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June 24, 2010
Jay Brown, Chair
Monterey County Planning Commission
168 West Alisal St., 2nd Floor
Salinas, CA 93901
SUBJECT: HARPER CANYON / ENCINA HILLS PROJECT
Dear Chair and Commissioners:
LandWatch Monterey County commented on the DEIR and the RDEIR. Based on our review of the project and responses to comments, we oppose the Harper Canyon project which would subdivide 344 acres into 17 lots in the Toro area. LandWatch opposes this project because a sustainable water supply does not exist, and the cumulative traffic impacts from this and myriad other projects in the area will create severe congestion on the already over-burdened roadways. Our comments follow:
Water Supply
The FEIR identifies that source of water as wells within Zone 2C of the Salinas Valley Groundwater Basin. Based on our comments submitted on GPU 2010, the Salinas Valley Groundwater Basin is in severe overdraft, and the Salinas Valley Water Project as a source of a long term water supply is unreliable. The Final EIR on GPU 2010 identifies a water balance for the Salinas Basin that projects a tiny surplus as of 2030. This analysis is deeply flawed for the following reasons:
- The water balance analysis is based on baseline and projected water usage from the 2001
Salinas Valley Water Project (“SVWP”) EIR. The SVWP EIR assumed that there
would be a net 1,849 acre decrease in agricultural land, whereas the 2007 General
Plan EIR projects a net increase of at least 7,682 acres. Water for this increased
agricultural acreage will eradicate the tiny surplus projected by the Final EIR and
place the basin into substantial overdraft.
- The FEIR’s attempt to explain that the SVWP EIR remains an adequate basis to
project future water supply and demand notwithstanding the increase in
agricultural acreage double counts the savings the SVWP EIR projected from
more efficient irrigation and changes in cropping patterns.
- The SVWP EIR baseline 1995 pumping assumptions understate actual pumping
as of 1995 by 44,268 afy, based on annual pumping data reported by the
MCWRA and included in the DEIR. The SVWP’s understatement of baseline
pumping is two orders of magnitude greater than the 542 afy projected 2030
surplus in the FEIR. Despite this, the FEIR cites this actual pumping data to
support its contention that the SVWP EIR “remains a solid basis” for evaluating
future demand.
- The FEIR claims that the urban demand projections in the SVWP EIR are
consistent with the FEIR’s water balance analysis, even though the FEIR
projects a 46% greater urban population than the SVWP EIR. To make this
claim, the FEIR “restates” the SVWP’s urban demand projection using
fundamentally different population and water use assumptions, and making
unexplained “minor adjustments” that are an order of magnitude larger than the
FEIR’s projected 542 afy surplus.
Traffic
The FEIR acknowledges that cumulative traffic impacts would be significant and unavoidable. Numerous projects along the Highway 68 corridor are either in the planning process or included in GPU2010. Major projects include Laguna Seca Villas (104 units); Bolendecker (212 units); Affordble Housing Overlay at the intersection of Reservation Road (356 units) and the Airport/Highway 68 AHO (976 units). Intensification of development beyond that allowed on legal lots of record is unsupportable until severe traffic congestion along this corridor is addressed and mitigation measures to meet the LOS standard are funded.
Thank you for the opportunity to comment.
Sincerely,
//s//
Amy L. White, Executive Director
posted 08.17.10
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