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

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

C9-1 Breidenbac
h, Susan
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 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
Please see Master Response MR-1 regarding the cumulative impacts of development in south and southeast Monterey.

Additionally, 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 for most projects under CEQA.

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of particular concern especially given the high
density.

C9-2 Breidenbac
h, Susan
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:

C9-3 Breidenbac
h, Susan
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
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 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 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 RTDM 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 ATTACHMENT 1 / EXHIBIT A
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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.

C9-4 Breidenbac
h, Susan
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
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 into 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 ATTACHMENT 1 / EXHIBIT A
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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.
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 character and aesthetics, and impacts would be less than significant.

C9-5 Breidenbac
h, Susan
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.

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.

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C9-6 Breidenbac
h, Susan
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.

C9-7 Breidenbac
h, Susan
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
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
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 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 ATTACHMENT 1 / EXHIBIT A
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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?
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.

Additionally, in parallel with preparation of the Housing Element, the City also updated the Safety Element of the General Plan and incorporated a robust framework of policies to address and mitigate the risk of loss and damage due to wildfire. These policies are referenced in the Draft EIR. The Safety Element was reviewed and approved by the California Department of Forestry and Fire prevention in April 2024.

C9-8 Breidenbac
h, Susan
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.

C9-9 Breidenbac
h, Susan
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
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 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.

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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.

C9-10 Breidenbac
h, Susan
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 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, the east side of General Jim Moore
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.

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

C10-1 Brown,
Henry
3/24/24 I strongly oppose the plan to potentially develop the 50 acre site of highway 68 for up to 600 high
density housing units. Rather than typing out a long
list of objections, I have included a very thorough
letter from my neighbor as I basically agree with all
her concerns and objections about the
development of this site. Please note my objections
to this site's development!
This 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.

C10-2 Brown,
Henry
3/24/24 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
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 Elements includes numerous policies to preserve and enhance scenic resources within 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. 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 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.

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rural character. If that is now developed, the
designation of Highway 68 as a scenic corridor
would be in jeopardy.

C10-3 Brown,
Henry
3/24/24 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.

Please see response to comment C2-2 regarding projections of population growth and corresponding housing needs. Please also see Master Response MR-1 regarding cumulative development impacts on scenic resources in the southeast and south Monterey.

C10-4 Brown,
Henry
3/24/24 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
Please see response to comment C2-3 regarding projections of population growth and corresponding housing needs. Please also see Master Response MR-1 regarding cumulative development impacts on scenic resources in the southeast and south Monterey.

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(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.

C10-5 Brown,
Henry
3/24/24 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.

C10-6 Brown,
Henry
3/24/24 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.

C10-7 Brown,
Henry
3/24/24 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
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 ATTACHMENT 1 / EXHIBIT A
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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.
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.

C10-8 Brown,
Henry
3/24/24 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 ATTACHMENT 1 / EXHIBIT A
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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.

C10-9 Brown,
Henry
3/24/24 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
Please see response to comment C2-8 regarding Goal 9 and Increased Workforce Housing Alternative.

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environment, and better for everyone else as it
reduces traffic congestion and air pollution and
maintains the scenic beauty of the Highway 68
Corridor?
C10-
10 Brown,
Henry
3/24/24 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
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.

C11-1 Chrietzber
g, Charles
3/19/24 As the owner of 14 properties in Monterra/
Tehama and York Highlands (Walden), we are in
100% in favor of this much needed housing.

This is an excellent location and we commend the
City for moving this project forward. I am certain
that most of the millionaires who live in Multi
million dollar homes in the exclusive developments
will be against this housing project as they can’t
understand lower priced housing for those not as
fortunate as them.

I wish you good luck with getting this project thru
this lengthy process.

C12-1 Cochran,
Robert
3/7/24 We are writing about the proposed housing project of 640 units off Highway 68 currently owned by the
Please see response MR-1 regarding cumulative development impacts on scenic resources in the southeast and south Monterey.

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Monterey Peninsula School District. This is
extremely concerning, given all the other
development being proposed in the immediate area,
including the Garden Court development, the 1300
units being proposed by the county, and the
Boundary Road project with significant units in the
Ryan Ranch area. We understand, and support, the
moral and political mandate for affordable housing,
but the cumulative effects of all this on an area that
already is struggling with traffic and was designated
a scenic corridor are likely to be disastrous. The
major areas of concern include:

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.

C12-2 Cochran,
Robert
3/7/24 1. Traffic. Assuming 2.5 car trips per housing unit per day, the city’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 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 for a traffic nightmare - not only for current
residents but for the new residents as well. Is there
any plan to deal with the impact of all this extra
traffic?
To emphasize the point, we understand that
Carmel, to take a nearby example, covers
approximately 1 square mile with about 3000
residents. As you know, Carmel can be quite
congested for pedestrians, cars, and bicycles. These
projects will have a considerably larger number of
residents packed within an area a fraction of
Carmel’s size. Does that really make sense?
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 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 RTDM has a base year of 2015 and a future year of 2045. The ATTACHMENT 1 / EXHIBIT A
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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.

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.

C12-3 Cochran,
Robert
3/7/24 2. 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, such as Mountain Lion,
Bobcat and Coyote as well as many avian species of
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 into the previously developed areas, although the 50-acre MPUSD site within the ATTACHMENT 1 / EXHIBIT A
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special interest. 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.

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 character and aesthetics, and impacts would be less than significant.

C12-4 Cochran,
Robert
3/7/24 3. 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 ATTACHMENT 1 / EXHIBIT A
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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.

C12-5 Cochran,
Robert
3/7/24 4. 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. Has the city of Monterey
analyzed additional risk of wildfire this
abandonment of firebreak will produce, given the
forest densities to the east and west, and is the city
prepared to assume liability for a future wildfire
disaster, which could have been prevented by
preservation of this firebreak?
As outlined in page 3.12-19, the DEIR did consider the impacts of fire and emergency services. 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 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 City-owned 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.

C12-6 Cochran,
Robert
3/7/24 5. Police Protection. The proposed rezoning will place an untenable burden on our existing law
enforcement resources, which already are in critical
shortage. Have the police and/or sheriff’s
departments been consulted and are they prepared
to handle this high 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.

C12-7 Cochran,
Robert
3/7/24 6. Air Quality. The additional traffic, especially considering the projected congestion and idling, will
As outlined on page 3.3-51, the DEIR did consider impacts of local air quality and sensitive receptors. Although it is unknown what ATTACHMENT 1 / EXHIBIT A
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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 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?
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.

C12-8 Cochran,
Robert
3/7/24 7. 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
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.

Regarding hazardous materials, as outlined on page 3.8-27, none of the parcels identified for housing are in need of remediation or ATTACHMENT 1 / EXHIBIT A
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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) .
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 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.

C12-9 Cochran,
Robert
3/7/24 In summation, it’s hard to believe that there are no sites which are more appropriate for a project of
this size. It also seems quite likely that the same
number of units could be spread out over a
number of sites in the city with far less harm done
to the existing communities, residents, and
environments, and a better outcome for the
occupants of the new housing. We hope you will
give serious consideration to the concerns raised in
this email.

C13-1 Cook,
Arthur
3/21/24 Draft Program-Level Draft Environmental Impact
Report (EIR) for the Monterey 2031 General Plan
Update. Specifically, the statements which appear in
the Revised Draft City of Monterey 2023-2031
Housing Element, as follows:
“HOUSING POTENTIAL BY OPPORTUNITY
AREA
“Garden Road
“This area contains a large, vacant parcel owned by
The comment is not related to the adequacy of the DEIR; thus, no further response is required.

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the Monterey City School District (MPUSD).

Located east of Tarpey Flats and south of the
airport, the 50-acre parcel is on relatively flat
terrain and is identified as potential site for
moderate and low income housing in the Highway
68 Area Plan if MPUSD were to declare the
property surplus… To facilitate development of this
site with mixed income housing, Program 1-I has
been included in the Housing Action Plan
(Chapter4) and the inventory assumes 640 new
housing units…”
Revised Draft | December 8, 2023 p. 3-15
C13-2 Cook,
Arthur
3/21/24 Dear Associate Planner Sadbo,
In considering its housing element, the City of
Monterey needs to be mindful that Monterey
Regional Airport brings $250 Million annually into
the City and immediate surrounding area.

The additional housing planned by the City and
described in the quote above, if approved, would
cripple the only vehicular ingress and egress for
passengers coming and going to and from the area
by air. The traffic impact of this proposed housing
development would
contribute to a disastrous bottleneck on Rt. 68
from Highway 1 to Ryan Ranch.

Vehicular Ingress and Egress to the Airport Is
Already Constricted: The primary route to and
from the Airport is by Olmsted Road via Route 68.

This section of highway is already very crowded,
and its status as the access to MRY Airport
terminals requires consideration. The City has
already approved 600 units on Garden Road.

Imagine if the City also approves 640 homes on the
50 acre parcel now owned by MPUSC. Meanwhile,
the County has proposed 1324 units of housing to
be built South of Route 68 at Olmsted Road. Any of
these projects would be highly detrimental to the
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, 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. In addition, see page 3.3-48 of the EIR for an assessment of carbon monoxide hot spots due to increased vehicle congestion.

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, ATTACHMENT 1 / EXHIBIT A
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Monterey Regional Airport, an engine of this area’s
economy. Collectively, more than 3000 additional
commuter vehicles will travel Route 68 through the
intersection with Olmsted Road twice daily,
weekday mornings and evenings. There are no jobs,
shops or services near any of these housing sites.

The nearest supermarket, Safeway at Fremont
Boulevard and Del Rey Oaks Boulevard, is over 2
miles away. Residents will require vehicular
transportation for every errand, adding additional
daily vehicular round trips through Route 68
between Highway 1 and Rt 218.

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.

Regarding emergency access, page 3.13-24 of the DEIR states that City staff, including emergency responders, review all development applications to ensure that applicable requirements are met, including provisions for adequate access for emergency
responders and response vehicles, consistent with the Fire Code.

As such, impacts on emergency access are less than significant.

Regarding evacuation, page 3.15-21 of the DEIR notes that under a multi-hazard evacuation scenario, traffic volumes would surpass capacity as traffic approaches Highway 1 at two locations in the network: the interchange of Fremont Street-Highway 1, where the volume to capacity ratio (v/c) would be 1.2, and at the Soledad Drive-Highway 1 approach, where the v/c ratio would be 1.1. This is a potentially significant impact; therefore mitigation measure MM-WF-1, which involves measures to temporarily increase capacity at constrained locations and proactively manage vehicle flow, is required to reduce this impact to a less than significant level. However, the highway onramps are part of the State transportation network, under the jurisdiction of Caltrans.

Caltrans does not currently have a plan or funding in place to temporarily increase capacity at constrained locations and implementation of this mitigation measure is beyond the control of the City. As such, it cannot be determined at this time whether the impact will in fact be mitigated to a less than significant level.

Therefore, overall this impact is considered significant and unavoidable.

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C13-3 Cook,
Arthur
3/21/24 CalTrans and TAMC Scenic Route 68 Corridor
Improvements Project: CalTrans and TAMC have a
joint project to place roundabouts at major
intersections along Route 68 between Salinas and
Monterey, including at Rt. 218 and Olmsted Road.

CalTrans’ and TAMC’s engineering for these
roundabouts took into consideration permits
which had been approved at the time of their
planning, but not as-yet-unpermitted projects such
as the City’s plan for 1240 housing units or the
County’s plan for 1324 housing units in the
immediate vicinity of the airport.

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

C13-4 Cook,
Arthur
3/21/24 Airport Expansion: These housing plans must also be considered in the context that Monterey
Regional Airport is already in the process of
renovating and expanding the airport terminal and
is adding gates, flights and destinations. More
vehicular traffic from the airport must also be
considered, entering and exiting at Olmsted Road
and Rt. 68.

Conclusion: Neither the City nor the County
should plan additional housing anywhere south of
Rt. 68 between Highway 1 and Ragsdale Drive.

Choking off vehicular access to the area’s
commercial airport would be disastrous for the
local economy.

Thank you for your consideration of this issue.

The comment is noted. Please see Master Response MR-1
regarding cumulative traffic impacts from the Proposed Plan in combination with other reasonably foreseeable projects in the region. As noted in MR-1 and discussed on page 3.13-8 of the DEIR, congestion has been replaced with vehicle miles travelled (VMT) as the metric for assessing traffic and transportation impacts under CEQA. Accordingly, cumulative VMT impacts from the Proposed Plan were on page 5-14 of the DEIR and in Chapter

3.13. The DEIR concluded that even after implementation of all feasible mitigation, impacts would remain significant and unavoidable.

C14-1 Cooper,
Helen
3/23/24 I am writing to express my concerns about the
proposed 640-unit housing development off
Highway 68, which is currently under the
ownership of the Monterey Peninsula School
District. As a resident in proximity to the site, I am
alarmed by the cumulative impact of this and other
developments planned in the vicinity, such as the
Garden Court and Boundary Road projects.

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

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 Elements includes numerous policies to preserve and enhance scenic resources within 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
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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 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.

C14-2 Cooper,
Helen
3/23/24 The proposed developments threaten to
exacerbate existing traffic issues in an area that
many, including myself, have chosen for its scenic
qualities and relative tranquility. The addition of
potentially over 5000 cars from these new units
poses a significant risk to the designated scenic
corridor and contradicts the State of California's
infill policy, which favors development on already
urbanized land.

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.

Lastly, as detailed on page 3.13-22 of the DEIR, increased ATTACHMENT 1 / EXHIBIT A
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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.

C14-3 Cooper,
Helen
3/23/24 Furthermore, the environmental repercussions of eliminating the greenbelt in this area cannot be
overstated. The loss of habitat for key species and
the disruption of the biological corridor are at
odds with preserving the rural character that
defines our community. Introducing high-density
housing (10-20 units per acre) in a scenic corridor
undermines the very essence of what makes this
area unique and raises questions about the
adherence to state criteria for affordable housing.

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 specialstatus 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. Regarding habitat connectivity, page

3.4-37 of the DEIR details that 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 ATTACHMENT 1 / EXHIBIT A
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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.

C14-4 Cooper,
Helen
3/23/24 Safety concerns also arise with the increased traffic, as the infrastructure, particularly on Olmstead
Road, is ill-equipped to handle the influx. The risks
extend beyond traffic to potential flight crash
hazards, fire protection challenges, and police
resource strains. The development's proximity to
critical firebreaks and the potential for increased
wildfire risks necessitate a thorough review and
consultation with CALFIRE.

As detailed on page 3.15-23, given that the Project proposes development in the Highway 68 area and the extent of which VHFHSZs exist in and around Monterey, buildout of the Proposed Plan could increase the risk of loss and damage due to wildfire, resulting in potentially significant impacts. However, construction would be required to meet CBC requirements, including CCR Title 24, Part 2, which includes specific requirements related to exterior wildfire exposure. The Board of Forestry, via CCR Title 14, sets forth the minimum development standards for emergency access, fuel modification, setback, signage, and water supply, which ATTACHMENT 1 / EXHIBIT A
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help prevent loss of structures or life by reducing wildfire hazards.

The codes and regulations would reduce the risk of loss, injury, or death from wildfire for new developments under the Proposed Plan to a less-than-significant level.

Please see response to comment C1-8 and C1-9 regarding fire and police protections. Please see also Master Response MR-1 regarding cumulative development in the southeast and south Monterey.

C14-5 Cooper,
Helen
3/23/24 Air quality degradation due to additional traffic and idling, along with potential water supply and quality
issues, further compound the potential negative
outcomes of these developments. The health and
safety of current and future residents must be a
priority, and I urge a reevaluation of the impact on
local air quality and groundwater, particularly
considering the known contaminants from Fort
Ord. In conclusion, I implore you to consider
alternative infill strategies that utilize existing
developed land, such as vacant lots near MPC and
Casa Verde, the old courthouse, and hospital, and
areas around Cannery Row. These options would
mitigate the risks and preserve the integrity of our
community.

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, 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. In addition, see page 3.3-48 of the EIR for an assessment of carbon monoxide hot spots due to increased vehicle congestion.

Please see also response to comment C1-11 and Master Response MR-2 regarding water supply. Further, as detailed on page 3.9-23, withdrawals of surface water from the Carmel River have been limited to protect threatened species that live in the river. The Seaside Basin is under a court-ordered reduction schedule limiting groundwater withdrawals. Groundwater pumping is limited to protect the basin from overuse and to prevent saltwater intrusion into the aquifer, which would contaminate the freshwater supply.

Therefore, implementation of the Proposed Plan would not deplete groundwater supplies or interfere substantially with groundwater recharge as the withdrawals of Carmel Valley and Seaside Basins are limited. Therefore, associated groundwater impacts would be less than significant.

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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.

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C15-1 Corliss,
Robert and
Melanie
3/7/24 We currently own a home in Monterey County and
am dismayed at the significant number of proposed
housing developments near the airport off Highway
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. The cumulative effects of this
massive undertaking will have significant
ramifications to the traffic, lifestyle, environment, air quality, safety, fire and police protection and water
availability for those of us who moved here to
enjoy these wonderful attributes that Monterey
provides. While we understand additional affordable
residential development is necessary, I would
suggest several of the proposed sites are of
particular concern given the high density. I
especially am greatly concerned about the
proposed 1324 units off Olmstead Road and the
city of Monterey's 640 units being proposed for
land that was previously designated for education.

Please reconsider the damaging effects these
developments will result in and consider alternative
sites that would be less damaging to these areas.

Thank you in advance for your consideration.

Please see response Master Response MR-1 regarding cumulative development impacts in the southeast and south Monterey, including traffic, aesthetics, biological resources, air quality, safety, fire and police protection, and water availability. Please see also Master Response MR-2 regarding water supply.

Further, 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.

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 Area 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 low-income and moderate-income housing units. As such the proposed development at the site is consistent with previous City planning efforts.

C16-1 Darabont,
Frank
3/1/24 Hello, my name is Frank Darabont, and I am a
current resident of the Monterra neighborhood in
Monterey, CA. It's just come to my attention that
there is a land overlay bordering Hwy 68/Olmsted
Rd/Via Malpaso (to the south of the airport) that is
being considered by the county for just under
1,400 units of state-mandated low-income housing
development.

ATTACHMENT 1 / EXHIBIT A
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While I agree whole-heartedly that affordable
housing is needed, and am not opposed to
additional residential development in our county, I
believe this is a terrible location for a housing
project of this density. I'm writing to you with the
following concerns
C16-2 Darabont,
Frank
3/1/24 1. Traffic on Olmsted Rd and Hwy 68:

There is a very important different between
inconvenient traffic (a fact of modern life for us
all) and catastrophic traffic, which is the type of
traffic development of this location would
create.

Each unit could be estimated to have 10 trips
per day (this includes multiple house members
and the frequency of Amazon and other
deliveries). An added 13,000 trips per day
would add a catastrophic impact to the onelane highway that services our airport (which is expanding), and provides the only artery for
the many commuters who work on the
Monterey Peninsula from Salinas and other
areas east of here. There is no mass transit in
the area to help alleviate this burden.

With the high danger of wildfires in this area,
how will Hwy 68 be able to stand in the
instance of mass evacuations, or provide clear
access for first responders?
When we have severe rain storms, like the one
we just endured, and flooding, how will this
impact the one-lane highway at this location?
How will airport access be affected in these
circumstances?
How do you plan to mitigate the impact of all
this extra traffic?
This plan would turn this area from a quiet
rural road into a very busy urban road. What is
your plan for pedestrian and cyclist safety if
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.

Also outlined on 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 ATTACHMENT 1 / EXHIBIT A
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you have a considerably high volume of cars in
this area?
The city has objected to the development of
this area before because of the need for a
highway expansion to make it feasible, among
other reasons. What is your plan for expanding
the highway and creating more lanes to this
area? Who will pay for infrastructure
development of this magnitude?
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.

As such, impacts on emergency access are less than significant.

Regarding evacuation, page 3.15-21 of the DEIR notes that under a multi-hazard evacuation scenario, traffic volumes would surpass capacity as traffic approaches Highway 1 at two locations in the network: the interchange of Fremont Street-Highway 1, where the volume to capacity ratio (v/c) would be 1.2, and at the Soledad Drive-Highway 1 approach, where the v/c ratio would be 1.1. This is a potentially significant impact; therefore, mitigation measure MM-WF-1, which involves measures to temporarily increase capacity at constrained locations and proactively manage vehicle flow, is required to reduce this impact to a less than significant level. However, the highway onramps are part of the State transportation network, under the jurisdiction of Caltrans.

Therefore, overall, this impact is considered significant and unavoidable.

Please see response to comment C1-7 about airport hazards.

C16-3 Darabont,
Frank
3/1/24 2. Environmental impact: The area we're
discussing is currently home to a significant
amount of wildlife, some of them presently
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 ATTACHMENT 1 / EXHIBIT A
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endangered (mountain lions, for example). It is
also home to a significant number of heritage
oak trees.

With a project of this density, how are you
proposing to mitigate the impact on this
sensitive area?
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 specialstatus 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.

C16-4 Darabont,
Frank
3/1/24 3. Air quality: The additional traffic, especially considering the projected congestion and car
idling, will cause significant deterioration in
local air quality, both to onsite residents of the
new development to nearby existing
populations.

How will this air pollution be mitigated and
what is the cost to the county for these
measures?
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.

C16-5 Darabont,
Frank
3/1/24 4. Loss of scenic and rural character of the Hwy 68 corridor: The current residential zoning in
As outlined on page 3.1-17 in Aesthetics, the DEIR did consider visual character and aesthetic impacts on the Planning Area. The ATTACHMENT 1 / EXHIBIT A
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this area is one home per 10 acres of land in
order to preserve the rural character and
wildlife preservation of this area.

How does such a high density (10-15 units per
acre) fit into this environment without
destroying its character? Once it's built, this
area will be changed permanently! It cannot be
undone!
The removal of this greenbelt is a significant
adverse impact aesthetically and visually, as well
as being a devastating loss of habitat for many
keystone animal species that can be observed
on the subject parcel. This area is not just a
blessing to the immediate neighbors of the
Hwy 68 Corridor, but to the entire Peninsula.

Developing this beautiful land that has been a
reserve for wildlife for so long will ruin the
character of this area, for the entire Peninsula
and for the hundreds of thousands of tourists
and visitors who came to Monterey for annual
events and to enjoy the natural beauty.

How will development of this area impact
tourism and the reputation of our area for
natural beauty? Instead of arrivals to our
airport being greeted with the graceful and
timeless open land and trees of this 50-acre
parcel, they will be shocked by inappropriate
development and catastrophic traffic.
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 into 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 character and aesthetics, and impacts would be less than significant.

C16-6 Darabont,
Frank
3/1/24 5. Sewage: How will the sewer be managed? Will
it be a closed septic system? This is a very
expensive system, who will be paying for it on
an ongoing basis?
As outlined on page 3.14-29, the DEIR did consider impacts on public sewer and stormwater conveyance infrastructure.

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 ATTACHMENT 1 / EXHIBIT A
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at a programmatic level throughout the DEIR. 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. Therefore, in conclusion, impacts associated with the relocation, construction, or expansion of public sewer infrastructure would be less than significant with mitigation incorporated; however, impacts associated with construction period impacts would remain significant and unavoidable even after implementation of all feasible mitigation measures.

C16-7 Darabont,
Frank
3/1/24 6. Increased requirements for Fire and Police
Services: This area is currently rural and
development of 1,300+ units would require a
dramatic increase in fire and police availability.

How would that be managed, and again, who is
paying for it on an ongoing basis?
As outlined in page 3.12-19, the DEIR did consider the impacts of increased demand for police protection services and resulting impacts from developing new facilities to accommodate increased demand and additional staff. The Monterey Police Department (MPD) is able to adjust staffing to be appropriate with population levels in order to maintain standards of service and accommodate the increase in calls for service anticipated with buildout of the Plan. Therefore, impacts would be less than significant.

Additionally, as outlined in page 3.12-19, the DEIR did consider the impacts of fire and emergency services. The MFD evaluates and can adjust staffing or equipment levels. The City of Monterey's 2022 Community Risk Assessment and Standards of Cover Study shows that 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. The Monterey Fire Department continues to explore opportunities for enhancing response times and service levels in the eastern portion of the City, which includes a potential new fire station near Highway 68 and Olmsted Road. This station would serve areas within the City of Monterey, Monterey County Regional Fire Protection District and Cypress Fire Protection District boundaries. While the location and design of this facility cannot be known at this time, ATTACHMENT 1 / EXHIBIT A
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the construction of a new station 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.

C16-8 Darabont,
Frank
3/1/24 7. Airport proximity: With the planned expansion of the airport, flight noise will be increasing.

Given this project's proximity to the airport,
flight noise will be a constant problem for the
occupants of this new development.

The EPA states that noise levels above 75 dB
are harmful and these levels will be exceeded
at the site. How will this be mitigated and have
you discussed this with the airport authority
yet?
In 2021, we experienced a tragic plane crash in
the neighborhood of Monterra, devastating one
home and causing several fatalities. There is a
potential danger of airplane crashes in this
area, and this danger would be increased
exponentially given the project's density.

What is your plan for protecting these
(endangered) species?
Also, with the land being converted into
concrete slabs and housing structures, you are
removing the natural cushioning that the green
belt provides to absorb the noise pollution
coming from the airport. With the impending
expansion of the airport, this noise pollution
will only increase.

What is your plan for mitigating the increased
noise pollution from the expanding airport, if
the green belt is converted into concrete and
housing?
I look forward to receiving your answers to
As detailed on page 3.11-28, the Airport Land Use Compatibility Plan (ALUCP) identifies the airport’s noise contours. The 65 dB contour is predominantly limited to the airport’s jurisdiction and does not overlap with areas where development is permitted or on housing sites identified in the Housing Element. Compliance with the General Plan Exterior Noise Exposure Standards for New Development would also limit the potential for placement of new sensitive uses within the 65 dB contour. Further, City standards and the California Building Code require an interior sound rating of 45 dB for new development involving for residences, schools, and other noise sensitive uses. As such, with adherence to State and local regulations and Proposed Plan standards, policies, and programs, implementation of the Proposed Plan would not expose people to excessive noise levels related to airport activities and there would be a less than significant impact with respect to this criterion.

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 ATTACHMENT 1 / EXHIBIT A
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the many questions and concerns I've raised
above.
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.

C17-1 Darabont,
Rae
3/1/24 My name is Rae Darabont, and I am a current
resident of the Monterra neighborhood in
Monterey, CA. It's just come to our attention that
there is a land overlay bordering Hwy 68/Olmsted
Rd/Via Malpaso (to the south of the airport) that is
being considered by the county for just under
1,400 units of state-mandated low-income housing
development.

While I agree whole-heartedly that affordable
housing is needed, and am not opposed to
additional residential development in our county, I
believe this is a terrible location for a housing
project of this density. I'm writing to you with the
following concerns:

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C17-2 Darabont,
Rae
3/1/24 1. Traffic on Olmsted Rd and Hwy 68:

There is a very important different between
inconvenient traffic (a fact of modern life for us
all) and catastrophic traffic, which is the type of
traffic development of this location would
create.

Please see response to comment C16-2 regarding traffic impacts.

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What is your plan for expanding the highway
and creating more lanes to this area? Who will
pay for infrastructure development of this
magnitude?
C17-3 Darabont,
Rae
3/1/24 2. Environmental impact: The area we're
discussing is currently home to a significant
amount of wildlife, some of them presently
endangered (mountain lions, for example). It is
also home to a significant number of heritage
oak trees. With a project of this density, how
are you proposing to mitigate the impact on
this sensitive area?
Please see response to comment C16-3 regarding wildlife impacts.

C17-4 Darabont,
Rae
3/1/24 3. Air quality: The additional traffic, especially considering the projected congestion and car
idling, will cause significant deterioration in
local air quality, both to onsite residents of the
new development to nearby existing
populations.

How will this air pollution be mitigated and
what is the cost to the county for these
measures?
Please see response to comment C16-4 regarding air quality impacts.

C17-5 Darabont,
Rae
3/1/24 4. Loss of scenic and rural character of the Hwy 68 corridor: The current residential zoning in
this area is one home per 10 acres of land in
order to preserve the rural character and
wildlife preservation of this area.

How does such a high density (10-15 units per
acre) fit into this environment without
destroying its character? Once it's built, this
area will be changed permanently! It cannot be
undone!
The removal of this greenbelt is a significant
adverse impact aesthetically and visually, as well
as being a devastating loss of habitat for many
keystone animal species that can be observed
on the subject parcel. This area is not just a
Please see response to comment C16-5 regarding aesthetic and scenic character impacts.

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blessing to the immediate neighbors of the
Hwy 68 Corridor, but to the entire Peninsula.

C17-6 Darabont,
Rae
3/1/24 5. Sewage: How will the sewer be managed? Will
it be a closed septic system? This is a very
expensive system, who will be paying for it on
an ongoing basis?
Please see response to comment C16-6 regarding.stormwater conveyance infrastructure.

C17-7 Darabont,
Rae
3/1/24 6. Increased requirements for Fire and Police
Services: This area is currently rural and
development of 1,300+ units would require a
dramatic increase in fire and police availability.

How would that be managed, and again, who is
paying for it on an ongoing basis?
Please see response to comment C16-7 regarding fire and police service impacts.

C17-8 Darabont,
Rae
3/1/24 7. Airport proximity: With the planned expansion of the airport, flight noise will be increasing.

Given this project's proximity to the airport,
flight noise will be a constant problem for the
occupants of this new development.

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the neighborhood of Monterra, devastating one
home and causing several fatalities. There is a
potential danger of airplane crashes in this
area, and this danger would be increased
exponentially given the project's density.

C18-1 DePalatis,
Dale and
Caroline
3/13/24 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
Please see Master Response MR-1 regarding cumulative
development impacts on scenic resources in the southeast and south Monterey.

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and work in Monterey County, several of the
proposed sites are of particular concern especially
given the high density.

C18-2 DePalatis,
Dale and
Caroline
3/13/24 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:

C18-3 DePalatis,
Dale and
Caroline
3/13/24 *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 Regional Travel Demand Model (AMBAG RTDM) was used to
estimate VMT efficiency metrics across all land uses. The AMBAG RTDM 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 ATTACHMENT 1 / EXHIBIT A
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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.

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.

C18-4 DePalatis,
Dale and
Caroline
3/13/24 *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
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 ATTACHMENT 1 / EXHIBIT A
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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.
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.

C18-5 DePalatis,
Dale and
Caroline
3/13/24 *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.

ATTACHMENT 1 / EXHIBIT A
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C18-6 DePalatis,
Dale and
Caroline
3/13/24 *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.

C18-7 DePalatis,
Dale and
Caroline
3/13/24 *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
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 ATTACHMENT 1 / EXHIBIT A
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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?
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.

C18-8 DePalatis,
Dale and
Caroline
3/13/24 *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 increased demand for police protection services and resulting impacts from developing new facilities to accommodate increased demand and additional staff. The Monterey Police Department (MPD) is able to adjust staffing to be appropriate with population levels in order to maintain standards of service and to accommodate the increase in calls for service anticipated with buildout of the Plan.

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.

C18-9 DePalatis,
Dale and
Caroline
3/13/24 *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
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 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 ATTACHMENT 1 / EXHIBIT A
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will this be mitigated for current and future
residents?
in PM emissions due to the Proposed Plan.

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.

C18-
10 DePalatis,
Dale and
Caroline
3/13/24 *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 our 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
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.

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 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 ATTACHMENT 1 / EXHIBIT A
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courthouse and hospital, as well as parcels around
Cannery Row. Or what about finding some land in
Fort Ord?
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 not related to the adequacy of the DEIR; thus, no further response is required.

C19-1 Hamilton,
Jackie
3/20/24 I am writing to provide you with my comments
regarding the Draft EIR for the Monterey 2031
General Plan Update. I have resided on Oak Tree
Place for the past 27 years. After discovering the
proposals for this area, I have become extremely
concerned and alarmed at the potential impacts
these plans would have on this area in order to
meet state mandates. I believe this plan will do way
more harm than good and other, more compatible,
sites must be identified on the peninsula to meet
these requirements. This is an important, sensitive
and already heavily encroached area that is
becoming more and more strained as the Garden
Road area and other sites down the highway
continue to be developed. We must leave this open
space or the entire area will become a
dysfunctional gridlock. We have been very close to
fire evacuation twice and as we live on the edge of
a pine preserve this is an extremely volatile area for
fire. How on earth would we all escape should a
fire hit the Jacks Peak area? As a highly dense forest
filled with flammable pines, we constantly consider
how quickly our homes will be threatened
should fire spark in that forest. With two lane roads
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. 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 transitoriented 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 ATTACHMENT 1 / EXHIBIT A
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and an already congested highway, how on earth
would we all escape should this area be developed
further?
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.

As such, impacts on emergency access are less than significant.

Regarding evacuation, page 3.15-21 of the DEIR notes that under a multi-hazard evacuation scenario, traffic volumes would surpass capacity as traffic approaches Highway 1 at two locations in the network: the interchange of Fremont Street-Highway 1, where the volume to capacity ratio (v/c) would be 1.2, and at the Soledad Drive-Highway 1 approach, where the v/c ratio would be 1.1. This is a potentially significant impact; therefore mitigation measure MM-WF-1, which involves measures to temporarily increase capacity at constrained locations and proactively manage vehicle flow, is required to reduce this impact to a less than significant level. However, the highway on-ramps are part of the State transportation network, under the jurisdiction of Caltrans.

Therefore, overall this impact is considered significant and unavoidable.

C19-2 Hamilton,
Jackie
3/20/24 Freeway traffic is so congested in the mornings and afternoons that commuters are utilizing the rural
route from hwy 68, through upper Aguajito Road
and across Olmsted Road to the Salinas Highway.

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 ATTACHMENT 1 / EXHIBIT A
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This two lane road has become a speedway, too
dangerous to walk, cross over, bike ride or pull out
onto. I cannot even fathom what this massive
additional population would do to this already
dangerous situation.
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 Regional Travel Demand Model (AMBAG RTDM) was used to
estimate VMT efficiency metrics across all land uses. The AMBAG RTDM 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.

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 ATTACHMENT 1 / EXHIBIT A
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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.

C19-3 Hamilton,
Jackie
3/20/24 Wildlife has very little open space left to hunt, forage and travel. It is not unusual on any given day
to see coyotes and deer crossing through. We have
had many visits by mountain lions and bobcats in
our yard. At one point a black bear even visited.

Please don’t take this remaining land from them.

They are not less important than humans.

Regarding habitat connectivity, page 3.4-37 of the DEIR details that 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.

C19-4 Hamilton,
Jackie
3/20/24 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
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, 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 ATTACHMENT 1 / EXHIBIT A
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designation of Highway 68 as a scenic corridor
would be in jeopardy.

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.

C19-5 Hamilton,
Jackie
3/20/24 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.

C19-6 Hamilton,
Jackie
3/20/24 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
Please see response to comment C2-3 regarding projections of population growth and corresponding housing needs. Please also see Master Response MR-1 regarding cumulative development impacts on scenic resources in the southeast and south Monterey.

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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.

C19-7 Hamilton,
Jackie
3/20/24 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.

C19-8 Hamilton,
Jackie
3/20/24 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.

C19-9 Hamilton,
Jackie
3/20/24 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
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 ATTACHMENT 1 / EXHIBIT A
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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.
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.

C19-
10 Hamilton,
Jackie
3/20/24 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.

See response to comment C55-7 regarding airport proximity. 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.

C19-
11 Hamilton,
Jackie
3/20/24 Goal 9 states that the Proposed Plan should
“support a vibrant local economy.” This goal is what
Please see response to comment C2-8 regarding Goal 9 and Increased Workforce Housing Alternative.

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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?
C19-
12 Hamilton,
Jackie
3/20/24 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
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
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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destroying the natural beauty and rural character
that attracts tourists to visit and retirees to
relocate to the Monterey Peninsula.

C20-1 Hamilton,
Randy
3/15/24 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.

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

C20-2 Hamilton,
Randy
3/15/24 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:

C20-3 Hamilton,
Randy
3/15/24 Violation of the City’s own objective #6: “ ….

Maintaining existing neighborhood characteristics”
(pg ES-3). The proposed plan would significantly
effect the current neighborhood in a very bad way.

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

C20-4 Hamilton,
Randy
3/15/24 *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.

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 RTDM 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.

As such, the Proposed Plan incorporates strategies to promote the development of mixed use villages and transit-oriented ATTACHMENT 1 / EXHIBIT A
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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.

C20-5 Hamilton,
Randy
3/15/24 *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
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 ATTACHMENT 1 / EXHIBIT A
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what California state criteria is for affordable
housing.
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 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.

C20-6 Hamilton,
Randy
3/15/24 *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.

C20-7 Hamilton,
Randy
3/15/24 *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
As outlined in page 3.12-19, the DEIR did consider the impacts of fire and emergency services. 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 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 City-owned fire station would likely be needed to serve ATTACHMENT 1 / EXHIBIT A
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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?
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.

C20-8 Hamilton,
Randy
3/15/24 *Police Protection. This proposed rezoning will place an untenable burden on our existing police
resources, which already are in critical shortage.

C20-9 Hamilton,
Randy
3/15/24 *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
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.

Regarding hazardous materials, as outlined on page 3.8-27, none of ATTACHMENT 1 / EXHIBIT A
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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.
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 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 not related to the adequacy of the DEIR; thus, no further response is required.

C21-1 Harril,
Meredith
3/25/24 I wish to express my disapproval of development of the Olmsted Road area. There are other areas
where infill development could be done where
infra-structure and nearby amenities are already in
place.

There are multiple limitations in the Olmsted area
regarding water, sewage, traffic, environmental
impacts, safety, HWY 68 impacts, fire and noise.

I think we can do much better. Thank you for
considering these concerns.

Please see response MR-1 regarding cumulative development in the southeast and south Monterey.

C22-1 Hawryluk,
Andrew
3/5/24 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
Please see response MR-1 regarding cumulative development in the southeast and south Monterey.

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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.

C22-2 Hawryluk,
Andrew
3/5/24 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:

C22-3 Hawryluk,
Andrew
3/5/24 *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.

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 ATTACHMENT 1 / EXHIBIT A
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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?
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 Regional Travel Demand Model (AMBAG RTDM) was used to
estimate VMT efficiency metrics across all land uses. The AMBAG RTDM 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.

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 ATTACHMENT 1 / EXHIBIT A
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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.

C22-4 Hawryluk,
Andrew
3/5/24 *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 and it is in
direct conflict with the governor’s 30x30 initiative.

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.

C22-5 Hawryluk,
Andrew
3/5/24 *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
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.

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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 cost- efficient approach is to reuse existing, under-utilized
facilities that already have streets, water, sewer,
power, etc.

C22-6 Hawryluk,
Andrew
3/5/24 *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.

C22-7 Hawryluk,
Andrew
3/5/24 *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
As outlined in page 3.12-19, the DEIR did consider the impacts of fire and emergency services. 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 ATTACHMENT 1 / EXHIBIT A
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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?
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 City-owned 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.

C22-8 Hawryluk,
Andrew
3/5/24 *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 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?
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.

MM-AQ-5 would reduce TAC and localized CO and PM exposure to future sensitive receptors but not for receptors at land uses ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2328, Packet Page 2656 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
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Letter Commenter Date Comment Response
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.

C22-9 Hawryluk,
Andrew
3/5/24 *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 ~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) .

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.

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 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 ATTACHMENT 1 / EXHIBIT A
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Letter Commenter Date Comment Response
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.

C23-1 Healy, Linda 3/5/24 I completely agree with Beth's letter attached This comment is not related to the adequacy of the DEIR; thus, no further response is required.

C23-2 Healy, Linda 3/5/24 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.

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

C23-3 Healy, Linda 3/5/24 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:

C23-4 Healy, Linda 3/5/24 *Traffic on Olmstead Road and Highway 68, including the proposed roundabout: It can be
First, it should be noted that under the California Environmental Quality Act (CEQA), traffic volume or level of service (LOS) can ATTACHMENT 1 / EXHIBIT A
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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?
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 Regional Travel Demand Model (AMBAG RTDM) was used to
estimate VMT efficiency metrics across all land uses. The AMBAG RTDM 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.

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, ATTACHMENT 1 / EXHIBIT A
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Letter Commenter Date Comment Response
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.

C23-5 Healy, Linda 3/5/24 *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.

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 BIOATTACHMENT 1 / EXHIBIT A Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2332, Packet Page 2660 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
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Letter Commenter Date Comment Response
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.

C23-6 Healy, Linda 3/5/24 *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.

C23-7 Healy, Linda 3/5/24 *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 ATTACHMENT 1 / EXHIBIT A
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Letter Commenter Date Comment Response
safety hazards potentially resulting from new development to the maximum extent practicable. Associated impacts would be less than significant.

C23-8 Healy, Linda 3/5/24 *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
how this firebreak is vital to community safety
along the entire Hwy 68 corridor?
As outlined in page 3.12-19, the DEIR did consider the impacts of fire and emergency services. 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 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 City-owned 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.

C23-9 Healy, Linda 3/5/24 *Police Protection. This proposed rezoning will place an untenable burden on our existing police
resources, which already are in critical shortage.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2334, Packet Page 2662 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
2-413
Letter Commenter Date Comment Response
consulted and are they prepared to handle this high
density loading and increased risk?
C23-
10 Healy, Linda 3/5/24 *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 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.

C23-
11 Healy, Linda 3/5/24 *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
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 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2335, Packet Page 2663 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
2-414
Letter Commenter Date Comment Response
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) .

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

C24-1 Healy,
Michael
3/5/24 Please see the attached letter which I
wholeheartedly agree with. Please consider our
concerns going forward. I own property in
Monterra Ranch. Thank you should you address our
concerns and not proceed with this plan.

C24-2 Healy,
Michael
3/5/24 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
Please see Master Response MR-1 regarding cumulative
development impacts on scenic resources in the southeast and south Monterey.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2336, Packet Page 2664 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
2-415
Letter Commenter Date Comment Response
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.

C24-3 Healy,
Michael
3/5/24 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:

C24-4 Healy,
Michael
3/5/24 *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
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 ATTACHMENT 1 / EXHIBIT A
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Letter Commenter Date Comment Response
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?
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 Regional Travel Demand Model (AMBAG RTDM) was used to
estimate VMT efficiency metrics across all land uses. The AMBAG RTDM 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.

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.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2338, Packet Page 2666 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
2-417
Letter Commenter Date Comment Response
C24-5 Healy,
Michael
3/5/24 *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.

C24-6 Healy,
Michael
3/5/24 *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
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 ATTACHMENT 1 / EXHIBIT A
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Letter Commenter Date Comment Response
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.
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.

C24-7 Healy,
Michael
3/5/24 *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.

C24-8 Healy,
Michael
3/5/24 *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.

As outlined in page 3.12-19, the DEIR did consider the impacts of fire and emergency services. 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 with buildout of the Plan. However, fire and emergency medical response services are currently provided ATTACHMENT 1 / EXHIBIT A
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Letter Commenter Date Comment Response
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?
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 City-owned 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.

C24-9 Healy,
Michael
3/5/24 *Police Protection. This proposed rezoning will
place an untenable burden on our existing police
resources, which already are in critical shortage.

C24-
10 Healy,
Michael
3/5/24 *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
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 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 ATTACHMENT 1 / EXHIBIT A
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will this be mitigated for current and future
residents?
existing nonattainment status for PM10 and the expected increase in PM emissions due to the Proposed Plan.

C24-
11 Healy,
Michael
3/5/24 *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
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.

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 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 ATTACHMENT 1 / EXHIBIT A
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empty lots next to MPC and Casa Verde, the old
courthouse and hospital, as well as parcels around
Cannery Row.
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 not related to the adequacy of the DEIR; thus, no further response is required.

C25-1 Heinrich,
Dana
3/5/24 The following letter completely expresses my
thoughts and concerns regarding this proposed
development off Highway 68 owned by the
Monterey Peninsula School District.

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

C25-2 Heinrich,
Dana
3/5/24 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.

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

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C25-3 Heinrich,
Dana
3/5/24 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:

C25-4 Heinrich,
Dana
3/5/24 *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.

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 RTDM 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 ATTACHMENT 1 / EXHIBIT A
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the County, including Monterey County, inform the model’s 2045 cumulative year.

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.

C25-5 Heinrich,
Dana
3/5/24 *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
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 ATTACHMENT 1 / EXHIBIT A
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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.

Program 1-I, the Project would not substantially degrade character and aesthetics, and impacts would be less than significant.

C25-6 Heinrich,
Dana
3/5/24 *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.

C25-7 Heinrich,
Dana
3/5/24 *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
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 ATTACHMENT 1 / EXHIBIT A
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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?
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.

C25-8 Heinrich,
Dana
3/5/24 *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.

ATTACHMENT 1 / EXHIBIT A
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how this firebreak is vital to community safety
along the entire Hwy 68 corridor?
C25-9 Heinrich,
Dana
3/5/24 *Police Protection. This proposed rezoning will
place an untenable burden on our existing police
resources, which already are in critical shortage.

C25-
10 Heinrich,
Dana
3/5/24 *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 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.

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 ATTACHMENT 1 / EXHIBIT A
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operational activity commences. Therefore, after mitigation, this impact would be significant and unavoidable.

C25-
11 Heinrich,
Dana
3/5/24 *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) .

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 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.

C26-1 Hennington
, Daian
3/25/24 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.

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

C26-2 Hennington
, Daian
3/25/24 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.

As detailed on page 3.15-23, all new construction under the Proposed Plan would be subject to the California Fire Code, which include safety measures to minimize the threat of fire, including ignition-resistant construction with exterior walls of
noncombustible or ignition resistant material from the surface of the ground to the roof system and sealing any gaps around doors, windows, eaves, and vents to prevent intrusion by flame or embers.

Construction would also be required to meet CBC requirements, including CCR Title 24, Part 2, which includes specific requirements related to exterior wildfire exposure. The Board of Forestry, via CCR Title 14, sets forth the minimum development standards for emergency access, fuel modification, setback, signage, and water supply, which help prevent loss of structures or life by reducing wildfire hazards. The codes and regulations would reduce the risk of loss, injury, or death from wildfire for new developments under the Proposed Plan to a less-than-significant level.

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 ATTACHMENT 1 / EXHIBIT A
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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.

Further, as detailed on page 3.9-23, withdrawals of surface water from the Carmel River have been limited to protect threatened species that live in the river. The Seaside Basin is under a courtordered reduction schedule limiting groundwater withdrawals.

Groundwater pumping is limited to protect the basin from overuse and to prevent saltwater intrusion into the aquifer, which would contaminate the freshwater supply. Therefore,
implementation of the Proposed Plan would not deplete
groundwater supplies or interfere substantially with groundwater recharge as the withdrawals of Carmel Valley and Seaside Basins are limited. Therefore, associated groundwater impacts would be less than significant.

C26-3 Hennington
, Daian
3/25/24 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.

C26-4 Hennington
, Daian
3/25/24 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
Please see response to comment C1-4 regarding traffic, response to comment C1-7 regarding airport impacts, response to
comment C1-10 regarding air quality, and response to comments C1-8 and C1-9, respectively, for fire and police services.

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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 infill 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
infrastructure readily accessible.

C27-1 Hogan,
Michael
3/19/24 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,
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.

C27-2 Hogan,
Michael
3/19/24 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
As detailed on page 3.15-23, given that the Project proposes development in the Highway 68 area and the extent of which VHFHSZs exist in and around Monterey, buildout of the Proposed Plan could increase the risk of loss and damage due to wildfire, resulting in potentially significant impacts. However, construction would be required to meet CBC requirements, including CCR Title 24, Part 2, which includes specific requirements related to exterior wildfire exposure. The Board of Forestry, via CCR Title 14, sets forth the minimum development standards for emergency access, fuel modification, setback, signage, and water supply, which help prevent loss of structures or life by reducing wildfire hazards.

Required adherence to the codes and regulations would reduce ATTACHMENT 1 / EXHIBIT A
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the risk of loss, injury, or death from wildfire for new developments under the Proposed Plan to a less-than-significant level.

C27-3 Hogan,
Michael
3/19/24 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
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.

C27-4 Hogan,
Michael
3/19/24 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
As detailed on page 3.11-20, the DEIR did consider impacts on noise and sound levels. Noise from individual construction projects carried out under the Proposed Plan would likely result in temporary increases in ambient noise levels at 25 feet and at adjacent property lines. As the precise details and timeframes for individual development projects that would be carried out under the Proposed Plan cannot be known at this time, it is not possible to determine exact noise levels, locations, or time periods for construction of such projects, or construction noise at adjacent properties. The severity of construction-related noise impacts depends on the proximity of construction activities to sensitive receptors, the presence of intervening barriers, the number and types of equipment used, and the duration of the activity.

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Individual projects pursuant to the Proposed Plan would be required to comply with Monterey City Code Section 38-112.2, which designates times associated with all construction, alteration, remodeling, demolition and repair activities. Implementation of policies contained in the General Plan would further reduce construction noise and associated impacts. Goal d allows only new construction where existing or projected noise levels are acceptable or can be mitigated. Under Policy d.1, the City would require noise mitigation to reduce interior noise levels to an acceptable level. Table 8 of the General Plan Noise Element establishes the land use compatibility standards for new development. Further, under Policy d.2 the City would limit the hours of noise generating construction activities as a condition of project approval.

Compliance with existing time-of-day restrictions for construction activities as well as the applicable Monterey City Code and General Plan policies would ensure that impacts related to construction noise would be less than significant.

C27-5 Hogan,
Michael
3/19/24 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
As outlined in page 3.3-41, the DEIR did consider air quality impacts from area, energy, and mobile source emissions of criteria air pollutants and precursors. 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 transitoriented 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, thus reducing the mobile source emissions, 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 ATTACHMENT 1 / EXHIBIT A
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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.

C28-1 Hunt,
Grant
3/6/24 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.

C28-2 Hunt,
Grant
3/6/24 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 overtaxed 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
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 into 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.

Regarding highway access, page 3.15-21 of the DEIR notes that under a multi-hazard evacuation scenario, traffic volumes would surpass capacity as traffic approaches Highway 1 at two locations in the network: the interchange of Fremont Street-Highway 1, where the volume to capacity ratio (v/c) would be 1.2, and at the Soledad Drive-Highway 1 approach, where the v/c ratio would be ATTACHMENT 1 / EXHIBIT A
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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.

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.

1.1. This is a potentially significant impact; therefore, mitigation measure MM-WF-1, which involves measures to temporarily increase capacity at constrained locations and proactively manage vehicle flow, is required to reduce this impact to a less than significant level. However, the highway on-ramps are part of the State transportation network, under the jurisdiction of Caltrans.

Therefore, overall this impact is considered significant and unavoidable.

Please see also Master Response MR-1 regarding cumulative development in the southeast and south Monterey, including the discussion of traffic congestion therein.

C28-3 Hunt,
Grant
3/6/24 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
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.

ATTACHMENT 1 / EXHIBIT A
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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.

C28-4 Hunt,
Grant
3/6/24 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).

C28-5 Hunt,
Grant
3/6/24 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.

As detailed on page 3.15-23, given that the Project proposes development in the Highway 68 area and the extent of which VHFHSZs exist in and around Monterey, buildout of the Proposed Plan could increase the risk of loss and damage due to wildfire, resulting in potentially significant impacts. However, construction would be required to meet CBC requirements, including CCR Title 24, Part 2, which includes specific requirements related to exterior wildfire exposure. The Board of Forestry, via CCR Title 14, sets forth the minimum development standards for emergency access, fuel modification, setback, signage, and water supply, which help prevent loss of structures or life by reducing wildfire hazards.

Required compliance with the codes and regulations would reduce the risk of loss, injury, or death from wildfire for new developments under the Proposed Plan to a less-than-significant level.

C28-6 Hunt,
Grant
3/6/24 Water
So, our Peninsula residents have been told for
decades that there is no additional water for
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 ATTACHMENT 1 / EXHIBIT A
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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?
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?
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.

C29-1 Hunt, Susan 3/18/24 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 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.

C29-2 Hunt, Susan 3/18/24 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 SR68 because of the already over-taxed traffic in that 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 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2358, Packet Page 2686 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
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Letter Commenter Date Comment Response
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 cityproposed 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.

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.
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.

C29-3 Hunt, Susan 3/18/24 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
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 ATTACHMENT 1 / EXHIBIT A
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Letter Commenter Date Comment Response
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 mouse with a howitzer. It is hard to
square up a policy proposal to dramatically increase
the supply of housing while population demand is
falling.
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.

C29-4 Hunt, Susan 3/18/24 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).

C29-5 Hunt, Susan 3/18/24 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
As detailed on page 3.15-23, given that the Project proposes development in the Highway 68 area and the extent of which VHFHSZs exist in and around Monterey, buildout of the Proposed Plan could increase the risk of loss and damage due to wildfire, resulting in potentially significant impacts. However, construction would be required to meet CBC requirements, including CCR Title 24, Part 2, which includes specific requirements related to ATTACHMENT 1 / EXHIBIT A
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Letter Commenter Date Comment Response
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.
exterior wildfire exposure. The Board of Forestry, via CCR Title 14, sets forth the minimum development standards for emergency access, fuel modification, setback, signage, and water supply, which help prevent loss of structures or life by reducing wildfire hazards.

Required compliance with the codes and regulations would reduce the risk of loss, injury, or death from wildfire for new developments under the Proposed Plan to a less-than-significant level.

C29-6 Hunt, Susan 3/18/24 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?
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?
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.

C30-1 Jacobs,
Stuart
3/21/24 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
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 ATTACHMENT 1 / EXHIBIT A
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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.
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.

C30-2 Jacobs,
Stuart
3/21/24 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
Please see response to comment C2-2 regarding projections of population growth and corresponding housing needs. Please also see Master Response MR-1 regarding cumulative development impacts on scenic resources in the southeast and south Monterey.

ATTACHMENT 1 / EXHIBIT A
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be a need for 3 times as many housing units as new
jobs, as is proposed.

C30-3 Jacobs,
Stuart
3/21/24 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.

Please see response to comment C2-3 regarding projections of population growth and corresponding housing needs. Please also see Master Response MR-1 regarding cumulative development impacts on scenic resources in the southeast and south Monterey.

C30-4 Jacobs,
Stuart
3/21/24 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.

C30-5 Jacobs,
Stuart
3/21/24 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
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.

ATTACHMENT 1 / EXHIBIT A
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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.

C30-6 Jacobs,
Stuart
3/21/24 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 adopted for the purpose of avoiding or mitigating an
environmental effect.

C30-7 Jacobs,
Stuart
3/21/24 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 ATTACHMENT 1 / EXHIBIT A
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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 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.

C30-8 Jacobs,
Stuart
3/21/24 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
Please see response to comment C2-8 regarding Goal 9 and Increased Workforce Housing Alternative.

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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?
C30-9 Jacobs,
Stuart
3/21/24 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
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.

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Thank you for your time and consideration of my
input.

C31-1 Jamieson,
Peter and
Kay
3/20/24 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.

Thank you for your letter. 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, 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 for most projects under CEQA.

C31-2 Jamieson,
Peter and
Kay
3/20/24 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.

C31-3 Jamieson,
Peter and
Kay
3/20/24 Environmental--Related to above, this area is a huge and significant wildlife corridor and is home to
beautiful heritage oaks, wild flowers, deer, fox,
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 ATTACHMENT 1 / EXHIBIT A
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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.
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 specialstatus 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. Regarding habitat connectivity, page

3.4-37 of the DEIR details that 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.

C31-4 Jamieson,
Peter and
Kay
3/20/24 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.

C31-5 Jamieson,
Peter and
Kay
3/20/24 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.

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. As ATTACHMENT 1 / EXHIBIT A
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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.

C31-6 Jamieson,
Peter and
Kay
3/20/24 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.

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 ATTACHMENT 1 / EXHIBIT A
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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.

C31-7 Jamieson,
Peter and
Kay
3/20/24 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.

C32-1 Jones,
Michelle
3/15/24 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.

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

C32-2 Jones,
Michelle
3/15/24 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
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 lowATTACHMENT 1 / EXHIBIT A Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2370, Packet Page 2698 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
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California's desire for infill on already developed
land and pose significant risk, including:
income and moderate-income housing units. As such the proposed development at the site is consistent with previous City planning efforts.

C32-3 Jones,
Michelle
3/15/24 *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.

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 RTDM 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.

As such, the Proposed Plan incorporates strategies to promote ATTACHMENT 1 / EXHIBIT A
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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.

C32-4 Jones,
Michelle
3/15/24 *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
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.

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 ATTACHMENT 1 / EXHIBIT A
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what California state criteria is for affordable
housing.

C32-5 Jones,
Michelle
3/15/24 *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.

C32-6 Jones,
Michelle
3/15/24 *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 ATTACHMENT 1 / EXHIBIT A
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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.

C32-7 Jones,
Michelle
3/15/24 *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
how this firebreak is vital to community safety
along the entire Hwy 68 corridor?
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.

C32-8 Jones,
Michelle
3/15/24 *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
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 ATTACHMENT 1 / EXHIBIT A
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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?
plans in place to increase staffing over the next five to ten years.

Therefore, impacts would be less than significant.

C32-9 Jones,
Michelle
3/15/24 *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 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.

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.

C32-
10 Jones,
Michelle
3/15/24 *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
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 ATTACHMENT 1 / EXHIBIT A
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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) .

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

C33-1 Kim, Young 3/22/24 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
Please see Master Response MR-1 regarding cumulative
development impacts on scenic resources in the southeast and south Monterey.

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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.

C33-2 Kim, Young 3/22/24 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:

C33-3 Kim, Young 3/22/24 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
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 ATTACHMENT 1 / EXHIBIT A
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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?
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 Regional Travel Demand Model (AMBAG RTDM) was used to
estimate VMT efficiency metrics across all land uses. The AMBAG RTDM 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.

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 ATTACHMENT 1 / EXHIBIT A
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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.

C33-4 Kim, Young 3/22/24 *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.

C33-5 Kim, Young 3/22/24 *Pedestrian and Bicycle safety: It is not clear the roads in and out of the 640 unit housing complex
As outlined in page 3.13-17, the DEIR did consider impacts to pedestrian and bicycle safety. The proposed Circulation Element ATTACHMENT 1 / EXHIBIT A
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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.
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.

C33-6 Kim, Young 3/22/24 *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.

C33-7 Kim, Young 3/22/24 *Fire Protection. This development would come with extraordinary expense of added fire response
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 ATTACHMENT 1 / EXHIBIT A
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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?
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.

C33-8 Kim, Young 3/22/24 *Police Protection. This proposed rezoning will place an untenable burden on our existing police
resources, which already are in critical shortage.

C33-9 Kim, Young 3/22/24 *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
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 ATTACHMENT 1 / EXHIBIT A
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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?
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.

C33-
10 Kim, Young 3/22/24 *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
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.

Fort Ord has been cleared of 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 not related to the adequacy of the DEIR; thus, no further response is required.

C34-1 Lanier,
Andrew
and Brent
3/25/24 We are writing to voice opposition 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.

C34-2 Lanier,
Andrew
and Brent
3/25/24 First, the proposed plan at Olmsted Road and
surrounding areas would adversely impact the
health and welfare of the community. The draft
Environmental Impact Report (EIR) concedes that
the proposed plan would both degrade air quality
through pollution and “generate substantial traffic”
in the Olmsted Road/Highway68 planning area.

Increased traffic flow and congestion will invariably
generate environmental pollutants. In fact, the EIR
states the planning areas around Highway 68 are
“hotspots” for CO emissions. In addition, the
extent of impact on air quality in the Olmsted
Road/Highway 68 area is not known without
additional research. Specifically, the EIR suggests
Please see response to comment C1-4 regarding traffic and response to comment C1-10 regarding air quality. Air quality impacts were analyzed in Chapter 3.3 Air Quality. The DEIR does not suggest that the Olmsted Road/Highway 68 area need
additional analysis to full assess air quality impacts. There is sufficient detail for a programmatic EIR; however, individual projects would need further analysis when the projects are proposed in order to assess their project-specific impacts.

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that the Olmsted Road/Highway 68 area needs
additional study to fully assess air quality impact.

C34-3 Lanier,
Andrew
and Brent
3/25/24 Next, the proposed plan poses an increased risk of wildfire danger. According to the Draft 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 mitigation efforts to reduce wildfire and
other hazardous risks to the community. By
removing the existing essential fire break, the
proposed development at Olmsted and
surrounding areas substantially increases the risk of
fire danger to the lives, property, and watersheds of
the community.

As detailed on page 3.15-23, given that the Project proposes development in the Highway 68 area and the extent of which VHFHSZs exist in and around Monterey, buildout of the Proposed Plan could increase the risk of loss and damage due to wildfire, resulting in potentially significant impacts. However, construction would be required to meet CBC requirements, including CCR Title 24, Part 2, which includes specific requirements related to exterior wildfire exposure. The Board of Forestry, via CCR Title 14, sets forth the minimum development standards for emergency access, fuel modification, setback, signage, and water supply, which help prevent loss of structures or life by reducing wildfire hazards.

Required compliance with the codes and regulations would reduce the risk of loss, injury, or death from wildfire for new developments under the Proposed Plan to a less-than-significant level.

C34-4 Lanier,
Andrew
and Brent
3/25/24 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 priorities. 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 better 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 preservation.

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 ATTACHMENT 1 / EXHIBIT A
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the potential to occur in the Planning Area are outlined in Table

C34-5 Lanier,
Andrew
and Brent
3/25/24 In addition, the proposed plan would adversely
impact water supply. As written, the EIR needs
addition research to address potential decreases
groundwater supplies and water quality. The report
acknowledges that construction 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.

Please see Master Response MR-2 regarding impacts on water supply.

Analysis regarding hydrology and water quality is included in Chapter 3.9 of the DEIR. As detailed on page 3.9-21 of the DEIR, construction activities arising from implementation of the Proposed Plan, such as grading and other construction-related earth-disturbing activities, could result in short-term water quality impacts. However, compliance with the State Construction General Permit, Monterey City Code (Chapter 31.5, Article 2) requirements, and submission of Erosion and Sediment Control Plans would ensure that best management practices (BMPs) would be implemented to control soil erosion and sedimentation and restrict non-stormwater discharges from construction sites as well as any release of hazardous materials. These standard National Pollutant Discharge Elimination System (NPDES) and local required construction period measures would reduce the
construction period pollutants entering waterbodies to a less-than significant level.

C34-6 Lanier,
Andrew
and Brent
3/25/24 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 aircraft flights and
operations at the Monterey Regional Airport.”
Adding increased traffic volume along
Olmsted/Highway 68 near the airport exacerbates
As detailed on page 3.11-28, the Airport Land Use Compatibility Plan (ALUCP) identifies the airport’s noise contours. The 65 dB contour is predominantly limited to the airport’s jurisdiction and does not overlap with areas where development is permitted or on housing sites identified in the Housing Element. Compliance with the General Plan Exterior Noise Exposure Standards for New Development would also limit the potential for placement of new sensitive uses within the 65 dB contour. Further, City ATTACHMENT 1 / EXHIBIT A
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existing noise concerns. As written, the plan needs
additional study and mitigation techniques to
ensure minimal impact on noise in this area to
comply with existing with Monterey regulations.

We hope you will consider our concerns. Thank
you for your time and consideration.
standards and the California Building Code require an interior sound rating of 45 dB for new development involving for residences, schools, and other noise sensitive uses. As such, with adherence to State and local regulations and Proposed Plan standards, policies, and programs, implementation of the Proposed Plan would not expose people to excessive noise levels related to airport activities and there would be a less than significant impact with respect to this criterion.

C35-1 Lovett,
Nigel
3/19/24 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.

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 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.

C35-2 Lovett,
Nigel
3/19/24 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
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 ATTACHMENT 1 / EXHIBIT A
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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.

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 Regional Travel Demand Model (AMBAG RTDM) was used to
estimate VMT efficiency metrics across all land uses. The AMBAG RTDM 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.

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 ATTACHMENT 1 / EXHIBIT A
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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.

C35-3 Lovett,
Nigel
3/19/24 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.

Please see also Master Response MR-2 regarding water supply and 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.

C36-1 MacHarg,
Carlyle
3/24/24 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
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 into 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 character and aesthetics, and impacts would be less than significant.

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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.

C36-2 MacHarg,
Carlyle
3/24/24 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.

41.9% growth in housing units.

C36-3 MacHarg,
Carlyle
3/24/24 PROPOSED PLAN CONFLICTS WITH PROJECT

OBJECTIVES
The Proposed Plan, which includes development of
the 50 acre parcel on Highway 68, conflicts with six
Please see response to comment C2-3 regarding projections of population growth and corresponding housing needs. Please also see Master Response MR-1 regarding cumulative development impacts on scenic resources in the southeast and south Monterey.

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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.

C36-4 MacHarg,
Carlyle
3/24/24 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.

C36-5 MacHarg,
Carlyle
3/24/24 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.

C36-6 MacHarg,
Carlyle
3/24/24 Goal 8 states that appropriate housing sites “are proximate to transportation, shopping and
schools…” This goal is in line with the State of
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 ATTACHMENT 1 / EXHIBIT A
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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.
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.

C36-7 MacHarg,
Carlyle
3/24/24 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.

In addition, page 3.11-27 of the DEIR states that portions of the ATTACHMENT 1 / EXHIBIT A
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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.

C36-8 MacHarg,
Carlyle
3/24/24 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
Please see response to comment C2-8 regarding Goal 9 and Increased Workforce Housing Alternative.

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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?
C36-9 MacHarg,
Carlyle
3/24/24 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
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.

C37-1 MacHarg,
Kimiko
3/24/24 We are nearby residents of the proposed housing project for 640 units off Highway 68 currently
owned by the Monterey Peninsula School District.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2393, Packet Page 2721 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
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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.

C37-2 MacHarg,
Kimiko
3/24/24 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:

C37-3 MacHarg,
Kimiko
3/24/24 *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.

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 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2394, Packet Page 2722 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
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Regional Travel Demand Model (AMBAG RTDM) was used to
estimate VMT efficiency metrics across all land uses. The AMBAG RTDM 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.

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.

C37-4 MacHarg,
Kimiko
3/24/24 *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
"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 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2395, Packet Page 2723 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
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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.
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. 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 Measure 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."
C37-5 MacHarg,
Kimiko
3/24/24 *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
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, ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2396, Packet Page 2724 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
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Highway 68? This would also pose significant safety
risks.
ordinance, or policy addressing the circulation system, particularly bicycle and pedestrian facilities, and the impact would be less than significant.

C37-6 MacHarg,
Kimiko
3/24/24 *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.

C37-7 MacHarg,
Kimiko
3/24/24 *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.

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 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2397, Packet Page 2725 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
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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?
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.

C37-8 MacHarg,
Kimiko
3/24/24 *Police Protection. This proposed rezoning will place an untenable burden on our existing police
resources, which already are in critical shortage.

C37-9 MacHarg,
Kimiko
3/24/24 *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 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.

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. MMATTACHMENT 1 / EXHIBIT A Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2398, Packet Page 2726 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
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AQ-2 through MM-AQ-4 would reduce CO, diesel, and PM
(exhaust and fugitive dust) emissions during construction activities.

C37-
10 MacHarg,
Kimiko
3/24/24 *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, the east side of General Jim Moore
Parkway, and even Ft. Ord which I understand
would require significant clean up but it has to be
done sometime.

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 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 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2399, Packet Page 2727 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
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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.
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 not related to the adequacy of the DEIR; thus, no further response is required.

C38-1 McLoghlin,
Oona
3/12/24 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 trafficcongested air-polluted urbanized and undesirable area it will become, the type of area we’ve all
moved here to avoid. How is this ok?
Thank you for your letter. 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 Regional Travel Demand Model (AMBAG RTDM) was used to
estimate VMT efficiency metrics across all land uses. The AMBAG RTDM 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 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2400, Packet Page 2728 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
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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.

C38-2 McLoghlin,
Oona
3/12/24 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.

C38-3 McLoghlin,
Oona
3/12/24 JOBS
I would like to see the studies showing an increase
in new and available jobs in the area to support this
This comment pertains to the Proposed Plan and is not related to the adequacy of the DEIR; thus, no further response is required.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2401, Packet Page 2729 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
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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.

C38-4 McLoghlin,
Oona
3/12/24 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.

As detailed on page 3.15-23, given that the Project proposes development in the Highway 68 area and the extent of which VHFHSZs exist in and around Monterey, buildout of the Proposed Plan could increase the risk of loss and damage due to wildfire, resulting in potentially significant impacts. However, construction would be required to meet CBC requirements, including CCR Title 24, Part 2, which includes specific requirements related to exterior wildfire exposure. The Board of Forestry, via CCR Title 14, sets forth the minimum development standards for emergency access, fuel modification, setback, signage, and water supply, which help prevent loss of structures or life by reducing wildfire hazards.

The codes and regulations would reduce the risk of loss, injury, or death from wildfire for new developments under the Proposed Plan to a less-than-significant level.

C38-5 McLoghlin,
Oona
3/12/24 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.

Analysis regarding hydrology and water quality is included in Chapter 3.9 of the DEIR. As detailed on page 3.9-21 of the DEIR, construction activities arising from implementation of the Proposed Plan, such as grading and other construction-related earth-disturbing activities, could result in short-term water quality impacts. However, compliance with the State Construction General Permit, Monterey City Code (Chapter 31.5, Article 2) requirements, and submission of Erosion and Sediment Control Plan would ensure that best management practices (BMPs) would be implemented to control soil erosion and sedimentation and restrict non-stormwater discharges from construction sites as well as any release of hazardous materials. These standard National Pollutant Discharge Elimination System (NPDES) and local required construction period measures would reduce the
construction period pollutants entering waterbodies to a less-than significant level.

Additionally, analysis regarding hazards and hazardous materials is included in Chapter 3.8 of the DEIR. As detailed on page 3.8-28 of ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2402, Packet Page 2730 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
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the DEIR, the northernmost parcel within the Fort Ord/Ryan Ranch opportunity area (APN 031-191-018-000, referred to as parcel E29.1) is part of a munitions response area where unexploded ordnances (UXO) have been discovered. The site has been cleared of UXO to a level that permits light industrial uses; however, residential use is restricted and additional remediation in coordination with the U.S. Army, U.S. Environmental Protection Agency, and California Department of Toxic Substances Control is required before the residential restriction can be removed.

Program 1-H in the proposed Housing Element would involve preparation of a specific plan to foster the creation of a mixed-use village within the Fort Ord/Ryan Ranch opportunity area to provide housing, jobs, schools, shops, services and recreation for future residents while also preserving carefully selected areas of natural open space and habitat. The proposed Housing Element does not identify the parcel E29.1 as a site available for housing within the 2023-31 planning period; however, the General Plan land use diagram designates the parcel as a mixed use neighborhood.

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.

C38-6 McLoghlin,
Oona
3/12/24

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.

C38-7 McLoghlin,
Oona
3/12/24 COSTS
Low income housing is important, a given in every
city state and country in the world with few
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 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2403, Packet Page 2731 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
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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.

Plan will be considered by City decision-makers at adoption hearings.

C39-1 Menzies,
Lurline
3/5/24 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.

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

C39-2 Menzies,
Lurline
3/5/24 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 ATTACHMENT 1 / EXHIBIT A
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development at the site is consistent with previous City planning efforts.

C39-3 Menzies,
Lurline
3/5/24 *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.

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 RTDM 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.

As such, the Proposed Plan incorporates strategies to promote the development of mixed use villages and transit-oriented ATTACHMENT 1 / EXHIBIT A
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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.

C39-4 Menzies,
Lurline
3/5/24 *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
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 ATTACHMENT 1 / EXHIBIT A
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what California state criteria is for affordable
housing.
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 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.

C39-5 Menzies,
Lurline
3/5/24 *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.

C39-6 Menzies,
Lurline
3/5/24 *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 ATTACHMENT 1 / EXHIBIT A
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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.

C39-7 Menzies,
Lurline
3/5/24 *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
how this firebreak is vital to community safety
along the entire Hwy 68 corridor?
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.

C39-8 Menzies,
Lurline
3/5/24 *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
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 ATTACHMENT 1 / EXHIBIT A
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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?
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.

C39-9 Menzies,
Lurline
3/5/24 *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 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.

C39-
10 Menzies,
Lurline
3/5/24 *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
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
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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) .

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

C40-1 Nikssarian,
David
3/21/24 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.

C40-2 Nikssarian,
David
3/21/24 My biggest concerns are:
• Scenic Corridor/Sensitive Wildlife Area. The
proposed area is an environmentally sensitive 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 Elements includes ATTACHMENT 1 / EXHIBIT A
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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.
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 General Plan 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 southeast and south Monterey.

C40-3 Nikssarian,
David
3/21/24 Traffic Congestion. Highway 68 is the biggest traffic bottleneck in Monterey County. This will horribly
aggravate an already stressed traffic area.

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 RTDM 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 ATTACHMENT 1 / EXHIBIT A
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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.

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.

C40-4 Nikssarian,
David
3/21/24 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 precious 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
As detailed on page 3.2-10, the DEIR did consider impacts on agricultural resources. There are no active agricultural uses within the Planning Area; however, there is land in the southeast of the Planning Area classified as Grazing Land under the California Department of Conservation's Farmland Mapping and Monitoring Program (FMMP). The Grazing Land is currently identified as vacant in data from the Monterey County Assessor and there are no active agricultural uses in this area. This area is currently zoned as a Planned Community (PC) District, given that it falls within the Highway 68 Area Plan Planning Area. The Highway 68 Area Plan ATTACHMENT 1 / EXHIBIT A
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additional traffic stress, and protect a sensitive
environmental area.
identifies a 50-acre site owned by MPUSD as a potential location for 300 units of housing to meet the needs of low- and moderateincome households. Program 1-I of the proposed Housing Element would involve an update to the Highway 68 Plan that would permit the development of this parcel with up to 614 new housing units and neighborhood retail and services on a portion of the 50-acre site. While the development of housing on the 50-acre site would be consistent with the Highway 68 Area Plan and while there are no active agricultural activities on the site today, this would result in the conversion of Farmland classified by the FMMP to nonagricultural use, which is a potentially significant impact. Therefore, implementation of Mitigation Measure AG-1 is required.

Nevertheless, Farmland is a finite and irreplaceable resource, and therefore not directly mitigable. Even with the acquisition of comparable land or a conversation easement, the conversion of Grazing Land to non-agricultural uses would represent a permanent loss of such land. The impact would remain significant and unavoidable.

C41-1 Nikssarian,
Mary
Khasigian
3/21/24 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.

C41-2 Nikssarian,
Mary
Khasigian
3/21/24 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.

As detailed on page 3.2-10, the DEIR did consider impacts on agricultural resources. There are no active agricultural uses within the Planning Area; however, there is land in the southeast of the Planning Area classified as Grazing Land under the California Department of Conservation's Farmland Mapping and Monitoring Program (FMMP). The Grazing Land is currently identified as vacant in data from the Monterey County Assessor and there are no active agricultural uses in this area. This area is currently zoned as a Planned Community (PC) District, given that it falls within the Highway 68 Area Plan Planning Area. The Highway 68 Area Plan identifies a 50-acre site owned by MPUSD as a potential location for 300 units of housing to meet the needs of low- and moderateincome households. Program 1-I of the proposed Housing Element ATTACHMENT 1 / EXHIBIT A
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would involve an update to the Highway 68 Plan that would permit the development of this parcel with up to 614 new housing units and neighborhood retail and services on a portion of the 50-acre site. While the development of housing on the 50-acre site would be consistent with the Highway 68 Area Plan and while there are no active agricultural activities on the site today, this would result in the conversion of Farmland classified by the FMMP to nonagricultural use, which is a potentially significant impact. Therefore, implementation of Mitigation Measure AG-1 is required.

C41-3 Nikssarian,
Mary
Khasigian
3/21/24 Traffic Congestion. Highway 68 is the biggest traffic bottleneck in Monterey County. This will horribly
aggravate an already stressed traffic area.

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 RTDM has a base year of 2015 and a future year of 2045. The ATTACHMENT 1 / EXHIBIT A
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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.

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.

C41-4 Nikssarian,
Mary
Khasigian
3/21/24 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. I believe a
better alternative is the area on South Boundary
Road, which will allow residents to walk to work.

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 Elements 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 ATTACHMENT 1 / EXHIBIT A
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This will protect agricultural land, eliminate the
additional traffic stress, and protect a sensitive
environmental area.
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 scenic vistas and corridors and impacts would be less than significant.

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

C42-1 O'Neil,
Carol
3/25/24 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."
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.

ATTACHMENT 1 / EXHIBIT A
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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 RTDM 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.

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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C42-2 O'Neil,
Carol
3/25/24 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.

Analysis regarding utility and transportation improvements is included in Chapters 3.13 and 3.14 of the DEIR. As outlined in page 3.12-19, the DEIR did consider the impacts of police protection services. MPD has existing plans in place to increase staffing over the next five to ten years. The Monterey Police Department (MPD) is able to adjust staffing to be appropriate with population levels in order to maintain standards of service. 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. Additionally, 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.

C42-3 O'Neil,
Carol
3/25/24 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.

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

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C42-4 O'Neil,
Carol
3/25/24 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.

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 RTDM 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.

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 ATTACHMENT 1 / EXHIBIT A
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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.

C42-5 O'Neil,
Carol
3/25/24 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.

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

C43-1 O'Neil,
John
3/25/24 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.

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

C43-2 O'Neil,
John
3/25/24 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.

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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 RTDM 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.

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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C43-3 O'Neil,
John
3/25/24 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.

As detailed on page 3.11-28, the Airport Land Use Compatibility Plan (ALUCP) identifies the airport’s noise contours. The 65 dB contour is predominantly limited to the airport’s jurisdiction and does not overlap with areas where development is permitted or on housing sites identified in the Housing Element. Compliance with the General Plan Exterior Noise Exposure Standards for New Development would also limit the potential for placement of new sensitive uses within the 65 dB contour. Further, City standards and the California Building Code require an interior sound rating of 45 dB for new development involving for residences, schools, and other noise sensitive uses. As such, with adherence to State and local regulations and Proposed Plan standards, policies, and programs, implementation of the Proposed Plan would not expose people to excessive noise levels related to airport activities and there would be a less than significant impact with respect to this criterion.

C43-4 O'Neil,
John
3/25/24 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.

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 ATTACHMENT 1 / EXHIBIT A
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RTDM 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.

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.

Please see also response to comment C27-4 regarding noise.

C44-1 Pace,
Andrea
3/24/24 I live at (x) 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 easement, so never did we imagine
that it would be developed in such a drastic way!
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
ATTACHMENT 1 / EXHIBIT A
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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
units get fire insurance? And how will our fire
department protect us with 3000 new residents?
Please re-think this excessive and unsafe 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.

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C45-1 Powell,
Rebecca
3/11/24 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 beautiful natural area and to escape the
urbanization of other parts of this great state.

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

C45-2 Powell,
Rebecca
3/11/24 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 overutilized presently with
community travel, not to mention 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.

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 RTDM 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 ATTACHMENT 1 / EXHIBIT A
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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.

C45-3 Powell,
Rebecca
3/11/24 2. Our local airport is expanding, which will
already increase traffic for those who are
visiting 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
fatalities.

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 ATTACHMENT 1 / EXHIBIT A
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safety hazards potentially resulting from new development to the maximum extent practicable. Associated impacts would be less than significant.

C45-4 Powell,
Rebecca
3/11/24 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 mention amphibians and insects. They are
present on this parcel.

The DEIR did consider impacts on wildlife and plant 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 specialstatus 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.

C45-5 Powell,
Rebecca
3/11/24 4. Water is an issue for this whole community.

We conserve presently to maintain quality and
quantity for future usage. Will the water be
safe for this community if the Fort Ord toxic
chemicals are present?
Analysis regarding hydrology and water quality is included in Chapter 3.9 of the DEIR. As detailed on page 3.9-21 of the DEIR, construction activities arising from implementation of the Proposed Plan, such as grading and other construction-related earth-disturbing activities, could result in short-term water quality impacts. However, compliance with the State Construction General Permit, Monterey City Code (Chapter 31.5, Article 2) requirements, and submission of Erosion and Sediment Control Plan would ensure that best management practices (BMPs) would be implemented to control soil erosion and sedimentation and restrict non-stormwater discharges from construction sites as well as any release of hazardous materials. These standard National Pollutant Discharge Elimination System (NPDES) and local required construction period measures would reduce the
construction period pollutants entering waterbodies to a less-than significant level.

Additionally, analysis regarding hazards and hazardous materials is included in Chapter 3.8 of the DEIR. As detailed on page 3.8-28 of the DEIR, the northernmost parcel within the Fort Ord/Ryan Ranch opportunity area (APN 031-191-018-000, referred to as ATTACHMENT 1 / EXHIBIT A
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parcel E29.1) is part of a munitions response area where unexploded ordnances (UXO) have been discovered. The site has been cleared of UXO to a level that permits light industrial uses; however, residential use is restricted and additional remediation in coordination with the U.S. Army, U.S. Environmental Protection Agency, and California Department of Toxic Substances Control is required before the residential restriction can be removed.

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.

C45-6 Powell,
Rebecca
3/11/24 5. This area is a natural fire-retardant area for homes and wooded area in higher elevation.

Will this impact our insurance availability as
most insurance companies have already left
this state?
This comment is not related to the adequacy of the DEIR; thus, no further response is required.

C45-7 Powell,
Rebecca
3/11/24 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 facilities available
for living and transportation. The old County
Courthouse, our old part of the County
Hospital, Fort Ord Mixed Use Area and even
areas around the Carmel Barnyard
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.

However, they may not be sufficient to address PM impacts if the source results in significant PM concentrations, especially given the ATTACHMENT 1 / EXHIBIT A
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Redevelopment Area and Cannery Row are
areas that are not fully utilized.
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 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.

C46-1 Robbins,
Gail
3/2/24 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.

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

C46-2 Robbins,
Gail
3/2/24 That being said, the City of Monterey plan appears inappropriate in some areas. The congestion, gridlock 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.

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

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C46-3 Robbins,
Gail
3/2/24 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.

C46-4 Robbins,
Gail
3/2/24 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?
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.

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 ATTACHMENT 1 / EXHIBIT A
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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 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.

C46-5 Robbins,
Gail
3/2/24 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 buildings
should be the priority and commitment.

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

C47-1 Roth, Tom 3/6/24 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.

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

C47-2 Roth, Tom 3/6/24 DEIR. Volume l
Table of Contents
The Table of Contents fails to list all of the Figures
that are present in the DEIR.

Executive Summary
The comment is noted. The Table of Contents lists all figures in the DEIR; however, certain figures are listed twice. The following edits have been made:

DEIR Table of Contents p. vi
Figure 3.1-1 Scenic Corridors
.....................................................................................................................3.1 -5
Figure 3.1-2 Scenic Vistas
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..........................................................................................................................

3.1-6
Figure 3.1-1 Scenic Corridors
.....................................................................................................................3.1 -5
Figure 3.1-2 Scenic Vistas
...........................................................................................................................

3.1-6
This edit does not constitute significant new information requiring recirculation pursuant to CEQA Guidelines section 15088.5.

C47-3 Roth, Tom 3/6/24 In the Executive Summary, the City states "The Proposed Plan is both a policy document and an
implementation tool for implementing the City's
General Plan." It is unclear what the City means by
the term implementation 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 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 limited amendment to the 2003 Harbor Plan
LUP. Specifically, the Coastal Commission approved
The Proposed Plan does not involve a LCP under the Coastal Act.

As background, in the early 1990’s, the City of Monterey divided its coastal planning area into five subareas – Cannery Row, Monterey Harbor, Del Monte Beach, Skyline and Laguna Grande.

Land use plans were prepared for these areas. The Coastal Commission ultimately certified each of the land use plans from 1992 to 2004 except for the Laguna Grande Land Use Plan. This refers to the "City of Monterey Local Coastal Land Use Plans (1992-2004)." The City of Monterey Local Coastal Land Use Plans (1992-2004) did not include an Implementation Plan; therefore, the City does not have a certified Local Coastal Program.

The City is currently preparing a Local Coastal Program (a consolidated land use plan and implementation plan); this is a separate parallel process to the General Plan Update. Ultimately, the LCP will be reviewed and approved by the Coastal
Commission before it is locally adopted.

The Waterfront Master Plan was adopted by the City Council on February 16, 2016. The City is updating the Local Coastal Program through a separate parallel process at the moment. The LCP will be approved by the Coastal Commission before it is locally adopted. Information about the Waterfront Master Plan was used to establish the Environmental Setting of the Proposed Plan as outlined on page 3.12-13 of the EIR, and does not impact the analysis of the EIR. As such, the comment is not related to the adequacy of the DEIR; thus, no further response is required.

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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 resubmitted 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 not 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
In addition, the following edits has been made:

DEIR p. ES-1:
"The Proposed Plan is both a policy document and an
implementation tool for implementing the City’s General Plan a targeted update to the Housing, Land Use, Safety, and Circulation Elements of the City of Monterey General Plan (adopted in 2005)."
DEIR p. 1-6:
“City of Monterey Local Coastal Land Use Plan (2016)(1992- 2004)”
This clarification does not constitute significant new information requiring recirculation pursuant to CEQA Guidelines section 15088.5.

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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 C2. 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 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.)
C47-4 Roth, Tom 3/6/24 Page2-4
The DEIR states "Adopted in January 2005 and last
amended in June 2020, the current General Plan
Please see response to comment C47-3 regarding City of
Monterey Local Coastal Land Use Plans. The Proposed Plan does not include any sites within the Harbor Coastal Zone Planning ATTACHMENT 1 / EXHIBIT A
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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.

Area; therefore, the 2003 Monterey Harbor Land Use Plan is not discussed.

C47-5 Roth, Tom 3/6/24 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.

The property at 1099 Del Monte is displayed as "General Commercial" on DEIR Figure 2-2, Existing Land Use in the Planning Area. The existing land use category "General Commercial" captures the following commercial uses: neighborhood commercial (C-1), community commercial (C-2), and general commercial (C-3).

As such, the 1099 Del Monte property is displayed correctly, and no change is needed.

C47-6 Roth, Tom 3/6/24 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
As detailed on page 2-10, the DEIR notes strategies to ensure the City meets its RHNA obligations, such as: "implementation of the Proposed Plan would involve the adoption of three new zoning overlays: an educational workforce housing overlay that would permit multifamily housing to be added on Monterey Peninsula United School District (MPUSD) properties in residential neighborhoods; a congregational overlay that would permit the development of affordable housing on properties owned by religious institutions; and an employer sponsored housing overlay that would facilitate development of employee housing on properties owned by major employers in the city, subject to objective standards." As such, no zoning changes are occurring in the coastal zone.

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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.

C47-7 Roth, Tom 3/6/24 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 to clearly
explain how the project amends the LUP, if at all.

The DEIR has failed to adequately discuss these
issues.

The Regulatory Setting of Chapter 3.1 Aesthetics includes regulations and policies that pertain to aesthetics and visual character. The Proposed Plan does not include any sites within the Harbor Coastal Zone Planning Area; therefore, the 2003 Monterey Harbor Land Use Plan is not discussed.

C47-8 Roth, Tom 3/6/24 Figure 3.10-1: Existing Land Use This figure incorrectly shows 1099 Del Monte as
"general commercial" rather than
"community commercial." It should be corrected.

Please see response to comment C47-5.

C47-9 Roth, Tom 3/6/24 Figure 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
The comment is noted. Figure 3.2-2 has been updated to display C-2 zoning for 1099 Del Monte property.

ATTACHMENT 1 / EXHIBIT A
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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.)
C47-
10 Roth, Tom 3/6/24 Page 3.12-13, Waterfront and Harbors 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 longexisting 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 C-2 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
The Waterfront Master Plan was adopted by the City Council on February 16, 2016. The City is updating the Local Coastal Program through a separate parallel process at the moment. The LCP will be approved by the Coastal Commission before it is locally adopted. Information about the Waterfront Master Plan was used to establish the Environmental Setting of the Proposed Plan as outlined on page 3.12-13 of the EIR, and does not impact the analysis of the EIR. As such, the comment is not related to the adequacy of the DEIR; thus, no further response is required.

ATTACHMENT 1 / EXHIBIT A
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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. 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. 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 land Use Element of the General Plan
Update.

C47-
11 Roth, Tom 3/6/24 Review by Airport Land Use Commission Before adoption, the General Plan Update 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. The DEIR fails to discuss this or
even mention this requirement. 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 this issue. In addition to being a
CEQA issue, the City's failure to seek and obtain
Airport Land Use Commission approval of the
The comment is noted. As detailed on page 3.10-19, the DEIR discusses the Monterey Regional Airport Land Use Compatibility Plan. The proposed Land Use Element incorporates a new Airport Compatibility Overlay with performance standards oriented to protecting airport operations and ensuring public safety. The purpose of the overlay is to resolve conflicts with respect to permitted development types and intensities on properties in the vicinity of the Monterey Regional Airport that have resulted from an update to the ALUCP prepared by the County in 2019. 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; establish requirements for ALUC notification and project approval; and incorporate new mitigation requirements for interior noise levels by land use type. Additionally, with implementation of Policy C.2, the City would refer all projects that may penetrate aeronautical surfaces identified in the ALUCP or impede approach/departure visibility within the Monterey Regional Airport Influence Area to the Airport Land Use Commission for consistency review prior to issuing local development permits; and through Policy C.3, would reduce the potential for bird strikes, and electromagnetic ATTACHMENT 1 / EXHIBIT A
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General Plan Update substantively 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.

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.
interference, and glare in order to help ensure that development adjacent to the airport would not adversely affect airport operations. Therefore, the DEIR does state the Proposed Plan would be submitted and reviewed by the Airport Land Use Commission, and the Proposed Plan would not conflict with the ALUCP.

C47-
12 Roth, Tom 3/6/24 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 can prepare additional comments.

For example, 1099 Del Monte 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 not apply unless
the property owner seeks to build structures that
The following edits have been made:

DEIR p. 3.8-21:
"The Airport Safety Zones associated with runway activities and airport influence areas for the Monterey Regional Airport overlap with the Planning Area, as shown on Figure 3.8-2 Figure 3.8-3 of this document and Exhibit 4C of the ALUCP."
Additionally, the City took the General Plan Update to the County of Monterey Airport Land Use Commission (ALUC) for approval.

On August 23, 2023, the ALUC found the Circulation Element consistent with the 2019 Airport Land Use Compatibility Plan (ALUCP) for the Monterey Regional Airport. On December 11, 2023, the ALUC found the Draft Housing Element consistent with the 2019 ALUCP. Lastly, on January 26, 2024, the ALUC found the Draft Land Use and Safety Elements consistent with the 2019 ATTACHMENT 1 / EXHIBIT A
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are prohibited in Table 4B of the airport plan.

Similarly, if the owner seeks to expand an existing
use, the infill exemption also would not 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 exemption" to mean that the infill exemption
applies only if required only Table 4B for zone 4,
and the City is not 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 immediately.

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.

ALUCP.This clarification does not constitute significant new information requiring recirculation pursuant to CEQA Guidelines section 15088.5.

C47-
13 Roth, Tom 3/6/24 Draft Land Use Element
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 Zoning 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.

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

ATTACHMENT 1 / EXHIBIT A
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It is unclear whether the City is proposing to
change the Zoning Code, and if so, how.

C48-1 Smith,
Geoff
3/21/24 My wife and I own a home in the Monterra
subdivision and I write this to endorse the
compelling and thorough objections previously
submitted to you by Liz Turner.

I add these thoughts: it is highly unusual to consider
converting a long time zoned "highly sensitive
viewshed" area without any infrastructure for
utilities, water, sewer and traffic being in place.

Typically when property is rezoned from a
conservation type category to a residential zone
the developer gets a windfall from the change in
value.

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.

C48-2 Smith,
Geoff
3/21/24 So, I get why development greed would motivate
this project. Yet, highway 68 traffic is already
congested particularly during the "rush" hours to
and from work. Some of that congestion comes
from the increased commercial and multi-family
residential units on the north side of Highway 68.

We in Monterra are already prohibited from egress
and ingress to Carmel Valley road while we must
allow egress and ingress for two additional
subdivisions, Tehama and Walden, through Olmsted
Road or the gate at the intersection of highways 68
and 218. Not only will traffic density increase
radically on highway 68, and access to highway 68
be restricted by the increase in traffic seeking to
access that highway, access will be severely
interrupted by first the equipment and access
needed to build infrastructure from scratch and
second the interruptions from several years of
housing construction.

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.

In addition, 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 ATTACHMENT 1 / EXHIBIT A
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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 RTDM 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.

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.

C48-3 Smith,
Geoff
3/21/24 Also, we are currently experiencing a crisis
obtaining homeowner insurance protection against
wildfire. Like thousands of others in California we
were cancelled as our insurance company withdrew
from California. Alternative coverages raised our
rates 300%. Even as a new plan to increase
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 ATTACHMENT 1 / EXHIBIT A
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homeowner insurance options takes effect at the
end of 2024 we will have more trouble getting
insurance if and when the build out of new
dwellings as proposed diminishes the response time
and effectiveness of the existing fire department
infrastructure now located at the airport.
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.

C49-1 Sorbo,
Allen
3/19/24 Dear Ms. Sabdo:

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

ATTACHMENT 1 / EXHIBIT A
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C49-2 Sorbo,
Allen
3/19/24 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.

41.9% growth in housing units.

C49-3 Sorbo,
Allen
3/19/24 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
Please see response to comment C2-3 regarding projections of population growth and corresponding housing needs. Please also see Master Response MR-1 regarding cumulative development impacts on scenic resources in the southeast and south Monterey.

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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.

C49-4 Sorbo,
Allen
3/19/24 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.

C49-5 Sorbo,
Allen
3/19/24 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.

C49-6 Sorbo,
Allen
3/19/24 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
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 ATTACHMENT 1 / EXHIBIT A
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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.
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.

Monterey City CouncilJuly 16, 2024

Monterey City Council
July 16, 2024