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LandWatch's Response to Carlsen Estates Subdivision

August 28, 2007

Don Rochester
Chair, Monterey County Planning Commission
168 West Alisal St., 2nd Floor
Salinas, CA 93901

Subject: Carlsen Estates Subdivision

Dear Chair and Members of the Planning Commission:

LandWatch Monterey County urges you to deny the proposed 39 unit Carlsen Estates subdivision on over 96 acres south of Berta Canyon Road in Prunedale. We oppose the project for the following reasons: significant impacts on water supply, biological resources, traffic, and existing code enforcement violations.

Water Supply

The project relies on the Salinas Valley Water Project to meet “an assured, long-term water supply”. The staff report states that the SVWP “has requisite voter approval for funding” and is well along in the project design phase.” Voters approved a project that would, in part, mix 9,700 acre-feet of impounded river water with recycled water. The blended water would then be delivered for irrigation to coastal farmers in North Monterey County – the only direct beneficiaries of the Salinas Valley Water Project. This blended water would eliminate pumping of 9,700 acre feet of groundwater annually, theoretically allowing well levels in affected areas to recover.

However, water quality concerns raised by the Water Quality and Operations Committee will reduce diversion facility’s capacity (rubber dam) by nearly half. Because of this change, “the maximum diversion capacity will be reduced from 85 cfs to 48 cfs.” This change is of great concern to North Monterey County residents who are paying among the highest assessments for the SVWP, who face the most immediate risk if the project fails or is ineffective and who continue to experience further subdivision rationalized by the theoretical benefits of an un-built project.

According to the SVWP EIR, by 2030, the project is supposed to serve a maximum urban population of about 355,000. According to AMBAG’s 2004 forecast, however, population within the SVWP project boundaries (excluding commitments to Marina) will reach approximately 413,000 by 2030. Including the Marina commitment of about 25,000 people, by 2030, 438,000 urban water users will depend on the SVWP– 83,000 more people than originally planned. As a matter of fact, by the year 2020 the population depending on this water project (375,000 people) will have exceeded the SVWP’s maximum capacity of serving 355,000 people by 20,000. The SVWP will not provide an assured long term water supply for the proposed project.

Biological Resources

The staff report (finding 6h) states, “Nevertheless, development of the proposed subdivisions...will have considerable direct and indirect impacts on the vegetation of the study area. Substantial amount of native vegetation will be removed...The remaining vegetation will be subject to ongoing degradation and replacement by invasive and non-native plant species...” The project would be conditioned to require use of native plants, prohibited from using exotic species, required to install irrigation system to minimize runoff and split rail fencing along the conservation easement boundary (Mitigation Measures 4.4-1 to 4.4-4). These mitigation measures do not reduce the projects impact on biological resources to less than significant.

The project would result in the loss of 7.4 acres of habitat for Hookers and Pajaro Manzanita. While Mitigation Measure 4.4-9 attempts to mitigate this loss, it relies on a management and enhancement plan monitoring program that would be extremely difficult to enforce, particularly in light of the applicant’s history of code violations.

Traffic

The project would have a significant cumulative impact on Highway 101, north of Highway 156, which is currently at LOS F. Mitigation Measure 4.7-4 requires payment of a regional traffic mitigation fee to be identified in the TAMC nexus study. Based on this mitigation, the staff report indicates the impact would be reduced to less than significant.

The proposed TAMC regional impact fee would be used for the following projects: SR1 Sand City/Seaside Widening; SR 68-CHOMP Widening; SR 156 Widening; Marina-Salinas Corridor; Del Monte-Lighthouse Corridor Improvements; US 101-San Juan Rd. interchange; US 101-South County; Westside Bypass; SR 68 Commuter Improvements; and Harris Rd./ Eastside Connector. None of these projects would address the affected highway segment. Additionally, the regional impact fee would only raise about $350 million, leaving over $600 million to be funded from other, unidentified sources. The project would have a significant, adverse impact on traffic.

Code Enforcement Violations

The applicant has code enforcement violations going back to 1999. While some progress is being made to address the violations, they are still unresolved. The history of the applicant’s compliance with County requirements raises serious questions regarding implementation of over 140 project conditions. The violations should be resolved prior to any consideration of the proposed project by the Planning Commission.

Thank you for your consideration.

Sincerely,

Chris Fitz
Executive Director

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posted 08.05.07