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November 8, 2004 Thom A. McCue, Senior Planner Subject: Partial Revised Draft EIR (PRDEIR) on Pebble
Beach Company's Dear Mr. McCue, Our organization commends the authors of the September 2004 PRDEIR. We are impressed with the comprehensive new mitigation requirements established under the "Yadon's Piperia" and "Water Supply and Demand" sections of the document. However, there are other environmental impacts associated with the pending applications for development projects that we feel have not been adequately addressed. Our comments are enclosed. We understand that we will not receive a response on subjects that are not included in the PRDEIR. We thank you and your associates for considering and acting on these comments. Sincerely, /ss/ /ss/ Ted R. Hunter
Carl E. Nielsen P.O. BOX 1229, Pebble Beach, CA 93953 |
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Nov. 8, 2004 Comments on PRDEIR COMMENTS ON PRDEIR 1. Water Supply and Demand We strongly support the revisions to the DEIR with respect to water supply and demand. It is essential that the proposed upgraded water reclamation system operate at design capacity before any actual development occurs. The recommended mitigation measures represent a very logical approach of resolving all water issues before approval of development plans. 2. Yadon's Piperia We are impressed with the comprehensive mitigation program outlined in the PRDEIR with respect to Yadon's piperia. We have two comments: Mitigation Measure BIO-D1-1 Avoidance The first item concerning building envelopes contains the final sentence: "This measure would reduce the loss of approximately 1.4 acres containing 34 individuals". The total proposed preservation population is over 86,000. It seems to us that the proposed reduction of loss of 34 individuals is so insignificant relative to the total that one could easily conclude that the administrative effort to implement this portion of BIO-D1-1 is not worth the benefit. Mitigation Measure BIO-D1-4 Piperia Plan We wish to compliment the County on the development of the Piperia Plan. It is the first time conditions have been imposed on the applicant with specificity in performance requirements, management oversight of the execution of the plan and meaningful penalties if the plan is not adequately funded. 3. Long Term Noise The PRDEIR and DEIR did not address the problem of long tern noise resulting from the conduct of equestrian events on the Lower Sawmill Gulch portion of the proposed Equestrian Center. There were 48 days of equestrian events conducted on the present equestrian center site this past year. This does not include set up and take down of temporary stables, etc. The largest number of equestrian event days occur during the summertime when the resulting noise will really affect the residences in the area. It should be noted that there are a substantial number of residents located from less than 200 feet to 400 or 500 feet of the equestrian center site. We believe there will be a significant impact on the residents and no mitigation measures have even been considered. Noise analysis in the DEIR dealt with steady-state noise such as ventilator noise or regular operations of maintenance equipment. The noises generated from all of the various special event activities on the Lower Sawmill Gulch site will not be steady state but will be frequent and loud and very disturbing to residents in the area. We compare this with noises resulting from aircraft operations which are not steady state but frequent and loud in nature and are recognized to be very disturbing to humans. We would appreciate comments on the subject.
COMMENTS ON ENVIRONMENTAL IMPACTS NOT ADEQUATELY ADDRESSED IN DEIR OR PRDEIR 1. Highway One Road Improvement at Entrance/Exit to Del Monte Forest The final EIR should make it clear that this road work must be completed before any construction on the proposed projects can begin. 2. Certification/Approval of the Measure "A" Initiative County action on this Measure with major changes in Forest zoning and Land Use Plans needs to be taken. When will this happen? The Final EIR needs to cover this. 3. Major Loss of Monterey Pines and 19 Species of Plants The Final EIR needs to cover the Coastal Commission's staff recommendation that the Monterey Pine Forest be designated an ESHA. 4. Limits on Further Commercial Growth Required One of the Measure "A" purposes reads.... "to encourage future visitor-serving development adjacent to existing visitor-serving or recreational facilities". The Final EIR should clearly state that the pending development projects represent the Final Build-Out in the Del Monte Forest. |
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Thom McCue, Planner Dear Thom : I wish to submit the following comments on the RDEIR. 3.3 Biological Resources : Protection of a natural resource such as Yadonts Piperia cannot be be assured without professional monitoring and strict adherence to policies in'the operative Land Use Plan. The mitigation calls for funding and identifying a long term plan. This must include a responsible agency or firm to carry out such a plan and be answerable for failure to do so. 3.5 Public Services and Utilities : D Water Demand The recognition that the Project would increase water demand for potable and recycled water and would result in increased withdrawals from the Carmel River and the Seaside Basin aquifers relative to the current baseline is a welcome admission that the "entitlement watern is in reality a new demand on the water source. Mitigation measures require that the RWP Phase 11 improvements shall be funded by the applicant and completed before any Project developments are served. Does this stricture include development dependent on the purchase of the applicant's water sale, presently 120 af but subject to potential increase? And will that sale be deducted from water needed for the project? As noted in my earlier comments, there was a discrepancy in numbers between the original entitlement of 360af and the proposed project use of 286.8 at plus the available water to be sold to fund the RWP 11. This must be addressed to assure that the water sold be subtracted from the water available to the project. D3 addresses , but does not identify the source of the potential overdraft. E Infrastructure Capacity : E.1 requires the applicant to evaluate the capacity of CAWD/PBCSD and or Cal-Am's distribution infrastructure to deliver recycled water for existing and project irrigation use and potable water needed for irrigation of project areas in the event of RWP interruption. Evaluation is a nonoperative term. The applicant must guarantee capacity to qualify as a mitigation. Finally, in light of the Coastal Commissionls staff Update recommendation that the native Monterey Pine Forest must be designated ESHA, this issue must be readdressed . To ignore the enormous loss of forest land intrinsic to this project would invalidate the entire FEIR. Respectfully, Janice M. O'Brien, Member DMFLUAC |
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November 5, 2004 Monterey County Planning Department Dear Mr. McCue, I am a resident of Del Monte Park and have lived on the corner of Miles and Buena Vista for the past 25 years. My husband and I own our house and we have raised two daughters who have grown up with a deep appreciation for the natural beauty surrounding them. For decades we walked through the forest on our way to Forest Grove Elementary School and few weekends went by without a walk to the beach through the forest. When the development of Spanish Bay Resort was approved we were deeply saddened. During construction, we lived with the drone of a conveyor belt at the end of our street, as well as the thundering sound of large earth moving machines. We watched the disappearance of the sand dunes at Spanish Bay and Asilomar. The jack rabbits that once frequented the area are long gone. After that major development, everyone in our area felt helpless when the Fifth Gate was built and Congress Road was extended. Again, another unwanted impact to our neighborhood. Following that, we fought and defeated Pebble Beach's plan to put a sewage pond at the south end of our neighborhood. And now, yet another major impact to our area is Pebble Beach's proposed development and (preservation?) of the Del Monte Forest. We pay taxes to the county also and I think our Del Monte Park area is underrepresented. I have read parts of the final draft Environmental Impact Report and find it unacceptable. The new equestrian center at Sawmill Gulch will still heavily impact the SFB Morse reserve as well as the Huckleberry Hill pygmy pine forest. The whole area from there down to the ocean will be impacted with an estimated 9,000 annual horse trips, half of which will be made by out of town guests. These trips along with more pedestrian traffic will occur in a forest minus 17,000 trees! And yet, the proposed mitigations will allegedly protect the wetlands, trails and current reserve areas? All users of the New Equestrian Centers will be encouraged to feed their horses noxious weed-free feed for two days prior to bringing their horses to the Del Monte Forest for boarding or equestrian events! There go the native plants! And what about all the run off from these new developments that will flow into our Nation Marine Sanctuary. I have observed Spanish Bay's attempts at management of its environmentally sensitive areas. There are small little token dunes with plants on them in the middle of the golf course. Is that supposed to be satisfying environmental protection of endangered plants and dunes? I have seen wetland areas at the golf course with little ropes or barriers around them saying ''environmentally sensitive area". But taken out of the larger area, can they survive. Can forests survive when they are fragmented and separated from a larger forest. Forests are then impacted by erosion and human traffic. Also, there was a wetland area west of Sunset drive between the Beachcomber Inn and Asilomar Beach that Pebble Beach was supposed to maintain. It is now filled with sludge and run off from the golf course. It has not been able to survive. I remember seeing ducks and Canadian geese there before Spanish Bay golf course and resort were built. Golf retrieval by golfers in environmentally sensitive areas would be mitigated by "maintenance personnel who have gone through an environmental education program that identifies the sensitive resources in the dune area and how to avoid impacts. All ball retrieval will be by hand only without the use of tools, mechanical or otherwise. " I see golfers at Spanish Bay retrieving balls in the dunes all the time. Who would oversee such a mitigation? Finally, Area C, where the driving range will be built is the last stand of pristine old growth forest that is located a few hundred yards from the ocean. The trees there are probably a few hundred years old and are part of the heritage of the Monterey Peninsula that should belong to all of us, not just a few people who want to cut it down for profit. Area C also has a wetland area that runs along the southwest corner that would be heavily impacted by more traffic and activity in the area. The loss of trees and mature forest growth in that area would decrease the breading and over wintering of birds and other wildlife in the area. Why not have the Pebble Beach Company designate that plot of land as another reserve in exchange for some of the other areas of development? Once the Pebble Beach Company's development begins much of this unique area that we all love will be gone forever. Just as the dunes at Spanish Bay Resort are gone now so the golf course could be built. Development and environmentally sensitive plants, animals, forests, and wetland areas don't work together. There is no "less than significant level" of impact. If the forest, wetland areas, native plants, wildlife and water are left alone, we won't need "restoration, enhancement, and dune creation efforts'. I think the Pebble Beach Company should be more considerate of the people that surround Pebble Beach and even its' own residents. Thank you for your time and consideration. Sincerely, /ss/ Nancy Parsons |