Greenfield Proposes City Expansion With No Environmental Review

April 2, 2003

Mark McClain, Planning Manager
City of Greenfield
45 El Camino Real
Greenfield, CA 93927

RE: Comment on Notice of Intent to Adopt a Negative Declaration for an Amendment of the Redevelopment Plan for the Greenfield Redevelopment Project

Dear Mark McClain and City of Greenfield Redevelopment Agency:

This letter is to comment on a Notice of Intent to Adopt a Negative Declaration for an Amendment of the Redevelopment Plan for the Greenfield Redevelopment Project. The Notice indicates that the review period is from March 3, 2003 through April 2, 2003. LandWatch Monterey County has the following comments:

CEQA Comments

1. We believe, contrary to the Notice of Intent to Adopt a Negative Declaration, that the proposed amendment to the Greenfield Redevelopment Project might have a significant negative impact on the environment, and that a full Environmental Impact Report (EIR) must be prepared, as required by the California Environmental Quality Act (CEQA).
   
   
2. The proposed project is to include within the Redevelopment Project boundaries approximately 200 acres of agricultural land that is not now scheduled for development, and to develop that land for residential and other purposes. Inclusion of the land within the Redevelopment Project boundaries will facilitate and advance the proposed development, and the development, if in fact undertaken, will undoubtedly have multiple impacts on the physical environment, as well as cumulative and growth-inducing impacts. Because inclusion of the land within the Redevelopment Project boundaries will contribute to and facilitate the physical development of the land, this is a project for which CEQA requires an EIR. Court cases make very clear that changes in planning documents are projects that may have a significant environmental impact, and when they may have such negative impacts, an EIR is required.
   
   
3. We note that the proposed Negative Declaration and Initial Study state that annexations to the City of the lands proposed to be added to the Redevelopment Project boundaries will have environmental impacts, and that, in fact, it is contemplated that an EIR will be prepared for those activities. This statement underscores the need to prepare an EIR for the current project. CEQA requires that environmental analysis and review may not be deferred, but should take place at the earliest possible time. If the City proposes to amend its Redevelopment Project prior to annexation, and thus prior to the environmental review that the City concedes will be needed at that time, then it must advance its preparation of the required environmental analysis. If the City prepares an EIR for some other action, it may then, probably, rely on that EIR for this proposed project. What it may not do, legally, is to avoid environmental analysis now, saying “we’re going to get to that later.” This is, in essence, what the City is proposing, and LandWatch believes that this violates the requirements of CEQA.
   
   Other Comments
   
   
4. The reason that CEQA requires environmental review prior to actions that could affect the environment is so that decision makers will be fully informed about the possible negative impacts of proposed projects, before they are undertaken. It may be, when environmental analysis is carried out, that the City and/or LAFCO will decide that the annexation of the lands in question should not be approved. The lands proposed to be added to the City’s Redevelopment Project are not currently located within the City of Greenfield, and thus do not now qualify for inclusion in the Redevelopment Project. Because it can not be predicted that the annexations will take place as currently contemplated in this proposed project, the proposed project is thus significantly “premature.” Again, we note that the City concedes that environmental review will be required prior to a decision on whether or not such annexations will take place, reinforcing this point.
   
   
5. With respect to the “merits” of the proposed annexations of the City of Greenfield, and thus their ultimate eligibility for inclusion in the City’s Redevelopment Project, LandWatch refers the Redevelopment Agency to its report and analysis, “Room Enough,” previously provided to the City, and available on the LandWatch website at www.landwatch.org. The “Room Enough” report demonstrates that there are feasible alternatives to meeting the City’s need for future residential and other development that do not require the annexations as proposed.
   
   
6. LandWatch strongly argues that the lands in question, whether or not ultimately annexed to the City of Greenfield, are not “blighted” within the meaning of the State’s Redevelopment Law, and thus are not eligible for inclusion in the Redevelopment Project. While this is not, strictly, a comment relevant to the environmental analysis required, if the proposed project is, in fact, inappropriate and illegal, then the City should not pursue it.

Thank you for taking our comments into consideration. LandWatch urges the City to defer any action on the proposed project until after the lands are annexed (if they are) into the City of Greenfield, and that the City then seek legal counsel on whether such lands in fact qualify for inclusion in the Redevelopment Project.

Very truly yours,

Gary A. Patton, Executive Director
LandWatch Monterey County

cc: Members, LandWatch Board of Directors
Monterey County LAFCO

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04.04.03