and Monterey County
a Non-Profit California Corporation
Dedicated to Preserving the
Natural Environment and Quality of Life in Del
Monte Forest and Peninsula
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
Reference: Your letter of February 20, 2002
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:
Page 2: Project Background 2nd Paragraph "abandoned
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 "...to 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
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 "....in
the existing reforested former quarry site..."
Page 5: Project Description 1st Paragraph Scenic
easements -Upper and Lower Borrow Sites need to be
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
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
Page 13: V. EVALUATION OF ENVIRONMENTAL
Item 5) States: "Earlier analyses may be used
where....an 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,
Wetlands, Riparian Habitat, and Sensitive habitat
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.
Page 21: 5. CULTURAL RESOURCES DISCUSSION /CONCLUSIONS
/MITIGATION: a) Historical Resources.
We are please that there will be another review
of the historical status of the existing Equestrian
Page 23: 6. GEOLOGY AND SOILS b, d, Soils and
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
Page 27: 9. LAND USE PLANNING DISCUSSION /CONCLUSION
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
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
Pages 31 and 32: 15. TRANSPORTATION /TRAFFIC
DISCUSSION /CONCLUSION /MITIGATION:
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 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
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?
- 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
- Shouldn't a complete disclosure be made of the
design, total cost, sources of funding and
construction schedule for this Highway intersection
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
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
PLEASE SEE THE ATTACHED PAGE (below)
To: Thom McCue, Monterey County Project
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"
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
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.