County Getting Ahead of Itself on "Butterfly Village"

August 12, 2004

Bob Schubert, Project Planner
Planning & Building Inspection Department
Monterey County
2620 First Avenue
Marina, CA 93933

RE: Butterfly Village (PLN0204701) – Public Hearing on August 26, 2004

Dear Mr. Schubert:

I am writing in response to a notice recently published in the Salinas Californian newspaper, indicating that the Monterey County Minor Subdivision/Subdivision Committee is planning to hold a public hearing on August 26, 2004, to consider the so-called “Butterfly Village” project proposed for the Rancho San Juan Area.

To say I was “surprised” to see this notice is to understate my amazement. As you know, a Draft Environmental Impact Report on the so-called “Butterfly Village” project has been circulated for public comment, and many comments have been made. The Draft EIR also, of course, covered a proposed Specific Plan for the Rancho San Juan Area. The Final EIR for these two proposed projects has not yet been issued, and based on the comments I have seen (and including comments submitted by LandWatch and CALTRANS), it is obvious to me that the Draft EIR will need to be changed in significant ways, and then recirculated.

I do not see how the County can begin officially considering whether or not to approve the “Butterfly Village” proposal until after the EIR process is complete, so that the results of that process can be taken into account. The traffic issues cited by both LandWatch and CALTRANS, just to mention one example, might well require a significant project redesign. Furthermore, it is also necessary for the County to make a decision on the proposed Rancho San Juan Specific Plan prior to considering approval of the proposed “Butterfly Village” project.

Legally, the “Butterfly Village” proposal can only be approved if it is consistent with the County General Plan. The current County General Plan requires that all development in the Rancho San Juan Area to be carried out according to a “Specific Plan,” and no such Specific Plan has been approved by the Board of Supervisors. Even if it were legally possible to approve the proposed “Butterfly Village” project concurrently with approval of the Specific Plan (and I question the legality of such a procedure), it is absolutely insupportable for the County to consider the “Butterfly Village” proposal as though the County had already adopted the necessary Specific Plan.

CEQA does not allow a jurisdiction to “piecemeal” significant decisions. County consideration of the proposed “Butterfly Village” subdivision and golf course development at this point is totally premature.

This letter is my request that you cancel the public hearing scheduled for August 26, 2004, and that you consider the proposed “Butterfly Village” project only after the legally required environmental review has been completed, and after the Board of Supervisors has adopted a Specific Plan for the Rancho San Juan Area, against which the proposed “Butterfly Village” project can be measured.

Thank you for your attention to this matter.

cc: Interested Persons

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posted 08.12.04