response is required.

Nevertheless, the City notes that this
assertion is incorrect. Program 1-H in the
proposed Housing Element calls for the
incorporation of incentives to ensure that a
minimum percentage of the new housing
units will be affordable to moderate and
lower income households given that the City
is the property owner. The Proposed Plan
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or surplus of units over the RHNA requirement for lower income units. (Housing Element, p. 3-30, Table 3-4.) The 196- unit overcount of moderate income units also exceeds the 44 unit buffer for moderate income units. Thus, the proposed project would fail to provide sufficient affordable units, whereas the Relocated Housing Alternative would provide them. In conclusion, LandWatch urges the City to adopt the Relocated Housing Alternative to better meet its RHNA
obligations and to minimize significant environmental impacts.

If the City chooses not to adopt this alternative, it must revise and recirculate the draft EIR to correct the flaws discussed above in the analysis of biological and water supply impacts caused by developing housing on Fort Ord land.
does not rely solely on adopted inclusionary
zoning requirements to achieve that
objective.

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C1-1 Weinstein,
Beth
3/4/24 I have concerns with both projects, and the
cumulative effects in what was always designated a
rural/scenic area. Appreciate the additional
information.

We are nearby residents of the proposed housing
project for 640 units off Highway 68 currently
owned by the Monterey Peninsula School District.

As outlined on page 5-6 in CEQA Required Conclusions, the DEIR did consider cumulative impacts on designated scenic areas. The 2005 General Plan Urban Design Element includes numerous policies to preserve and enhance scenic resources within the Planning Area. New development within the Planning Area would primarily be focused in the previously developed areas, although the 50-acre MPUSD site within the Highway 68 Area Plan
boundary is vacant. Implementation of proposed Housing Element Program 1-I would involve standards to integrate the new housing on the MPUSD site in a context-sensitive manner. Therefore, in combination with 2005 General Plan Urban Design Element policies and implementation of Program 1- I, the Project would not substantially degrade scenic resources and cumulative impacts would be less than significant. Please see also Master Response MR-1 regarding cumulative development in the southeast and south Monterey.

C1-2 Weinstein,
Beth
3/4/24 Does anyone care about the cumulative effects of all these developments on an area that already is
struggling with traffic and was designated a scenic
corridor? Many of us moved to this area to escape
the urbanization and densification in other parts of
California. While I support the need for additional
residential development that is affordable to ensure
hard working people can afford to live and work in
Monterey County, several of the proposed sites are
of particular concern especially given the high
density.

Please see Master Response MR-1 regarding cumulative
development impacts on scenic resources in the southeast and south Monterey.

An assessment of impacts on traffic congestion is no longer required under CEQA and thus, not incorporated into the DEIR.

With the passage of SB 743 (September 27, 2013) and the subsequent adoption of revised CEQA Guidelines in 2019, level of service (LOS) can no longer be used as a criterion for identifying significant transportation impacts for most projects under CEQA.

LOS measures the average amount of delay experienced by vehicle drivers at an intersection during the most congested time of day, while the new CEQA metric (vehicle miles traveled, or VMT) measures the total number of daily miles traveled by vehicles on the roadway network and the impacts on the environment from those miles traveled. See Chapter 3.13 of the DEIR regarding transportation impacts.

C1-3 Weinstein,
Beth
3/4/24 The two I especially object to are the County's
1324 units being proposed off Olmstead Rd and
the city of Monterey's 640 units being proposed for
As outlined on page 3.10-10, the 50-acre Monterey Peninsula Unified School District (MPUSD) site is within the Highway 68 Area Plan which was adopted in 1984. The plan claims a maximum ATTACHMENT 1 / EXHIBIT A
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land that was previously designated for education.

Both of these projects violate the State of
California's desire for infill on already developed
land and pose significant risk, including:
of 3,550 dwelling units will be permitted in the Monterra, Laguna Seca, and Aguajito areas. Specifically, for the MPUSD 50-acre site, the Highway 68 Area Plan calls for the development of 300 lowincome and moderate-income housing units. As such the proposed development at the site is consistent with previous City planning efforts.

This comment pertains to the Proposed Plan and is not related to the adequacy of the DEIR; thus, no further response is required.

C1-4 Weinstein,
Beth
3/4/24 *Traffic on Olmstead Road and Highway 68,
including the proposed roundabout: It can be
estimated that Monterey's proposed development
could generate up to 1600 extra cars per day and
the County's project 3250 extra cars per day. This
would be approximately 5000 more cars in an area
already dense with traffic and backups, especially
during commute windows. The assumption is 2.5
car trips per housing unit per day). The expansion
of the airport facilities and new apartments on
Garden Rd and proposed housing on South
Boundary Rd and the current courthouse off
Aguajito Rd. would make traffic even worse.

Enormous costs of widening Hwy 68 would be paid
for by taxpayers. There is currently no mass transit
in the area. What is the plan to mitigate the impact
of all this
extra traffic?
First, it should be noted that under the California Environmental Quality Act (CEQA), traffic volume or level of service (LOS) can no longer be used, pursuant to Senate Bill 743 (Steinberg, 2013) as codified in Public Resources Code section 21099, which required changes to the guidelines implementing CEQA (CEQA Guidelines) (Cal. Code Regs., Title 14, Div. 6, Ch. 3, § 15000 et seq.) regarding the analysis of transportation impacts. With the California Natural Resources Agency’s certification and adoption of the changes to the CEQA Guidelines, automobile delay, as measured by “level of service” and other similar metrics, no longer constitutes a significant environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3).). The Technical Advisory by OPR outlines VMT (vehicle-miles traveled) as the metric to be used for transportation analysis under CEQA. See also page 3.13-8 of the EIR for further detail.

Second, for the DEIR, an analysis of VMT in the Planning Area was conducted for conditions without and with the Proposed Plan by a California traffic engineering firm, Kimley-Horn. The most recent version of the Association of Monterey Bay Area Governments Travel Demand Model (AMBAG RTDM) was used to estimate
VMT efficiency metrics across all land uses. The AMBAG TDM has a base year of 2015 and a future year of 2045. The model’s 2045 cumulative year includes growth that is consistent with adopted general plans within Monterey County and with regional
projections contained in the 2045 Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS). As such, the City’s Housing Element and all Housing Elements in the County, including Monterey County, inform the model’s 2045 cumulative year.

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Lastly, as detailed on page 3.13-22 of the DEIR, increased development in the Planning Area would generate additional vehicle trips on the local and regional roadway network, where employment-based land uses have a potentially significant impact.

As such, the Proposed Plan incorporates strategies to promote the development of mixed use villages and transit-oriented development within the City limit, including proposed Land Use Element policies A.1, A.2, and A.4, as well as policies involving coordination with MST to support transit use, including Circulation Element policies E.3, E.5, E. 6, and E.7.). In addition, Mitigation Measure VMT-1 is required to reduce the total VMT per service population generated by typical uses in the Planning Area through the adoption of an Employee Commute Trip Reduction Project and would reduce the magnitude of the impact. However, the effectiveness cannot be accurately estimated for the expected developments in the Planning Area, because the detailed characteristics of these future development and/or the specific strategies implemented by these future developments cannot be known at this time. Thus, this DEIR conservatively assumes that these impacts would be significant and unavoidable. In addition, see page 3.3-48 of the EIR for an assessment of carbon monoxide hot spots due to increased vehicle congestion.

C1-5 Weinstein,
Beth
3/4/24 *Environmental impact and vanishing Greenbelt:

The removal of this greenbelt is a significant
adverse impact aesthetically and a huge contrast
from the scenic easement that gives this area such
a special character. It is also a loss of habitat for
many keystone animal species that can be observed
on the subject parcel. Frequent observations occur
of Apex/keystone species such as Mountain Lion,
Bobcat and Coyote as well as many avian species of
special interest. Does the County understand the
implications of eliminating
this biological corridor? The current residential
zoning in this area is one home per 10 acres to
allow for new residential development, while still
preserving the rural character of this beautiful area.

As outlined on page 3.1-19 in Aesthetics, the DEIR did consider impacts on designated scenic vistas and corridors in the Planning Area. The 2005 General Plan Urban Design Element includes numerous policies to preserve and enhance scenic vistas and corridors within the Planning Area. New development within the Planning Area would primarily be focused in the previously developed areas, although the 50-acre MPUSD site within the Highway 68 Area Plan boundary is vacant. Implementation of proposed Housing Element Program 1-I would involve standards to integrate the new housing on the MPUSD site in a contextsensitive manner. Therefore, in combination with 2005 Urban Design Element policies and implementation of Program 1-I, the Project would not substantially degrade scenic vistas and corridors and impacts would be less than significant. Please see also Master Response MR-1 regarding cumulative development in the
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How does such a high density (10-20 units per
acre) fit into this environment? I don't understand
how a designated scenic corridor can be turned
into a high density set of houses and roads. That is
not in the spirit of what California state criteria is
for affordable housing.
southeast and south Monterey.

Additionally, the DEIR did consider impacts on special-status species in the Planning Area. Pursuant to data from the California Department of Fish and Wildlife, special-status animal species with the potential to occur in the Planning Area are outlined in Table

3.4-2. As detailed on page 3.4-24, development could contribute to the loss of natural lands in the Planning Area, with potential effects on special-status species. However, impacts would be reduced with implementation of Mitigation Measures BIO-1 through BIO-12, which would ensure the protection of special-status plant and animal species. With implementation of Mitigation Measures BIO-1 through BIO-12 and compliance with federal, state, and local regulations, the Plan’s contribution to biological resources impacts would be less than significant.

C1-6 Weinstein,
Beth
3/4/24 *Pedestrian and Bicycle safety: It is not clear the roads in and out of the 640 unit housing complex
since there would need to be at least one
additional road for entry in and out. Is this also
going to be onto Olmstead Road through the
County's
development? Olmstead Rd would go from a quiet
rural road to a very busy urban one. What is the
plan for pedestrian and bike safety with a high
volume of cars coming in and out onto Olmstead
on both sides of the street? Are you planning to
access the development directly from Highway 68?
This would also pose significant safety risks.

As outlined in page 3.13-17, the DEIR did consider impacts to pedestrian and bicycle safety. The proposed Circulation Element sets out a list of guidelines and considerations for Complete Streets in the City’s multimodal plan, which would maximize safety through design (Policy b.6), aligning with Move Monterey’s strategy to examine projects impact on safety for pedestrians and bicyclists.

Further, the proposed Circulation Element also requires development projects to provide on-site facilities such a bicycle parking and showers, to dedicate land to expand existing facilities or provide new facilities such as sidewalks/multi-use paths and/or bicycle lanes, and to ensure projects are designed to be efficiently served by bike routes and pedestrian connections (Policy c.9). As a result, the Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, particularly bicycle and pedestrian facilities, and the impact would be less than significant.

C1-7 Weinstein,
Beth
3/4/24 *Flight Crash Risk. 2 years ago, there was a crash into an unoccupied single family home in the
Monterra neighborhood. If such an incident were
to occur in a high density community, there could
be a substantial loss of life. Similar incidents have
As outlined in page 3.8-30, the DEIR did consider the impacts of airport proximity. Future development under the Plan would be required to comply with the safety zone land use compatibility standards in Table 4B Safety Criteria Matrix of the ALUCP in order to protect and promote the safety and welfare of residents and ATTACHMENT 1 / EXHIBIT A
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occurred in California (i.e. Truckee with a private
jet, as well as Naples FLA recently). Has the city of
Monterey and County consulted with Monterey
Regional Airport on the flight crash risk specific to
the subject property?
airport users. The Safety Criteria Matrix establishes maximum densities, intensities, prohibited uses, and other development conditions for proposed development within the ALUCP safety zones so as to restrict the development of land uses that could pose particular hazards to the public or to vulnerable populations in case of an aircraft accident. Further, the proposed Land Use Element includes policies to minimize airport safety hazards and promote compatibility with airport operations, including Policy C.1 which requires that new development be compatible with the standards for land uses, density, and intensity specified in ALUCP for the Monterey Regional Airport. Therefore, compliance with the ALUCP and implementation of the Plan would reduce airport safety hazards potentially resulting from new development to the maximum extent practicable. Associated impacts would be less than significant.

C1-8 Weinstein,
Beth
3/4/24 *Fire Protection. This development would come
with extraordinary expense of added fire response
personnel and equipment. This is compounded by
traffic jams adding to response times. Additionally,
one of the important functions of the existing
greenbelt zoning gives the entire community an
important firebreak. CALFIRE depends on this
parcel for fire protection of this whole region.

These parcels were an important staging area for
firefighters during the last fire just three years ago
and we would lose that critical capability if this land were to be developed. Does the city of Monterey
and County comprehend the magnitude of
additional risk of wildfire this abandonment of
firebreak will produce, given the forest densities to
the east and west? Is the city of Monterey and
County prepared to assume liability for a future
wildfire disaster, which could have been prevented
by preservation of this critical firebreak? Has the
County consulted with CALFIRE on the details of
As outlined in page 3.12-19, the DEIR did consider the impacts of fire and emergency services. The MFD does not have plans to increase staffing or equipment levels over the next eight years.

Current staffing and equipment levels provide an adequate number of staffing for fires, medical, or rescue situations and would be sufficient to handle the potential increase in incidents in infill areas with buildout of the Plan. However, fire and emergency medical response services are currently provided to the eastern portion of the city from Station 16, which is leased from the Monterey Airport District and it isn't well suited to provide increased services to that portion of Monterey. As such, a dedicated Cityowned fire station would likely be needed to serve that area.

While the location and design of this facility cannot be known at this time, the construction of the facility could potentially result in environmental impacts. Therefore, implementation of Mitigation Measure PF-1 is required, and would reduce the potential environmental impacts associated with construction of the fire station to the maximum extent practicable. Therefore, at a programmatic level, impacts would be less than significant with mitigation.

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how this firebreak is vital to community safety
along the entire Hwy 68 corridor?
C1-9 Weinstein,
Beth
3/4/24 *Police Protection. This proposed rezoning will
place an untenable burden on our existing police
resources, which already are in critical shortage.

This is not only a public safety threat, but also an
extraordinary economic impact by placing 3000
new residents with the county's Olmstead
development and ~1500 with Monterey's
development in locations, which are not even
conveniently serviced for the
expected demand level. Has the Monterey County
sheriff been consulted and are they prepared to
handle this high density loading and increased risk?
As outlined in page 3.12-19, the DEIR did consider the impacts of police protection services. The Monterey Police Department (MPD) is able to adjust staffing to be appropriate with population levels in order to maintain standards of service. MPD has existing plans in place to increase staffing over the next five to ten years. MPD and MFD have plans to develop a new joint public safety facility. The planned facility would be sufficient to accommodate increased MPD staffing and equipment needed to accommodate the increase in calls for service anticipated with buildout of the Plan. Therefore, impacts would be less than significant.

C1-10 Weinstein,
Beth
3/4/24 *Air Quality. The additional traffic, especially considering the projected congestion and idling, will
cause significant deterioration in local air quality,
both to onsite residents of the new development
and to nearby existing populations. The specific
pollutants of public health concern are sulfur
dioxide, oxides of nitrogen, carbon monoxide and
carbon fibre from tyres. Is the County aware that
approximately 20,000 deaths per annum occur in
the United States from these air pollutants? How
will this be mitigated for current and future
residents?
As outlined on page 3.3-51, the DEIR did consider impacts of local air quality and sensitive receptors. Although it is unknown what specific sources would be installed or where they would operate, all new stationary sources would be subject to the permit authority of the Monterey Bay Air Resources District (MBARD), and review of new sources are subject to Best Available Control Technology (BACT) requirements. These regulatory mechanisms would ensure that cancer and health hazard impacts from stationary sources developed under the future projects would be less than significant. However, they may not be sufficient to address PM impacts if the source results in significant PM concentrations, especially given the existing nonattainment status for PM10 and the expected increase in PM emissions due to the Proposed Plan.

MM-AQ-1 is therefore required to provide a project-level evaluation of construction- and operational-related health risks from future projects within 1,000 feet of sensitive receptors.

Mitigation Measures MM-AQ-2 through MM-AQ-4 would reduce CO, diesel, and PM (exhaust and fugitive dust) emissions during construction activities. MM-AQ-5 would reduce TAC and localized CO and PM exposure to future sensitive receptors but not for receptors at land uses that have already been constructed. MMAQ-6 requires air quality equipment to minimize health risks but ATTACHMENT 1 / EXHIBIT A
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would not apply to existing sensitive receptors that are present before new construction or operational activity commences.

Therefore, after mitigation, this impact would be significant and unavoidable.

C1-11 Weinstein,
Beth
3/4/24 *Quality and Availability of Water: If the
moratorium on drilling wells is lifted, is there data
to support that the onsite wells can provide
sufficient healthy ground water for over 3000 new
residents for the County development and ~1500
for the Monterey city development without being a
detriment to the current ground water supply? It is
well established that there are a number of
carcinogenic and toxic chemicals in the
groundwater emanating from Fort Ord. It is also
known that this subsurface water plume is
presently moving in the direction of the proposed
rezoning parcel, if not already present beneath the
subject parcel. This is a serious threat to residents
of the subject parcels, particularly to children who
will predictably explore the soils of their
neighborhood. See for example: Cancer cluster at
Fort Ord: Sick vets wonder, are there more of us?
(thecalifornian.com) . Thank you for including my
input. I would encourage you to look at using ADUs
and other infill strategies using land that has already been developed and is not being fully utilized, such
as empty lots next to MPC and Casa Verde, the old
courthouse and hospital, as well as parcels around
Cannery Row.

As outlined in page 3.14-26, the DEIR did consider impacts of water supply. The MCWD projects that available groundwater supply from the Salinas Valley Groundwater Basin will be sufficient to meet demand in its service area through 2040. Further, MM UTIL-2, involving actions to expand MCWD supply, is required. To meet additional future demands, the MCWD 2020 UWMP
provides that reactivation of the MCWD pilot seawater
desalination plant could potentially add 300 AFY of additional supply. Further, to provide additional water to meet future demand when it materializes, the MCWD 2020 UWMP states Phase 2 of the Pure Water Monterey Expansion Project is anticipated to deliver additional water to the Seaside Basin. See also Master Response MR-2 regarding water supply.

Regarding hazardous materials, as outlined on page 3.8-27, none of the parcels identified for housing are in need of remediation or disposal of hazardous waste. The northernmost parcel (APN 031- 191-018-000, referred to as parcel E29.1) within the City limit at Fort Ord has been cleared of unexploded ordnance (UXO) to a level that permits light industrial uses, but not residential uses.

UXO are mostly encountered on former military sites. Additional remediation would be required prior to residential development on the site. As such, the parcel has been excluded as a site in the Housing Element. Prior to issuance of a building permit for residential or mixed-use development on the parcel, the City shall require documentation demonstrating that soil and water on the parcel have been remediated consistent with the Residential Quality Assurance (RQA) process (or equal) and that the residential restriction has been removed by DTSC. Therefore, implementation of Mitigation Measure HAZ-1 is required to ensure adequate remediation in coordination with the U.S. Army, U.S. EPA, and DTSC before development occurs. Implementation of MM-HAZ-1 would make this impact less than significant. The remainder of the comment pertains to the Proposed Plan and is ATTACHMENT 1 / EXHIBIT A
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not related to the adequacy of the DEIR; thus, no further response is required.

C2-1 Turner, Liz 3/16/24 I am writing to provide you with my comments regarding the Draft EIR for the Monterey 2031
General Plan Update.

The proposed housing plan for the City of
Monterey includes developing a 50 acre parcel on
Highway 68. Developing this parcel would have a
significant negative impact on the Highway 68
Scenic Corridor and on the environment, in
general, especially as it would increase traffic
congestion on Highway 68 and the surrounding
rural roads. The parcel is in an area that is labeled
as a “highly sensitive viewshed.” There has already
been extensive development in the Highway 68
Scenic Corridor as evidenced by the airport
runway extension, the Highway 68 car condos, and
the Montage Ohana building that was inexplicably
allowed to loom over the highway. At least, the
south side of the highway has maintained a scenic
rural character. If that is now developed, the
designation of Highway 68 as a scenic corridor
would be in jeopardy.

Please see response to comment C1-5 regarding aesthetic and biological resource impacts in southeast and south Monterey.

C2-2 Turner, Liz 3/16/24 PROPOSED PLAN BASED ON UNREALISTIC

PROJECTIONS
The Proposed Plan outlined in the City of
Monterey document is based on what seem to be
unrealistic projections of population growth and
corresponding housing needs. The population of
Monterey has actually decreased by 2.2% over the
past 3 years and is projected to continue to
decrease. The source of these projections, AMBAG,
states that employment drives growth, but
projected employment growth does not support
the numbers used as the basis for the proposed
housing development plan. The
As detailed on page 3.10-9 of the DEIR, the California Department of Housing and Community Development (HCD) determines the regional need based on population projections and other factors including rates of vacancy, overcrowding, and cost burden.

Population projections and other factors are required to distribute the region’s share of statewide need to cities and counties within its jurisdiction. The Association of Monterey Bay Area
Governments (AMBAG) is responsible for adopting the Regional Housing Needs Allocation. The AMBAG Board adopted 3,654 on many factors including anticipated growth needs, fair housing considerations, etc. The City is required to plan for this adopted growth. The City does not have an opportunity at this time to dispute these numbers in order to comply with State Housing law.

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Proposed Plan assumes that, by 2031, employment
in Monterey will grow by 8.3%, but population will
grow by 37.6%, and somehow that necessitates a

41.9% growth in housing units. For each new job, it
is proposed that approximately five people will
move to Monterey. Is population growth outpacing
employment growth due to the birth rate and/or
due to the number of unemployed (potentially
retired) people expected to move to Monterey? If
it is the birth rate, it should be noted that children
live in the same housing unit as their parents so
there should not be a need for three times as many
housing units as new jobs, as is
proposed.

Please see Master Response MR-1 regarding cumulative
development impacts on scenic resources in the southeast and south Monterey.

C2-3 Turner, Liz 3/16/24 PROPOSED PLAN CONFLICTS WITH PROJECT

OBJECTIVES
The Proposed Plan, which includes development of
the 50 acre parcel on Highway 68, conflicts with six
of the specific objectives, or goals, for the project
as outlined in the report. Goal 1 states that the
plan should address the regional housing needs
(RHNA) but, as mentioned above, Monterey
appears to be planning for many more new units
than are necessary to meet projected needs. It
leads one to wonder if perhaps the Highway 68
parcel is included because an influential developer
would like to build on it at the
expense of the Highway 68 Scenic Corridor, the
environment, and the general enjoyment and
welfare of the community.

Population projections and other factors are required to distribute the region’s share of statewide need to cities and counties within its jurisdiction. The purpose of the RHNA is to allocate a share of the Monterey Bay Area’s projected housing need to cities and counties by household income group, categorized as “very low,” “low,” “moderate,” and “above moderate.” According to the Draft 2023–2031 RHNA, AMBAG has determined that Monterey’s share of regional housing need for the period from December 15, 2023 through December 15, 2031 would be 3,654 units. In addition, please see Master Response MR-1 regarding cumulative
development impacts on scenic resources in the southeast and south Monterey. The comment pertains to the Proposed Plan and is not related to the adequacy of the DEIR; thus, no further response is required.

C2-4 Turner, Liz 3/16/24 Goal 6 states that the City of Monterey should “ encourage new housing in locations supported by
existing or planned
infrastructure, while maintaining existing
As detailed on page 3.10-22 of the DEIR, Program 1-I involves amending the Highway 68 Area Plan to accommodate mixed
income housing on the 50-acre MPUSD site and incorporate infrastructure financing mechanisms. However, the comment ATTACHMENT 1 / EXHIBIT A
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neighborhood character.” There is no existing
infrastructure on the 50 acre Highway 68 parcel
and the neighborhood character is low density
residential and rural so the proposed plan does not
meet goal 6.
pertains to the Proposed Plan and is not related to the adequacy of the DEIR; thus, no further response is required.

C2-5 Turner, Liz 3/16/24 Goal 7, entitled “Maintain Existing Housing," states that the city wants to “assure high quality
maintenance, safety, and habitability of existing
housing resources.” If this is so, why not have
programs to rehabilitate and remodel existing
housing, especially in core areas of the city? If you
build an excess of new housing and significantly
increase vacancy rates and decrease rental rates, it
is well known that landlords will not be willing or
able to maintain existing properties. The result will
be some nice new buildings along Highway 68 while
the appearance of Monterey's central district
continues to degrade.

The Housing Element includes strategies to maintain and expand housing in the core areas of the City. Infill development strategies include Housing Element Programs 1-C, Specific Plan Updates, Program 1-D, Permit Streamlining Pilot Project, Program 1-E, Education Workforce Housing Overlay, Program 1-G, Surplus Municipal Parking Facilities, Program 2-E, Revise Parking Requirements, Program 2-L, Moratorium on Vehicle Storage, and Program 3-C, Local Density Bonus.The comment pertains to the Proposed Plan and is not related to the adequacy of the DEIR; thus, no further response is required.

C2-6 Turner, Liz 3/16/24 Goal 8 states that appropriate housing sites “are proximate to transportation, shopping and
schools…” This goal is in line with the State of
California’s goal to promote infill as a way to
promote sustainability and minimize negative
impacts on the environment. The parcel on
Highway 68 does not meet this goal. It is not infill
and would require residents to use cars to get to
work and for all errands. It is not on a major transit
route and it has a very low walk score.

As detailed on page 3.10-22 of the DEIR, Program 1-I involves amending the Highway 68 Area Plan to accommodate mixed
income housing on the 50-acre MPUSD site and incorporate infrastructure financing mechanisms. In addition, as detailed on page 3.10-17, the Proposed Plan incorporates numerous strategies to accommodate infill development and focus new growth so as to balance levels of employment and housing within the community to reduce commute times, improve air quality, and provide more opportunities for those who work in Monterey to live locally. Infill development strategies include Housing Element Programs 1-C, Specific Plan Updates, Program 1-D, Permit Streamlining Pilot Project, Program 1-E, Education Workforce Housing Overlay, Program 1-G, Surplus Municipal Parking Facilities, Program 2-E, Revise Parking Requirements, Program 2-L, Moratorium on Vehicle Storage, and Program 3-C, Local Density Bonus. As such, overall, implementation of the Proposed Plan would not conflict with regional, airport land use, or local plans, policies, or regulations ATTACHMENT 1 / EXHIBIT A
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adopted for the purpose of avoiding or mitigating an
environmental effect.

C2-7 Turner, Liz 3/16/24 Goal 12 states that the Proposed Plan should be consistent with the Airport Land Use Compatibility
Plan (ALUCP) yet
development of the 50 acre parcel blatantly violates
this stated goal. According to ALUCP, the parcel is
in Zone 3, where all residential development is
prohibited, except low density and infill in already
developed areas.

As outlined in page 3.8-30, the DEIR did consider the impacts of airport proximity. Future development under the Plan would be required to comply with the safety zone land use compatibility standards in Table 4B Safety Criteria Matrix of the ALUCP in order to protect and promote the safety and welfare of residents and airport users. The Safety Criteria Matrix establishes maximum densities, intensities, prohibited uses, and other development conditions for proposed development within the ALUCP safety zones so as to restrict the development of land uses that could pose particular hazards to the public or to vulnerable populations in case of an aircraft accident. Further, the proposed Land Use Element includes policies to minimize airport safety hazards and promote compatibility with airport operations, including Policy C.1 which requires that new development be compatible with the standards for land uses, density, and intensity specified in ALUCP for the Monterey Regional Airport. Therefore, compliance with the ALUCP and implementation of the Plan would reduce airport safety hazards potentially resulting from new development to the maximum extent practicable. Associated impacts would be less than significant.

In addition, page 3.11-27 of the DEIR states that portions of the Fort Ord opportunity area and the 50-acre MPUSD parcel south of Highway 68 are within Airport Safety Zone 3, which prohibits all residential except for low density residential and infill in developed areas. However, the proposed Land Use Element establishes a new Airport Compatibility Overlay (AC-O) that applies to properties in airport safety zones 1 through 6 as identified in the Monterey Regional Airport Land Use Compatibility Plan (ALUCP) in order to protect airport operations and ensure public safety. Existing uses are permitted to continue on sites within the AC-O, and new development and expansion of existing uses shall only be permitted where the compatibility criteria or the infill exemption criteria of the ALUCP can be met. Further, Program 1-H and Program 1-I of the proposed Housing Element would also help ensure compatibility with the ALUCP, requiring future land uses ATTACHMENT 1 / EXHIBIT A
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planned on the Fort Ord property and the Highway 68 Area Plan boundaries that are within the Monterey Regional Airport Influence Area to be compatible with the ALUCP. As such, no conflicts with ALUCP zones would result.

C2-8 Turner, Liz 3/16/24 Goal 9 states that the Proposed Plan should “support a vibrant local economy.” This goal is what
is used to promote the Proposed Plan over the
“Increased Workforce Alternative Plan.” The City of
Monterey report states that the Increased
Workforce Alternative Plan is environmentally
superior to the Proposed Plan as it avoids
significant and unavoidable impacts to agricultural
resources and air quality. However, the City of
Monterey rejects the Increased Workforce
Alternative Plan because it does not support local
economic vitality to the same extent as the
Proposed Plan does. This is in direct contradiction
to the stated facts! Goal 9, which discusses
economic vitality, states that there should be a
balance of jobs and housing so that those who
work in Monterey can afford to live in Monterey
but the report also states that with the Proposed
Plan, low wage hospitality and tourism workers
would increase their vehicle miles traveled (VMT).

So isn’t the Increased Workforce Alternative Plan
better for low wage workers, better for the
environment, and better for everyone else as it
reduces traffic congestion and air pollution and
maintains the scenic beauty
of the Highway 68 Corridor?
The Increased Workforce Housing Alternative was not rejected in the DEIR. It was carried forward as a potentially feasible alternative for an analytical comparison of its impacts with those of the Proposed Plan. The DEIR noted that this Alternative would not meet the project objectives as well as the Proposed Plan, and there was no indication of market demand to accommodate the proposed number of housing units. Given that the Ryan Ranch Business Park is a major employment center for the city, the lack of development under the Highway 68 Area Plan would not support the needs of nearby employment centers. Further, many of the sites identified under this Alternative for lower income RHNA do not meet the requirements established for such sites in State law. The City Council will make the ultimate decision regarding the actual feasibility of all of the alternatives analyzed in the DEIR when it considers whether to certify the Final EIR and approve the Proposed Plan. The remainder of the comment pertains to the Proposed Plan and is not related to the adequacy of the DEIR; thus, no further response is required.

C2-9 Turner, Liz 3/16/24 Finally, why not embrace a hybrid plan? Development of the land on South Boundary Rd, as
described in the Proposed Plan, makes sense as it’s
within walking distance of jobs at Ryan Ranch. Why
not implement part of the Increased Workforce
Alternative Plan but also develop housing along
The comment pertains to the Proposed Plan and is not related to the adequacy of the DEIR; thus, no further response is required in this document. Comments related to the content of the Proposed Plan will be considered by City decision-makers at adoption hearings.

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Boundary Rd? Boundary Rd. is not part of a
recognized scenic corridor and would be much less
likely to add to traffic congestion on Highway 68. In
keeping with the State of California’s guideline for
higher density units that are infill, the City of
Monterey could modernize and further develop
areas that could use revitalization without
destroying the natural beauty and rural character
that attracts tourists to visit and retirees to
relocate to the Monterey Peninsula.

C3-1 Behl,
Robert
3/19/24 My wife and I are active members of the Monterey City Community, despite currently living in
Monterra. For well over 20 years, we owned a
home in the city, before we were able to afford
something more rural, but close to our many Citycentric activities like volunteering at the Aquarium, etc. The proposed high-density housing adjacent to
our new home is, of course concerning, but we are
trying hard not to be NIMBYs, as we understand
the need for additional housing.

We do not oppose lower-density, careful
development that maintains Highway 68 as a scenic
corridor, with adequate spacing from both the
Highway and neighbors and maintaining firebreak
and passage for wildlife.

However, we are deeply concerned about the
infrastructure needed to support both the County
and the City’s proposals. Who is going to pay for
water, sewer, and highway improvements required
to make the proposed number of homes viable.

Analysis regarding utility and transportation improvements is included in Chapters 3.13 and 3.14 of the DEIR. Please see also Master Response MR-1 regarding cumulative development in the southeast and south Monterey. The remainder of the comment pertains to the Proposed Plan and is not related to the adequacy of the DEIR; thus, no further response is required.

C3-2 Behl,
Robert
3/19/24 We are particularly concerned about water
availability. Currently Canada Woods Water serves
several local communities from the local aquifer.

This aquifer already is experiencing salt water
intrusion, requiring expensive reverse-osmosis
desalination.

Please see Master Response MR-2 regarding water supply impacts of the Proposed Plan and cumulative impacts.

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In recent meetings the airport has brought up that
they will require significant additional water from
their two wells in the same aquifer, to support the
terminal improvement project. Additionally, the test
wells on the proposed County parcel have also had
significant water quality problems from the same
aquifer, without continuous drawing of water for
more than a possible 1000 new homes. If the City
were to use substantial amounts of well water for
their development, in addition to the already highly
endangered supply, the results could be disastrous
for everybody.

C3-3 Behl,
Robert
3/19/24 Secondly, the existing wastewater infrastructure, is very likely not going to be sufficient to support the
expanded airport, re-development of Garden Road,
and the proposed County development. It certainly
will not support many hundreds of additional
homes along highway 68.

As stated on page 3.14-31 of the DEIR, implementation of the Proposed Plan would require the construction and extension of public sewer and stormwater conveyance infrastructure to areas not currently served by existing facilities, including the 50-acre MPUSD site in the Highway 68 Plan area and portions of Fort Ord.

Construction or expansion of infrastructure to these areas could potentially result in environmental impacts. Construction period impacts are analyzed at a programmatic level throughout this Draft EIR. While construction period impacts related to soil erosion and noise can be mitigated to a less than significant level, construction period impacts related to air quality, biological resources, cultural and tribal cultural resources, energy and greenhouse gas emissions would remain significant and unavoidable even after
implementation of all feasible mitigation measures.

C3-4 Behl,
Robert
3/19/24 Finally, commuters bypassing the Highway1/68
exchange, especially in the evening commute, are
already pushing Olmsted Rd beyond capacity, and
putting pressure on the troubled
Olmsted/impacted 68 intersection. With added
pressure from redeveloped homes on Garden
Road, increased airport traffic, and Olmsted homes
per the County plan, that intersection will be a
nightmare, blocking
commuters from new City homes, even if it
Please see Master Response MR-1 regarding cumulative
development impacts on scenic resources in the southeast and south Monterey.

As detailed on page 3.13-8 of the EIR, an assessment of impacts on traffic congestion is no longer required under CEQA and thus, congestion is not analyzed in the DEIR. With the passage of SB 743 (September 27, 2013) and the subsequent adoption of revised CEQA Guidelines in 2019, level of service (LOS) can no longer be used as a criterion for identifying significant transportation impacts ATTACHMENT 1 / EXHIBIT A
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eventually has a traffic circle installed. To solve this, may require four-lanes on 68, all the way up to
Ryan Ranch, and some sort of cloverleaf/mergelanes at Olmsted. Very expensive, and certainly not a “Scenic Highway” entrance to Monterey.
for most projects under CEQA. LOS measures the average
amount of delay experienced by vehicle drivers at an intersection during the most congested time of day, while the new CEQA metric (vehicle miles traveled, or VMT) measures the total number of daily miles traveled by vehicles on the roadway network and the impacts on the environment from those miles traveled. See Chapter 3.13 of the DEIR regarding transportation impacts. In addition, see page 3.3-48 of the EIR for an assessment of carbon monoxide hot spots due to increased vehicle congestion.

C3-5 Behl,
Robert
3/19/24 We really think that higher density infill and
development closer to existing infrastructure, jobs,
shopping, etc makes a whole lot more sense for
everybody, especially for those future homeowners.

That also comes closer to the state mandates for
housing which does not intend creation of an
isolated development, divorced from the existing
community.

Thank you for considering our input in these
matters,
The comment pertains to the Proposed Plan and is not related to the adequacy of the DEIR; thus, no further response is required in this document. Comments related to the content of the Proposed Plan will be considered by City decision-makers at adoption hearings.

C4-1 Benzing, Jeff 3/16/24 I am writing to provide you with my comments regarding the Draft EIR for the Monterey 2031
General Plan Update.

The proposed housing plan for the City of
Monterey includes developing a 50 acre parcel on
Highway 68. Developing this parcel would have a
significant negative impact
on the Highway 68 Scenic Corridor and on the
environment, in general, especially as it would
increase traffic congestion on Highway 68 and the
surrounding rural roads. The
parcel is in an area that is labeled as a “highly
sensitive viewshed.” There has already been
extensive development in the Highway 68 Scenic
Corridor as evidenced by the
airport runway extension, the Highway 68 car
condos, and the Montage Ohana building that was
Please see response to comment C1-5 regarding aesthetic and biological resource impacts in southeast and south Monterey.

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inexplicably allowed to loom over the highway. At
least, the south side of the
highway has maintained a scenic rural character. If
that is now developed, the designation of Highway
68 as a scenic corridor would be in jeopardy.

C4-2 Benzing, Jeff 3/16/24 PROPOSED PLAN BASED ON UNREALISTIC

PROJECTIONS
The Proposed Plan outlined in the City of
Monterey Document is based on what seem to be
unrealistic projections of population growth and
corresponding housing needs. The population of
Monterey has actually decreased by 2.2% over the
past 3 years and is projected to continue to
decrease. The source of these projections, AMBAG,
states that employment drives growth, but
projected employment growth does not support
the numbers used as the basis for the proposed
housing development plan. The Proposed Plan
assumes that, by 2031, employment in Monterey
will grow by 8.3%, but population will grow by

37.6%, and somehow that necessitates a 41.9%
growth in housing units. For each new job, it is
proposed that approximately 5 people will move to
Monterey. Is population growth outpacing
employment growth due to the birth rate and/or
due to the number of unemployed (potentially
retired) people expected to move to Monterey? If
it is the birth rate, it should be noted that children
live in the same housing unit as their parents so
there should not be a need for 3 times as many
housing units as new jobs, as is proposed.

As detailed on page 3.10-9 of the DEIR, the California
Department of Housing and Community Development (HCD)
determines the regional need based on population projections and other factors including rates of vacancy, overcrowding, and cost burden. Population projections and other factors are required to distribute the region’s share of statewide need to cities and counties within its jurisdiction. The Association of Monterey Bay Area Governments (AMBAG) is responsible for adopting the Regional Housing Needs Allocation. The AMBAG Board adopted 3,654 on many factors including anticipated growth needs, fair housing considerations, etc. The City is required to plan for this adopted growth. The City does not have an opportunity at this time to dispute these numbers in order to comply with State Housing law.

Please see Master Response MR-1 regarding cumulative
development impacts on scenic resources in the southeast and south Monterey.

C4-3 Benzing, Jeff 3/16/24 PROPOSED PLAN CONFLICTS WITH PROJECT

OBJECTIVES
The Proposed Plan, which includes development of
the 50 acre parcel on Highway 68, conflicts with six
of the specific objectives, or goals, for the project
As detailed on page 3.10-9 of the DEIR, the California
Department of Housing and Community Development (HCD)
determines the regional need based on population projections and other factors including rates of vacancy, overcrowding, and cost burden. Population projections and other factors are required to ATTACHMENT 1 / EXHIBIT A
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as outlined in the
report. Goal 1 states that the plan should address
the regional housing needs (RHNA) but, as
mentioned above, Monterey appears to be planning
for many more new units
than are necessary to meet projected needs. It
leads one to wonder if perhaps the Highway 68
parcel is included because an influential developer
would like to build on it at the expense of the
Highway 68 Scenic Corridor, the environment, and
the general enjoyment and welfare of the
community.
distribute the region’s share of statewide need to cities and counties within its jurisdiction. The purpose of the RHNA is to allocate a share of the Monterey Bay Area’s projected housing need to cities and counties by household income group,
categorized as “very low,” “low,” “moderate,” and “above moderate.” According to the Draft 2023–2031 RHNA, AMBAG has determined that Monterey’s share of regional housing need for the period from December 15, 2023 through December 15, 2031 would be 3,654 units. In addition, please see Master Response MR1 regarding cumulative development impacts on scenic resources in the southeast and south Monterey.

C4-4 Benzing, Jeff 3/16/24 Goal 6 states that the City of Monterey should “ encourage new housing in locations supported by
existing or planned infrastructure, while maintaining
existing neighborhood character.” There is no
existing infrastructure on the 50 acre Highway 68
parcel and the neighborhood character is low
density residential and rural so the proposed plan
does not meet goal 6.

As detailed on page 3.10-22 of the DEIR, Program 1-I involves amending the Highway 68 Area Plan to accommodate mixed
income housing on the 50-acre MPUSD site and incorporate infrastructure financing mechanisms. However, the comment pertains to the Proposed Plan and is not related to the adequacy of the DEIR; thus, no further response is required.

C4-5 Benzing, Jeff 3/16/24 Goal 7, entitled “Maintain Existing Housing” , states that the city wants to “assure high quality
maintenance, safety, and habitability of existing
housing resources.” If this is so,
why not have programs to rehabilitate and remodel
existing housing, especially in core areas of the city? If you build an excess of new housing and
significantly increase
vacancy rates and decrease rental rates, it is well
known that landlords will not be willing or able to
maintain existing properties. The result will be
some nice new buildings along Highway 68 while
the appearance of Monterey's central district
continues to degrade.

The comment pertains to the Proposed Plan and is not related to the adequacy of the DEIR; thus, no further response is required.

C4-6 Benzing, Jeff 3/16/24 Goal 8 states that appropriate housing sites “are proximate to transportation, shopping and
As detailed on page 3.10-22 of the DEIR, Program 1-I involves amending the Highway 68 Area Plan to accommodate mixed
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schools…” This goal is in line with the State of
California’s goal to promote infill as a way to
promote sustainability and minimize negative
impacts on the environment. The parcel on
Highway 68 does not meet this goal. It is not infill
and would require residents to use cars to get to
work and for all errands. It is not on a major transit
route and it has a very low walk score.
income housing on the 50-acre MPUSD site and incorporate infrastructure financing mechanisms. In addition, as detailed on page 3.10-17, the Proposed Plan incorporates numerous strategies to accommodate infill development and focus new growth so as to balance levels of employment and housing within the community to reduce commute times, improve air quality, and provide more opportunities for those who work in Monterey to live locally. Infill development strategies include Housing Element Programs 1-C, Specific Plan Updates, Program 1-D, Permit Streamlining Pilot Project, Program 1-E, Education Workforce Housing Overlay, Program 1-G, Surplus Municipal Parking Facilities, Program 2-E, Revise Parking Requirements, Program 2-L, Moratorium on Vehicle Storage, and Program 3-C, Local Density Bonus. As such, overall, implementation of the Proposed Plan would not conflict with regional, airport land use, or local plans, policies, or regulations adopted for the purpose of avoiding or mitigating an
environmental effect.

C4-7 Benzing, Jeff 3/16/24 Goal 12 states that the Proposed Plan should be consistent with the Airport Land Use Compatibility
Plan (ALUCP) yet development of the 50 acre
parcel blatantly violates this
stated goal. According to ALUCP, the parcel is in
Zone 3, where all residential development is
prohibited, except low density and infill in already
developed areas. The
airport is a major revenue generator for the county
and provider of jobs. It has been proven time and
time again that residential development within an
airport environment
leads to community pressure to close, or at a
minimum, scale back airport operations due to
noise and environmental issues. As you are aware,
the Airport district is
currently undergoing the construction of a new
Terminal building and an expansion of its served
markets, all things which lead to higher tax
revenues for the County and an
As outlined in page 3.8-30, the DEIR did consider the impacts of airport proximity. Future development under the Plan would be required to comply with the safety zone land use compatibility standards in Table 4B Safety Criteria Matrix of the ALUCP in order to protect and promote the safety and welfare of residents and airport users. The Safety Criteria Matrix establishes maximum densities, intensities, prohibited uses, and other development conditions for proposed development within the ALUCP safety zones so as to restrict the development of land uses that could pose particular hazards to the public or to vulnerable populations in case of an aircraft accident. Further, the proposed Land Use Element includes policies to minimize airport safety hazards and promote compatibility with airport operations, including Policy C.1 which requires that new development be compatible with the standards for land uses, density, and intensity specified in ALUCP for the Monterey Regional Airport. Therefore, compliance with the ALUCP and implementation of the Plan would reduce airport safety hazards potentially resulting from new development to the maximum extent practicable. Associated impacts would be less than significant.

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increased number of high paying skilled
employment opportunities for the area’s residents.

To put this in jeopardy would be a mistake.

In addition, page 3.11-27 of the DEIR states that portions of the Fort Ord opportunity area and the 50-acre MPUSD parcel south of Highway 68 are within Airport Safety Zone 3, which prohibits all residential except for low density residential and infill in developed areas. However, the proposed Land Use Element establishes a new Airport Compatibility Overlay (AC-O) that applies to properties in airport safety zones 1 through 6 as identified in the Monterey Regional Airport Land Use Compatibility Plan (ALUCP) in order to protect airport operations and ensure public safety. Existing uses are permitted to continue on sites within the AC-O, and new development and expansion of existing uses shall only be permitted where the compatibility criteria or the infill exemption criteria of the ALUCP can be met. Further, Program 1-H and Program 1-I of the proposed Housing Element would also help ensure compatibility with the ALUCP, requiring future land uses planned on the Fort Ord property and the Highway 68 Area Plan boundaries that are within the Monterey Regional Airport Influence Area to be compatible with the ALUCP. As such, no conflicts with ALUCP zones would result.

C4-8 Benzing, Jeff 3/16/24 Goal 9 states that the Proposed Plan should “support a vibrant local economy.” This goal is what
is used to promote the Proposed Plan over the
“Increased Workforce
Alternative Plan.” The City of Monterey report
states that the Increased Workforce Alternative
Plan is environmentally superior to the Proposed
Plan as it avoids significant
and unavoidable impacts to agricultural resources
and air quality. However, the City of Monterey
rejects the Increased Workforce Alternative Plan
because it does not support
local economic vitality to the same extent as the
Proposed Plan does. This is in direct contradiction
to the stated facts! Goal 9, which discusses
economic vitality, states that
there should be a balance of jobs and housing so
that those who work in Monterey can afford to live
Please see response to comment C2-8 regarding Goal 9 and Increased Workforce Housing Alternative.

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in Monterey but the report also states that with
the Proposed Plan, low
wage hospitality and tourism workers would
increase their vehicle miles traveled (VMT). So isn’t
the Increased Workforce Alternative Plan better for
low wage workers, better for the environment, and
better for everyone else as it reduces traffic
congestion and air pollution and maintains the
scenic beauty of the Highway 68 Corridor?
C4-9 Benzing, Jeff 3/16/24 Finally, why put our Airport at risk? Why not embrace a hybrid plan? Development of the land on
South Boundary Rd, as described in the Proposed
Plan, makes sense as
it’s within walking distance of jobs at Ryan Ranch.

Why not implement part of the Increased
Workforce Alternative Plan but also develop
housing along Boundary Rd?
Boundary Rd. is not part of a recognized scenic
corridor and would be much less likely to add to
traffic congestion on Highway 68. In keeping with
the State of California’s
guideline for higher density units that are infill, the City of Monterey could modernize and further
develop areas that could use revitalization without
destroying the natural
beauty and rural character that attracts tourists to
visit and retirees to relocate to the Monterey
Peninsula.

Thank you for your time and consideration of my
input.

The comment pertains to the Proposed Plan and is not related to the adequacy of the DEIR; thus, no further response is required in this document. Comments related to the content of the Proposed Plan will be considered by City decision-makers at adoption hearings.

C5-1 Biby, Jordan 3/22/24 I am writing to express my strong opposition to the proposed housing development in our
neighborhood. While I understand the need for
affordable housing in our city, I believe that this
project would have a detrimental impact on our
community.

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C5-2 Biby, Jordan 3/22/24 First and foremost, the proposed development is simply too large for our area. The increase in
population density would put a strain on our
already overburdened infrastructure, leading to
increased traffic congestion, noise pollution, and
strain on our public services. Additionally, the
construction of this project would result in
significant environmental damage, destroying
natural habitats and putting wildlife at risk.

Analysis regarding utility and transportation improvements is included in Chapters 3.13 and 3.14 of the DEIR. Please see response to comment C1-4 regarding traffic impacts, response to comment C27-4 regarding noise pollution, responses to comments C1-8 and C1-9 about public services, and response to comment C1-5 regarding habitat and wildlife risk.

C5-3 Biby, Jordan 3/22/24 Furthermore, the type of housing being proposed is simply not in keeping with the character of our
neighborhood. It would also drastically alter the
aesthetic of our area, replacing the existing
greenery and open spaces with a high-density
housing complex.

As outlined on page 3.1-17 in Aesthetics, the DEIR did consider visual character and aesthetic impacts on the Planning Area. The 2005 General Plan Urban Design Element includes numerous policies to ensure that new development pursuant to the Proposed Plan would not substantially degrade the scenic character of the Planning Area. New development within the Planning Area would primarily be focused in the previously developed areas, although the 50-acre MPUSD site within the Highway 68 Area Plan boundary is vacant. Implementation of proposed Housing Element Program 1-I would involve standards to integrate the new housing on the MPUSD site in a contextsensitive manner. Therefore, in combination with 2005 General Plan Urban Design Element policies and implementation of Program 1-I, the Project would not substantially degrade character and aesthetics, and impacts would be less than significant.

C5-4 Biby, Jordan 3/22/24 In conclusion, I am deeply concerned about the impact this development would have on property
values in the
surrounding area. I strongly urge you to reconsider
this proposed housing development. While I
recognize the need for affordable housing, I believe
that this project is simply not the right fit for our
neighborhood. Thank you for your attention to this
matter. Please add all impacted residents to the
discussion about planning and development in areas
that would directly affect their homes.

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C6-1 Birkhofer,
Wendell
and
Celeste
3/20/24 We are writing as very concerned long-term
homeowners on the Highway 68 Scenic Corridor.

The proposed 50 acre development across from
Monterey Airport, off Olmstead Road, raises a
number of serious issues related to our community.
we certainly know that affordable housing is in
short supply in our beautiful region on the coast.

However, the broad issues of environmental impact,
water supply and run-off, more congested traffic
along Highway 68, air quality, fire protection and
public safety services, among other issues, make the
Olmstead development highly unattractive in our
view.

Please see also Master Response MR-1 regarding cumulative development in the southeast and south Monterey.

C6-2 Birkhofer,
Wendell
and
Celeste
3/20/24 We urge you to reconsider the efforts being
undertaken to change scenic/conservation zoning
and provide entitlements, and evaluate other more
attractive areas for future housing supply. The
residents of our greenbelt community are also
disappointed that we were not informed earlier
about the looming threats to the character of our
Monterey rural area along Highway 68.

As outlined on page 5-6 in CEQA Required Conclusions, the DEIR did consider cumulative impacts on designated scenic areas. The 2005 General Plan Urban Design Element includes numerous policies to preserve and enhance scenic resources within the Planning Area. New development within the Planning Area would primarily be focused in the previously developed areas, although the 50-acre MPUSD site within the Highway 68 Area Plan
boundary is vacant. Implementation of proposed Housing Element Program 1-I would involve standards to integrate the new housing on the MPUSD site in a context-sensitive manner. Therefore, in combination with 2005 General Plan Urban Design Element policies and implementation of Program 1-I, the Project would not substantially degrade scenic resources and cumulative impacts would be less than significant. Please see also Master Response MR-1 regarding cumulative development in the southeast and south Monterey. As further detailed on page 3.1-20, overall compliance with applicable zoning regulations and General Plan policies would ensure impacts on existing visual character would be less than significant.

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C7-1 Bonavico,
Chris
3/1/24 We live across Olmsted road from the area you are studying.

We have small children and are very concerned
about the greatly increased additional traffic and
the risk to children that tenants of subsidized
housing presents.

Thank you for your letter. As detailed on page 3.13-23 of the DEIR, the Proposed Plan includes goals to improve the overall safety of the transportation network as well as the safety for nonautomobile travel modes. In addition, all future public and private improvement projects and transportation facilities would be subject to additional review and approval to ensure safety.

Considering that the Proposed Plan would not substantially increase hazards due to design features and that it would be compatible with existing uses in the area, impacts would be less than significant.

C7-2 Bonavico,
Chris
3/1/24 The wildlife also will suffer. And the school /
schoolchildren will be negatively impacted by
development.

I know there is political pressure to create low
income housing, but this is a terrible area to impact.

We are not a high income family, but we ask that
you consider the impacts to families here - and
choose to develop elsewhere.

The DEIR did consider impacts on wildlife species in the Planning Area. Pursuant to data from the California Department of Fish and Wildlife, special-status animal species with the potential to occur in the Planning Area are outlined in Table 3.4-2. As detailed on page

3.4-24, development could contribute to the loss of natural lands in the Planning Area, with potential effects on special-status species. However, impacts would be reduced with implementation of Mitigation Measure BIO-1 through BIO-12, which would ensure the protection of special-status plant and animal species. With implementation of Mitigation Measures BIO-1 through BIO-12 and compliance with federal, state, and local regulations, the Plan’s contribution to biological resources impacts would be less than significant.

C8-1 Breidenbac
h, Fred
3/8/24 I had the opportunity to review my neighbors
letter and I thought it was spot on with regards to
my personal concerns. So, rather than rewrite it or
paraphrase it, I am copying it with the exception of
this paragraph and the last two paragraphs.

We are nearby residents of the proposed housing
project for 640 units off Highway 68 currently
owned by the Monterey Peninsula School District.

I'm shocked with all the development being
proposed all around the airport/68,
including the Garden Court development, the 1324
units being proposed by the county, and the
Boundary Road project with significant units in the
Please see Master Response MR-1 regarding cumulative
development impacts on scenic resources in the southeast and south Monterey.

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Ryan Ranch area. Does anyone care about the
cumulative effects of all these developments on an
area that already is struggling with traffic and was
designated a scenic corridor? Many of us moved to
this area to escape the urbanization and
densification in other parts of California. While I
support the need for additional residential
development that is affordable to ensure hard
working people can afford to live and work in
Monterey County, several of the proposed sites are
of particular concern especially given the high
density.

C8-2 Breidenbac
h, Fred
3/8/24 The two I especially object to are the County's
1324 units being proposed off Olmstead Rd and
the city of Monterey's 640 units being proposed for
land that was previously designated for education.

Both of these projects violate the State of
California's desire for infill on already developed
land and pose significant risk, including:

As outlined on page 3.10-10, the 50-acre Monterey Peninsula Unified School District (MPUSD) site is within the Highway 68 Area Plan which was adopted in 1984. The plan claims a maximum of 3,550 dwelling units will be permitted in the Monterra, Laguna Seca, and Aguajito areas. Specifically, for the MPUSD 50-acre site, the Highway 68 Area Plan calls for the development of 300 lowincome and moderate-income housing units. As such the proposed development at the site is consistent with previous City planning efforts.

C8-3 Breidenbac
h, Fred
3/8/24 *Traffic on Olmstead Road and Highway 68,
including the proposed roundabout: It can be
estimated that Monterey's proposed development
could generate up to 1600 extra cars per day and
the County's project 3250 extra cars per day. This
would be approximately 5000 more cars in an area
already dense with traffic and backups, especially
during commute windows. The assumption is 2.5
car trips per housing unit per day). The expansion
of the airport facilities and new apartments on
Garden Rd and proposed housing on South
Boundary Rd and the current courthouse off
Aguajito Rd. would make traffic even worse.

Enormous costs of widening Hwy 68 would be paid
for by taxpayers. There is currently no mass transit
First, it should be noted that under the California Environmental Quality Act (CEQA), traffic volume or level of service (LOS) can no longer be used as a traffic impact metric, pursuant to Senate Bill 743 (Steinberg, 2013) as codified in Public Resources Code section 21099, which required changes to the guidelines implementing CEQA (CEQA Guidelines) (Cal. Code Regs., Title 14, Div. 6, Ch. 3, § 15000 et seq.) regarding the analysis of transportation impacts. With the California Natural Resources Agency’s certification and adoption of the changes to the CEQA Guidelines, automobile delay, as measured by “level of service” and other similar metrics, no longer constitutes a significant environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3).). The Technical Advisory by OPR outlines VMT (vehicle-miles traveled) as the metric to be used for transportation analysis under CEQA. See also page 3.13-8 of the EIR for further ATTACHMENT 1 / EXHIBIT A
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in the area. What is the plan to mitigate the impact
of all this extra traffic?
detail.

Second, for the DEIR, an analysis of VMT in the Planning Area was conducted for conditions without and with the Proposed Plan by a California traffic engineering firm, Kimley-Horn. The most recent version of the Association of Monterey Bay Area Governments Regional Travel Demand Model (AMBAG RTDM) was used to
estimate VMT efficiency metrics across all land uses. The AMBAG TDM has a base year of 2015 and a future year of 2045. The model’s 2045 cumulative year includes growth that is consistent with adopted general plans within Monterey County and with regional projections contained in the 2045 Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS).

As such, the City’s Housing Element and all Housing Elements in the County, including Monterey County, inform the model’s 2045 cumulative year.

Lastly, as detailed on page 3.13-22 of the DEIR, increased development in the Planning Area would generate additional vehicle trips on the local and regional roadway network, where employment-based land uses have a potentially significant impact.

As such, the Proposed Plan incorporates strategies to promote the development of mixed use villages and transit-oriented development within the City limit, including proposed Land Use Element policies A.1, A.2, and A.4, as well as policies involving coordination with MST to support transit use, including Circulation Element policies E.3, E.5, E. 6, and E.7. In addition, Mitigation Measure VMT-1 is required to reduce the total VMT per service population generated by typical uses in the Planning Area through the adoption of an Employee Commute Trip Reduction Project and would reduce the magnitude of the impact. However, the effectiveness cannot be accurately estimated for the expected developments in the Planning Area, because the detailed characteristics of these future development and/or the specific strategies implemented by these future developments cannot be known at this time. Thus, this DEIR conservatively assumes that these impacts would be significant and unavoidable. In addition, see page 3.3-48 of the EIR for an assessment of carbon monoxide hot spots due to increased vehicle congestion.

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C8-4 Breidenbac
h, Fred
3/8/24 *Environmental impact and vanishing Greenbelt:

The removal of this greenbelt is a significant
adverse impact aesthetically and a huge contrast
from the scenic easement that gives this area such
a special character. It is also a loss of habitat for
many keystone animal species that can be observed
on the subject parcel. Frequent observations occur
of Apex/keystone species such as Mountain Lion,
Bobcat and Coyote as well as many avian species of
special interest. Does the County understand the
implications of eliminating this biological corridor?
The current residential zoning in this area is one
home per 10 acres to allow for new residential
development, while still preserving the rural
character of this beautiful area. How does such a
high density (10-20 units per acre) fit into this
environment? I don't understand how a designated
scenic corridor can be turned into a high density
set of houses and roads. That is not in the spirit of
what California state criteria is for affordable
housing.

As outlined on page 3.1-17 in Aesthetics, the DEIR did consider visual character and aesthetic impacts on the Planning Area. The 2005 General Plan Urban Design Elements includes numerous policies to ensure that new development pursuant to the Proposed Plan would not substantially degrade the scenic character of the Planning Area. New development within the Planning Area would primarily be focused in the previously developed areas, although the 50-acre MPUSD site within the Highway 68 Area Plan boundary is vacant. Implementation of proposed Housing Element Program 1-I would involve standards to integrate the new housing on the MPUSD site in a contextsensitive manner. Therefore, in combination with 2005 General Plan Urban Design Element policies and implementation of Program 1-I, the Project would not substantially degrade character and aesthetics, and impacts would be less than significant.

3.4-2. As detailed on page 3.4-24, development could contribute to the loss of natural lands in the Planning Area, with potential effects on special-status species. However, impacts would be reduced with implementation of Mitigation Measures BIO-1 through BIO-12, which would ensure the protection of special-status plant and animal species. With implementation of Mitigation Measures BIO1 through BIO-12 and compliance with federal, state, and local regulations, the Plan’s contribution to biological resources impacts would be less than significant.

C8-5 Breidenbac
h, Fred
3/8/24 *Pedestrian and Bicycle safety: It is not clear the roads in and out of the 640 unit housing complex
since there would need to be at least one
additional road for entry in and out. Is this also
going to be onto Olmstead Road through the
County's development? Olmstead Rd would go
from a quiet rural road to a very busy urban one.

Further, the proposed Circulation Element also requires ATTACHMENT 1 / EXHIBIT A
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What is the plan for pedestrian and bike safety with
a high volume of cars coming in and out onto
Olmstead on both sides of the street? Are you
planning to access the development directly from
Highway 68? This would also pose significant safety
risks.
development projects to provide on-site facilities such a bicycle parking and showers, to dedicate land to expand existing facilities or provide new facilities such as sidewalks/multi-use paths and/or bicycle lanes, and to ensure projects are designed to be efficiently served by bike routes and pedestrian connections (Policy c.9). As a result, the Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, particularly bicycle and pedestrian facilities, and the impact would be less than significant.

C8-6 Breidenbac
h, Fred
3/8/24 *Flight Crash Risk. 2 years ago, there was a crash into an unoccupied single-family home in the
Monterra neighborhood. If such an incident were
to occur in a high-density community, there could
be a substantial loss of life. Similar incidents have
occurred in California (i.e. Truckee with a private
jet, as well as Naples FLA recently). Has the city of
Monterey and County consulted with Monterey
Regional Airport on the flight crash risk specific to
the subject property?
As outlined in page 3.8-30, the DEIR did consider the impacts of airport proximity. Future development under the Plan would be required to comply with the safety zone land use compatibility standards in Table 4B Safety Criteria Matrix of the ALUCP in order to protect and promote the safety and welfare of residents and airport users. The Safety Criteria Matrix establishes maximum densities, intensities, prohibited uses, and other development conditions for proposed development within the ALUCP safety zones so as to restrict the development of land uses that could pose particular hazards to the public or to vulnerable populations in case of an aircraft accident. Further, the proposed Land Use Element includes policies to minimize airport safety hazards and promote compatibility with airport operations, including Policy C.1 which requires that new development be compatible with the standards for land uses, density, and intensity specified in ALUCP for the Monterey Regional Airport. Therefore, compliance with the ALUCP and implementation of the Plan would reduce airport safety hazards potentially resulting from new development to the maximum extent practicable. Associated impacts would be less than significant.

C8-7 Breidenbac
h, Fred
3/8/24 *Fire Protection. This development would come
with extraordinary expense of added fire response
personnel and equipment. This is compounded by
traffic jams adding to response times. Additionally,
one of the important functions of the existing
greenbelt zoning gives the entire community an
important firebreak. CALFIRE depends on this
As outlined in page 3.12-19, the DEIR did consider the impacts of new development on fire and emergency services and facilities.

Monterey Fire Department (MFD) does not have plans to increase staffing or equipment levels over the next eight years. Current staffing and equipment levels provide an adequate number of staffing for fires, medical, or rescue situations and would be sufficient to handle the potential increase in incidents in infill areas ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2262, Packet Page 2590 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
2-341
Letter Commenter Date Comment Response
parcel for fire protection of this whole region.

These
parcels were an important staging area for
firefighters during the last fire just three years ago
and we would lose that critical capability if this land were to be developed. Does the city of Monterey
and County comprehend the magnitude of
additional risk of wildfire this abandonment of
firebreak will produce, given the forest densities to
the east and west? Is the city of Monterey and
County prepared to assume liability for a future
wildfire disaster, which could have been
prevented by preservation of this critical firebreak?
Has the County consulted with CALFIRE on the
details of how this firebreak is vital to community
safety along the entire Hwy 68 corridor?
with buildout of the Plan. However, fire and emergency medical response services are currently provided to the eastern portion of the city from Station 16, which is leased from the Monterey Airport District and it isn't well suited to provide increased services to that portion of Monterey. As such, a dedicated Cityowned fire station would likely be needed to serve that area.

C8-8 Breidenbac
h, Fred
3/8/24 *Police Protection. This proposed rezoning will
place an untenable burden on our existing police
resources, which already are in critical shortage.

This is not only a public safety threat, but also an
extraordinary economic impact by placing
3000 new residents with the county's Olmstead
development and ~1500 with Monterey's
development in locations, which are not even
conveniently serviced for the expected demand
level. Has the Monterey County sheriff been
consulted and are they prepared to handle this high
density loading and increased risk?
As outlined in page 3.12-19, the DEIR did consider the impacts of new development on police protection services and facilities. The Monterey Police Department (MPD) is able to adjust staffing to be appropriate with population levels in order to maintain standards of service. MPD has existing plans in place to increase staffing over the next five to ten years. MPD and MFD have plans to develop a new joint public safety facility. The planned facility would be sufficient to accommodate increased MPD staffing and equipment needed to accommodate the increase in calls for service anticipated with buildout of the Plan. Therefore, impacts would be less than significant.

C8-9 Breidenbac
h, Fred
3/8/24 *Air Quality. The additional traffic, especially considering the projected congestion and idling, will
cause significant deterioration in local air quality,
both to onsite residents of the new development
and to nearby existing populations. The specific
pollutants of public health concern are sulfur
dioxide, oxides of nitrogen, carbon monoxide and
carbon fibre from tyres. Is the County aware that
As outlined in page 3.3-51, the DEIR did consider impacts of local air quality and sensitive receptors. Although it is unknown what specific sources would be installed or where they would operate, all new stationary sources would be subject to the permit authority of the MBARD, and review of new sources are subject to BACT requirements. These regulatory mechanisms would ensure that cancer and health hazard impacts from stationary sources developed under the future projects would be less than significant.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2263, Packet Page 2591 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
2-342
Letter Commenter Date Comment Response
approximately 20,000 deaths per annum occur in
the United States from these air pollutants? How
will this be mitigated for current and future
residents?
However, they may not be sufficient to address PM impacts if the source results in significant PM concentrations, especially given the existing nonattainment status for PM10 and the expected increase in PM emissions due to the Proposed Plan.

MM-AQ-1 is therefore required to provide a project-level evaluation of construction- and operational-related health risks from future projects within 1,000 feet of sensitive receptors. MMAQ-2 through MM-AQ-4 would reduce CO, diesel, and PM (exhaust and fugitive dust) emissions during construction activities.

MM-AQ-5 would reduce TAC and localized CO and PM exposure to future sensitive receptors but not for receptors at land uses that have already been constructed. MM-AQ-6 requires air quality equipment to minimize health risks but would not apply to existing sensitive receptors that are present before new construction or operational activity commences. Therefore, after mitigation, this impact would be significant and unavoidable.

C8-10 Breidenbac
h, Fred
3/8/24 *Quality and Availability of Water: If the
moratorium on drilling wells is lifted, is there data
to support that the onsite wells can provide
sufficient healthy ground water for over 3000 new
residents for the County development and ~1500
for the Monterey city development without being a
detriment to the current ground water supply? It is
well established that there are a number of
carcinogenic and toxic chemicals in the
groundwater emanating from Fort Ord. It is also
known that this subsurface water plume is
presently moving in the direction of the proposed
rezoning parcel, if not already present beneath the
subject parcel. This is a serious threat to residents
of the subject parcels, particularly to children who
will predictably explore the soils of their
neighborhood. See for example: Cancer cluster at
Fort Ord: Sick vets wonder, are there more of us?
(thecalifornian.com) . Thank you for including my
input. I would encourage you to look at using ADUs
and other infill strategies using land that has already As outlined in page 3.14-26, the DEIR did consider impacts of water supply. The Marina Coast Water District (MCWD) projects that available groundwater supply from the Salinas Valley Groundwater Basin will be sufficient to meet demand in its service area through 2040. Further, MM UTIL-2, involving actions to expand MCWD supply, is required. To meet additional future demands, the MCWD 2020 UWMP provides that reactivation of the MCWD pilot seawater desalination plant could potentially add 300 AFY of additional supply. Further, to provide additional water to meet future demand when it materializes, the MCWD 2020 UWMP states Phase 2 of the Pure Water Monterey Expansion Project is anticipated to deliver additional water to the Seaside Basin. See also Master Response MR-2 regarding water supply.

Monterey City CouncilJuly 16, 2024

Monterey City Council
July 16, 2024