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and Monterey County
a Non-Profit California Corporation

Dedicated to Preserving the Natural Environment and Quality of Life in Del Monte Forest and Peninsula Communities

April 12, 2002

Mr. Thomas A. McCue, Project Planner
Monterey County Planning and Building Dept.
2620 First Ave.
Marina, CA 93933

Subject: Notice of Preparation - Environmental Impact Report #9570
              Pebble Beach Company Files PLN010254 and PLN010341

Reference: Your letter of February 20, 2002 (Revised 3-6-2002)

Dear Thom,

The Concerned Residents of Pebble Beach (CR-PB) organization has prepared the following comments on the County's Initial Study covering the scope of work required for the subject EIR.

We are pleased that the scope of this EIR is comprehensive and detailed in content. Having gone through the evaluations of two prior EIRs for the previously proposed Pebble Beach Company developments we recognize how important it is to have a clearly defined scope of work for all aspects of the project.

Recommendations for clarification, modifications and additions to the scope of the EIR follow:

Initial Study
Page 2: Project Background 2nd Paragraph "abandoned quarry"

The report states: "The new location of the golf course required relocation of the existing equestrian center to an abandoned quarry near the City of Pacific Grove". We believe this description is misleading and should read " a reforested former quarry site near the City of Pacific Grove". This change describes the site as it exists today.

Page 3: Measure "A" lst Paragraph "obtain approval of the new plan

The words.. "To obtain approval of the new plan, the new Pebble Beach Company owners sponsored a countywide voter initiative (Measure "A")".. are not accurate. It is suggested that this read... "To amend the Del Monte Forest Land Use Plan and allow for the new plan.etc."

Page 3: Measure "A" 5th Paragraph "existing mined out former quarry site"

The report states: "allow application for a new equestrian center in the existing minded out former quarry site in the Gowen-Cypress area".. As suggested above, we believe this description should read " the existing reforested former quarry site..."

Page 5: Project Description 1st Paragraph Scenic easements -Upper and Lower Borrow Sites need to be
        covered in describing the new Equestrian Center Site

There is no specific reference to the recorded scenic easements that exist on the Upper and Lower Borrow Sites as a result of the approval of the Spanish Bay development (PC-5202).

On page 5, the Report only states: "The application also includes requested amendments to the existing Spanish Bay Use Permit (PC-5202) as to conditions imposed at the Sawmill Borrow Site, which is now proposed for the relocated equestrian center".

Residents of Pebble Beach and the City of Pacific Grove assumed these scenic easements were to be in perpetuity and that approval of the Spanish Bay development permit was contingent upon these two easements being required; one by the County of Monterey and one by the California Coastal Commission.

Our organization, CR-PB, believes the EIR must discuss these easements in detail, laying out the historical background, including an evaluation of the commitments, real and implied, that were made to the residents of Pebble Beach and City of Pacific Grove.

It would be very helpful to the evaluators of the EIR if copies of the two scenic easements as well as appropriate historical documents were included in an appendix in the EIR.

Operation of Equestrian Center

The previous EIR did not include a proper discussion on how the proposed new equestrian center would be operated. This new EIR should provide detailed rules and conditions on allowed hours of operation, noise limits, neighborhood protection from oder and how special events should be controlled. The documents should provide limitations on operations of large horse-hauling vehicles, parking and overnight camping at the equestrian center.


Item 5) States: "Earlier analyses may be used effect has been adequately analyzed in an earlier EIR or negative declaration".

Item 5) b) and c) are of real concern to the CR-PB organization. We believe that impacts were not adequately addressed in previous EIR documents and that the proposed mitigation measures were inadequate. Specifically, it is felt that some of the internal traffic problems, e.g., the "Level F" condition of segments of the 17-Mile Drive and the traffic and related noise of the proposed new equestrian center were not adequately addressed. As a result adequate mitigation measures were not proposed. To permit the new EIR to rely on prior studies that were inadequate would not produce a reliable EIR.

Page 19: 4th Paragraph Forest Management Plans OSAC, etc.
              b-c Wetlands, Riparian Habitat, and Sensitive habitat Areas.

Previous EIRs have mentioned Forest Management Plans, OSAC, etc. However, the essence of these documents was not conveniently available to individuals and organizations wishing to evaluate discussions, conclusions and proposed mitigation measures in the report. It would be helpful to the public if the essential elements of cited reports are included as appendices to the EIR.

CR-PB would like to have the EIR contain a discussion of how the proposed golf course will be operated to protect the large numbers of wetlands and sensitive habitat. Further, we, and the general public, would like to see an evaluation of how chemicals (fertilizers, pesticides, etc.) used in the maintenance of the proposed golf course could effect the wetlands and sensitive habitat. Also, the EIR should describe how the use of these chemicals near the water shore line of Monterey Bay will effect the quality of the bay water.


We are please that there will be another review of the historical status of the existing Equestrian Center.

Page 23: 6. GEOLOGY AND SOILS b, d, Soils and Erosion

Reference is made to the amount of grading to be done. There will be extensive excavation due to the development of two new underground parking facilities. It is important that truck routes be clearly described and defined as well as the conditions that will be imposed on hours of operating, load coverings, noise limits, road cleaning, etc.


The statement: "The effects of intensification of visitor-serving uses at The Pebble Beach Lodge and Spanish Bay Inn require review", needs expanding. An "in-depth study and discussion" is required. We wish to emphasize the fact that neither the existing Del Monte Forest Land Use Plan nor Measure "A" address the specific issue of how intensification of visitor-serving uses will impact the quality of residential life in the Del Monte Forest.

Major expansions are proposed for The Lodge and adjacent areas. The Spanish Bay complex will also be expanded according to the pending application. The Lodge area is already congested due to the mixture of commercial and residential activities. Unless controls are established, more commercial development beyond the pending applications could occur in future years. The previous EIRs addressed this subject in a peripheral way. The new EIR should include a comprehensive study of this growing problem and provide extensive mitigation measures.

Page 32: 3rd Paragraph a-b Traffic.

The Study document includes the statement: "Additional roadway improvements are being proposed to an entrance to Del Monte Forest at the convergence of Highway 1,

Highway 68, and the 17-Mile Drive. This latter improvement is being proposed separately to meet existing traffic conditions, although the extent of any additional capacity will need to be reviewed in this EIR". This true.

However, there is a long history of not solving current problems before construction of any new development takes place. The EIR should address the question....are there sufficient funds ($5 to $6 million) really available to complete this badly needed highway intersection improvement and the Community Hospital of Monterey Peninsula Highway 68 improvement project?

In addition:

- Should the Pebble Beach Company's development project approval and go-ahead be contingent upon the Highway1/68/17-Mile Drive construction project being started and completed prior to the time the ten development projects are completed?

- Shouldn't a complete disclosure be made of the design, total cost, sources of funding and construction schedule for this Highway intersection improvement project?

Many traffic issues including the above mentioned project are of paramount importance to the Forest residents and workers as well as people who live and work in Pacific Grove, Monterey, Carmel-By-The-Sea, and the unincorporated Carmel area, along with employees and guests at the Community Hospital.

The Traffic data included in this new EIR should be up-to-date and projections should be based upon the proposed developments within and outside the Del Monte Forest. It is misleading and confusing to compare traffic that would be generated by the hypothetical development of 900 residential lots or to use the twenty year old obsolete Crowel Report. Neither has any credibility today.

There are numerous intersections and roadways in the Forest that need improvement now before any further development takes place. Based on previous EIRs and County's action related to road improvements in the Forest is appears the County has little real interest in the problems as they involve privately owned roads. The EIR should make an issue of this.


Pages 32, 33: 16. UTILITIES AND SERVICE SYSTEMS b) and d) Water Service

This section includes: "To reduce reliance on Cal-Am water, the Pebble Beach Company will be utilizing recycled wastewater to irrigate the proposed golf course and driving range".

The ability to use recycled water on the proposed golf course and driving range as well as to meet the shortfall of recycled water for the existing golf courses depends upon the production capability of the wastewater reclamation project. The existing system is hundreds of acre-feet short of meeting the existing and projected water demand. The existing water quality is inadequate. The EIR must examine this issue in great detail and specifically describe what has to be done to be sure there is sufficient water supply of acceptable quality before the development of the new golf course and driving range can begin. It would be poor public policy, even on an interim basis, to allow use of potable water for the new golf course and driving range, even if the Pebble Beach Company has sufficient water "entitlements".



/ss Ted R. Hunter       Carl E. Nielsen

cc: Concerned Residents of Pebble Beach Steering and Advisory Committee


To: Thom McCue, Monterey County Project Planner

Re: Notice of Preparation (NOP) - Environmental Impact Report (EIR) on - Analysis of changes in DMF Land Use Plan Policies and Designations - Measure "A" Initiative


Thom, your letter of February 20th states: This document (EIR) will also analyze the changes in the land use policies and designations which have been made by the voter-approved initiative Measure ""A".

However, the 36-page EIR scope document does not include a detailed list of the Del Monte Forest Land Use Policies and Designations that are changed by the Measure "A" document.

the County Counsel's summary of "A" includes:

- This initiative would remove the resource constraint zoning overlay on the lands where all water, sewer, and traffic constraints have been satisfied, as provided in the initiative.

- This initiative would rezone property...etc...for visitor serving uses.

- This initiative shall become a valid and binding ordinance of the County of Monterey.

-This initiative is intended to be consistent with the California Coastal Act.

In addition, the initiative includes many significant policy changes in the proposed Land Use Plan amendments that are not addressed in the EIR scope document.

In order to properly complete the required EIR on Measure "A", the firm conducting the study, Jones & Stokes, needs a very complete list of each policy and designation that have been changed in the DMF Land Use Plan. the impact of each of these changes needs to be fully discussed in the EIR.

Our organization believes this list should be provided for use by Jones & Stokes, the California Coastal Commission staff, and the public along with a copy of Measure "A" initiative.

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