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Forest Lake and Lopez Roads
Pebble Beach, CA 93953

March 15,2004

Mr. Thom McCue
Senior Planner
Planning and Building Inspection Department
Coastal Office
2620 1st Avenue
Marina, CA 93933

Re: Draft Environmental Impact Report, Pebble Beach Project

Dear Mr. McCue:

In the time allotted this committee to review subject report, inevitably our review is incomplete and, perhaps, in some respects superficial, considering the length and depth of the report. The report was received on Thursday, February 5,2004, and considered at our meeting on March 11,2004.

The authors of the report are commended for their thorough and definitive treatment of the multiple land use areas addressed. The breadth and scope of issues are extensive and complex. The report is generally clear and precise. The Executive Summary and Project Summary are particularly helpful. Our difficulty with the report lies with its organization and dispersed treatment of specific projects. Individual projects are not set forth as independent packages or subject areas but as specific topics whose implications or impact must be appraised by reference to multiple areas in the report. For example, in the case of the new golf course, the reader is obliged to examine areas elsewhere in the report to assess that undertaking, e.g., land use, traffic, wetlands, the pine forest, etc. Hindsight suggests that the report list each application sequentially in all its implications, rather than requiring the reader to examine descriptions of its impact placed elsewhere in the report. Commendably, however, the report does summarize the impact of the project in various tables, particularly, Table ES and Table 2.0-4. Further, at its beginning, the report addresses, however briefly, contentious issues in its "Areas of Known Controversy."

There is no index to the report and there is no listed identification of the various areas affected by the EIR. Figure ES-2 does show most of the areas but their exact locutions are not clear. It would have been helpful if the area locations were identified with road parameters or some other recognizable description.

Is this Project the Final Build-Out? The Committee still asks whether this project represents the "final" build-out of the Pebble Beach Company. Although the County back on September 12,2002, in a letter to this Committee stated that the project cc...proposes final build-out of Company's lands in the Del Monte Forest.", to our knowledge the Company has never formally made such a declaration. Concern in this respect lies in Measure A, itself, sponsored by the Company, which states in its preamble "[The purpose of Measure A is] ... to encourage future visitor serving development adjacent to existing visitor-serving or recreational facilities..."

The preamble then requires "future development" to be consistent with the California Coastal Act and subject to environmental review. Back in 1992, when the Pebble Beach Lot Program was reviewed, the same question was asked. The answer obviously influences decision-making affecting the current project. The applicant reported at the March 11 meeting that it has formally agreed with the DMF Property Owners that this project constitutes a final build-out.

Application of the Coastal Act. Brief reference appears in the report (Volume 11, Appendix, Chapter 3.1, page C-1) to the California Coastal Act (Public Resources Code, Sections 30,000 et seq.) acknowledging the need for the project's compliance. Reference appears elsewhere to Measure A, the public initiative in general support of the project. Although the Committee cannot and does not expect a legal treatise of the application of the Coastal Act and Measure A and the consistency or lack of it between them, some declaration of compliance and consistency might be helpful to dispel doubt and uncertainty respecting the project. Another helpful item for the reader would be a copy of Measure A attached as a part of the Appendix.

Specific Issues. These specific issues merit the concern of the Committee:

1. Forest Reduction. The EIR concludes that mitigation measures will reduce forest reduction to a "less than significantn level. The numbers in support of this conclusion are confusing. The project provides:

a. direct removal of 99 acres of undeveloped forest;
b. conversion of 28 acres of undeveloped forest to suburban forest (What is the definition of "suburban forest"?);
c. non-restoration of 23 acres at the Sawmill site.

Table 2.0-4 breaks this down in numbers of tree removal, roughly, 9,500 pines and 500 coastal oaks from the golf course and 1,900 pines and 485 oaks from the equestrian center, and significantly lesser numbers from other project areas. These numbers are intimidating; thus the EIR's assessment of the project's cumulative impact is questioned. Totals here are 150 acres of impacted forest. In mitigation, the EIR states that 458 acres of forest will be preserved and the forest in situ will be retained. This is laudable, of course. But should not mitigation be measured on what happens to existing conditions, rather than on conditions that exist had the project not been undertaken? The existing local plan authorizes 800 plus residential units and expanded commercial and recreational facilities. What counts is the impact of the project on existing conditions, i.e., the existing forest, not what could have occurred with some other option. Although the proposed project is substantially reduced in comparison with what the project could have been, is not the determination of impact measured on the reduced project as an independent and separate undertaking?

The ultimate questions, here, are: 1) By how many acres (and trees) will the Monterey Pine forest be reduced from existing conditions by reason of this project? 2) What conditions mitigate this reduction to a less-than-significant level?

2, SFB Morse Gate. This gate was originally constructed to accommodate visitor traffic to Spanish Bay and to provide a shorter access to Del Monte Forest on northbound Highway 68, bypassing passage through Del Monte Park in Pacific Grove. What restrictions, if any, will be applied to commercial use of this gate, subject to reasonable accommodation of the new equestrian center?

3. Highway 1 and 68 Intersections. Proposed changes help alleviate traffic problems here but require "positioning" of cars in appropriate lanes prior to reaching the intersection from southbound Highway 1 and southbound Highway 68. This is understandable, perhaps as the only practical solution, but it does little to minimize drivers' confusion at this complex configuration. Further, improvement in egress from the Beverly Manor professional area and the Community Hospital apparently is dependent upon state funding. This means inaction for years to come.

Specifically, cars traveling east on Hwy 68 approaching the PB and Hwy 1 intersection will attempt to follow the right lanes into PB. Would a barrier at the light help this situation? Cars leaving PB to Carmel on Hwy 1 will continue to merge with cars from Hwy 68 headed in same direction. All traffic entering the PB Hwy 1 gate faces a tight turn while making lane changes to accommodate visitor versus resident lanes. Admittedly, this is a difficult area, and no easy solution exists.

4. Traffic. Increased commercial traffic is inevitable with the expansion of the Lodge and the Spanish Bay Inn and another golf course. Special events at the Equestrian Center generate heavy traffic in trucks and trailers, thus traffic will concentrate on the Sawmill site area inside the Morse Gate. This is helpful. Whether replacement of the existing center with a golf course reduces traffic in this critical area close to the Lodge is questionable.

5. Bristol Curve Area. Plans apparently are still evolving in this area. The presence of Yadon's piperia plant makes any road changes difficult. If, indeed, the plant is present throughout the "triangle" encompassed by Bristol Curve, Stevenson and Forest Lake Roads, should not the Stevenson connection with Forest Lake remain or be constructed in close proximity to its present location? Dividing or splitting this sensitive parcel seems unnecessary if a modified intersection at or close to Stevenson and Forest Lake can accommodate golf course traffic. Assurances from the applicant at the meeting on March 11, 2004, suggest this concern can be satisfactorily resolved.

6. Water Quality. This issue also remains a concern. Assurances are given that water quality will be achieved through certain efforts, but those assurances appear marginal. See Chapter 3.4-27 et seq., and Chapter 3.4-30 et s.eq. The Best Management Plan (BMP) at Charter 3.4-9 et seq. provides remedial actions to achieve elimination of waste, salt, nitrogen, etc., through runoff, reclamation, and mixing, inter alia. Whether these efforts will improve water quality to an acceptable level is questioned.

Attached for your review are individual comments from Mrs. Janice O'Brien, a member of the Committee. Your consideration of Mrs. O'Brien's comments and the comments expressed in this letter is appreciated.

Sincerely yours,


Paul De Lay,

cc: Scott Hennessy, Director, Planning & Bidg. Inspection Department
Mark Stillwell, Executive Vice-president, Pebble Beach Company
Richard Andrews, General Manager, PBCSD
Committee Membership

enclosure: Comments from Mrs. Janice O'Brien, Member

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February 19, 2004

Thom McCue,
Planner Monterey County Planning and Building Inspection Department
2620 1st Avenue
Marina, Ca. 99933

Dear Thom :

I wish to submit the following comments on the draft EIR for the PBC Development Plan.

The EIR is quite explicit that this plan as it stands will have significant impact on the native Monterey Pine Forest (NMPF) and its habitat. It then attempts to mitigate the unmitigable with a series of management plans to be monitored over a period of twenty years. This approach has been an utter failure in the past, as witness Sawmill Gulch and Spanish Bay which is still not in compliance, and is less likely to succeed now when the Planning Department is facing a major reduction in staff. In addition, the EIR does not address the inconsistency of this plan with the policies in the operative LCP. This is required under the Coastal Act.

The EIR is based on the assumption that measure A will be certified, but a review of the past three years' correspondence between the County and the Coastal Commission staff does not support this assumption. The cumulative devastation of the NMPF is expressly forbidden in the recent recommendation for updating regulations submitted by the Coastal Commission staff in December of last year.

Justification for the removal of water and traffic constraints under Measure A is not supported by findings in the EIR. Water : The water demand for the project is estimated at a potential 286.8 afy. This water is to be supplied from the company's "entitlement water" of approximately 360 afy. The justification for this amount was the presumption of a commensurate savings of potable water due to water reclaimed for the golf courses in Pebble Beach. However, this savings has not been realized and cannot be assured without major improvements to the Reclamation Project process and storage capability. In order to fund these improvements, the Company has proposed selling another 150afy to new demand. If this occurs, the 150afy must be added to the 286.8 to arrive at an estimate of 436.8 afy, 76.8 over the Company's entitlement. Since all of this water will be coming from the Carmel River, it will exacerbate the continuing overdraft of the River and its adverse consequences and must be deemed a significant impact on the water resource. Traffic : The road system within the Forest is rural in nature and not conducive to major enlargement. The "improvements" on Hwy. 68 will be of minimal help in coping with the added traffic resulting from the increase in commercial buildout within the Forest. The new lights on Hwy. 68 will merely orchestrate the traffic jam. No mention is made of the traffic increase which will be generated by the future buildout of Community Hospital.

Any discussion of the project's impact on the residential community cannot be confined merely to a construction time frame. The emphasis on expanded commercialism will alter the residential character of the Forest. The systematic degradation of the forest environment will not only diminish the quality of life but could have a negative impact on residential property values as well.

This project will destroy approximately 17,000 trees. It will impact 150 acres, 1.06 of the remaining known developed NMPF.- The overall effect of cumulative development on NMPF on a regional basis could result in a loss of 1600 acres or 12% of the extant forest in the Monterey region. Reference is made to other forested areas outside the Forest under Company ownership. It is not clear if the preservation of these areas is being suggested as mitigation for the destruction of forested areas within the Del Monte Forest as a quid pro quo. And no mention is made of making it a requirement.

There is no discussion of the potential climatic impact from the major loss of tree cover, not only in the DMF but on the Peninsula as a whole. The forest canopy protects the Peninsula from the violent coastal winds. It is also the basis of our clement weather patterns which we all enjoy.

Finally, the Del Monte Forest comprises one fifth of the Monterey Peninsula and is its environmental signature. It is not only a community resource of inestimable value, but a national treasure. The popularity of Pebble Beach as a resort is largely dependent on the forest ambiance. The E I R must evaluate these public interests against the financial expectations of the Company.



Janice M. O'Brien
Member of DMFLUAC

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Ted R. Hunter
P.O. Box 1189
Pebble Beach, CA 93953
Ph. 831-624-3734 Fax 831-620-1525

March 16, 2004

Thom McCue, Senior Planner
Monterey County Planning & Bldg. Insp. Dept.
2620 First Ave.
Marina, CA 93933

Subject: Draft Environmental Impact Report on Pebble Beach Company's pending Application
for Major Construction Projects in Del Monte Forest

Dear Thom,

Rich Walter and the Jones & Stokes consultants have produced a very complex document.

It appears to be very thorough in addressing many environmental issues involved with the Pebble Beach Company's extensive development plans. However, I feel this Draft Report is inconsistent in many areas and it is very difficult to find all the important information related to each individual application to determine what the full adverse impact will be for each.

I suggest that the Final EIR be improved with a better organization of information with all facts about each of the ten pending applications in one place. It is important to know the specific impacts each individual application (proposed construction project) will have and how that individual project will impact traffic, air quality, noise, the environment, etc. in that particular area of the Forest.

I also found this draft report to be incomplete. I strongly suggest that the Final EIR cover the

following items to assist the decision makers in understanding the volume of information and locating facts about a specific pending application.

The Final EIR should include:

1. An Index and Glossary with definition of terms and acronyms

2. A complete copy of the Measure "A" Initiative. The summary on page ES-2 and in Appendix C page C-1 is not sufficient. The document should explain why the Environmental Analysis of Measure "A" is not being made available for the public prior to the first public hearing. It should also indicate when it will be available for the public and how the public will be able to respond to the analysis document.

3. The description on Appendix C page C-2 of the Del Monte Forest Local Coastal Plan and Land Use Plan is incomplete. If and when Measure "A" is certified and approved by the County and Coastal Commission these documents must be amended and approved before the pending applications can be approved.

4. Extracts from the California 1976 Coastal Act that apply to the Del Monte Forest need to be added in the Appendix C page C-1 & 2

5. A copy of each of the pending applications dated July 18, 2001 with a complete description of each project. The list of development projects in Chapter 2.0 page 3 is not adequate.

6. A separation of all environmental facts, impacts and mitigation measures listed for each application. Chapter 4.4 Cumulative Impacts does not breakdown the environmental impacts for each application or project by the Titles listed on page 2.0-3. The readers know the project by the Titles not the Area identification and they want to know the mitigation plans for each project.

7. Enforcement - A requirement/condition that Monterey County will follow-up and ENFORCE all conditions placed on these development projects. Currently it seems funds are not available for this important work. The Final EIR must deal with this problem.

8. Reference to Enforcing Conditions associated with the Spanish Bay development that are still pending and should be included in the EIR.

9. New Schedule for Construction Starts on each project -The DEIR Table 3.7-1A and Table 3.7-lB do not clearly indicate which construction projects have priority. An improved clearer Schedule is required, in addition to the Table, listing a priority sequence for major construction work for each application/project. Pages 3.7-11 and 12 indicated "construction of the New Equestrian Center is proposed to begin concurrently with work at the proposed Golf Course". This Chapter also indicates major excavation work will take place for underground garages at Spanish Bay and in the area of The Lodge, however it is not clear when this work will begin and if it is all scheduled to begin at the same time. Table 3.7-1A refers to using Haul Trucks at Spanish bay, the Golf Course and the Equestrian Center during the first three months and at The Lodge area during Months 19 through 21. It is suggested that this Table be amended with a clearer Schedule listing each of the 10 projects with estimated start times and end times in the 42 Month period.

If all of this construction work for these projects is in progress at the same time why hasn't the DEIR addressed the significant adverse impact on the residents?

Chapter 3.7 and the Table do not make it clear that the Hwy 1 Hill Gate Road Improvement work is the No. 1 Priority Project. A Condition associated with these development projects should require that this Hwy 1 Hill Gate road improvement be completed before any other work begins.

The Final EIR should indicated that the first two important priority projects are:

1. Road Improvements at the Hwy l Hill Gate and
2. Construction of a New Equestrian Center

10. Include a reference to the fact that the Monterey Pine Forest ecosystem is in an Environmental Sensitive Habitat Area (required by the Coastal Act). And that the Santa Cruz, San Mateo, and San Luis Obispo General Plans have established this designation for native Monterey Pines. The Final EIR should also discuss the recent California Coastal Commission Staff Periodic Review of the Local Coastal Plan with recommendations on this subject and how the proposed development projects will be affected.

11. Final Build-Out -A requirement/condition that the applicant, PB Co. enter into an agreement with the County and California Coastal Commission stating the these development Projects represent the Company's FINAL BUILD-OUT in Del Monte Forest.

Comments on the Measure "A" Initiative

Page 1.0-2 on Measure "A" states: To encourage FUTURE visitor-serving development adjacent to existing visitor-serving or recreational facilities in the Del Monte Forest. Conditions and a separate Agreements are required to put an end to future commercial development in the Forest.

The Monterey County Policy Makers need to control/stop continued commercial development in the residential community of the Forest and maintain a balance for the tax paying resident property owners.

If Measure "A" is approved by the County and Coastal Commission it would allow an open ended expansion of Visitor Serving units at Spanish Bay, The Lodge and it would permit the expansion of commercial units at the Spyglass Hill complex (Founders Bldg.). The pending applications represent an excessive expansion of Visitor Serving units in the Forest. It is not in the best interest of the residential community to allow an unlimited further expansion of Visitor Serving units.


The following additional important issues associated with the proposed development project need further coverage in the Final EIR:


Roadway Improvements

Highway l/Highway 68/17-Mile Dr. Pages 2.0-11 and 3.7-3.

These sections require additional information on how this road improvement at the Hwy 1 Entrance (Gate) to the Forest and Hwy 68 from CHOMP to the Hwy 1 interchange require coordination with Monterey County, the City of Monterey, CHOMP and Caltrans. What are the problems associated with financing this priority project? And what will be funded by the applicant? The Final EIR should indicate who is responsible for funding which part. Why isn't the need for a replacement of the 17-Mile Drive narrow Bridge near the Hospital been addressed?


Internal Forest Road Changes Pages 2.0-12 and 2.0-13.

The information following "Proposed Golf Course" needs to be expanded to include reference to the problems listed elsewhere in the documents related to the Yadon's Piperia on pages 3.3-37 and 38. The "mitigation presentation" on page 3.3-37 indicating that Stevenson Drive would not be realigned and that Bristol Curve would be retained as a main arterial road is NOT ACCEPTABLE.

The Final EIR needs to covers other alternatives to preserve the Yadon's Piperia and eliminate a significant adverse impact for tax paying property owners on Bristol Curve and Bristol Lane.

As you know Thom, Mark Stilwell, Exec. V.P. PB Co. and the residents on Bristol Curve/Lane, that would be significantly impacted by the use of Bristol Curve as a main artery, will be meeting, probably several times, to discuss the redesigning of this section of the golf course and an improved plan for extending Stevenson Drive to Forest Lake Rd.


Monterey Pine Forest and Coast Live Oaks

Executive Summary Pages ES-10, 11 and 12. Summary of Impact and Mitigation Measures Table ES-2 and Attachment C Project Summary Page 45.

The total number of trees to be removed..=..15,391 Monterey Pines and 1,769 Coast Live Oaks

should be listed in the Executive Summary on page ES-10 along with reference to acres affected.

The Mitigation Measures listed in Table ES-2 page 5 (using areas outside the Forest - Old Capitol Site) and the Resource Management Plans (RMPs) ARE NOT APPROPRIATE.

The removal of 9,582 Monterey Pines and 501 Coast Live Oaks = Total of 10,083 trees just for the proposed Golf Course will completely change the forest environment for the residential property in this area of the Forest. Why hasn't the DEIR isolated this problem with a statement indicating that this will create a significant adverse impact that cannot be mitigated for this residential neighborhood.? Why hasn't the fact that the proposed developments throughout the Forest will remove the Forest canopy and produce a potential climatic impact for the Del Monte Forest and the whole Peninsula area been identified in the DEIR? These facts should be covered in the Final EIR.



Executive Summary Page ES-16 and 17.

The Final EIR should discuss the problems on the water supply required for all of the development projects if the Phase II improvements to the CAWD/PBSCD Recycle Water Project and the proposed plan to sell entitled water do not produce the projected results. New restriction on withdrawing water from the Carmel River should also be discussed.

Does the DEIR cover the need for a Special Condition on these applications indicating that potable water can not be used for the new golf course? I can't find this statement in Chapter 2.0-5 or in Chapter 3.4-3 on the golf course. Please include this requirement in the Final EIR.

Why doesn't the DEIR address the fact that all of the required water will increase the continuing overdraft of the Carmel River and that this will create a significant adverse impact that can not be mitigated.?


New Equestrian Center & Aug. 11, 1995 Title 20 Ordinance

This major project is mentioned in several Chapters of the DEIR, however, it is very difficult to find all of the facts about how this use of land, with recorded easements dedicating it for open space, can become a commercial Equestrian Center without significant adverse impacts.


Here are important questions:

1. Why aren't copies of the County and California Coastal Commission recorded Conservation Easement provided in the DEIR? The Final EIR needs to provide the decision makers with details on why the Easements were required, and when they were recorded.

2. Why doesn't the document mention the Title 20 Ordinance that prohibits RV vehicles and camping in the Forest? Special events that last several days at the Equestrian Center usually include parked RV's and camping by the participants. The Final EIR should address this problem.

3.Why aren't the Wetlands in this area better defined?

4. What is the definition of "Temporary Events"?

5. Why hasn't the fact that participants will truck their horses to the Ocean Area been addressed?

6. What is the accurate total acreage of the proposed Equestrian Center? Several figures are used....40, 41, 43 and 45.

7. Who will be responsible for the environmental education of participants that use the Forest trails and the Center at Special Events?

8. How many events will be held each year? What is the expected number of participants and spectators and each event?

9. Each equestrian event involves set-up time, event days, take down and clean up time. What is the estimated total number of days for the average event? How will traffic and and noise from loud speakers affect the residents in the area?



Internal Road Changes 3.7-4

Spanish Bay - The proposed additions of Conference Rooms, Hotel Rooms and an Underground Garage at Spanish Bay will increase the traffic in and out of this Resort Complex. The road improvements proposed at the entrance,- 17-Mile Dr. and Congress Road,- are not adequate. Why hasn't the DEIR addressed the adverse impact the added resort traffic will have on the residents of the 83 Townhomes in the area? This impact will be very significant at times when an emergency ambulance is required for a residents. The plans provide for only one single entrance from 17-Mile Drive to both the Resort Complex and the Townhomes. Visitors to the Inn will follow a new separate road once inside the main entrance, however the EIR needs to address the traffic problem for residents at the single road main entrance. The problem can be mitigated by building a new separate entrance to the Townhomes that would not be used by visitors to the Inn or other resort facilities. Does the DEIR mentioned traffic problems for emergency ambulance or fire truck vehicles?

Golf Course & 11 Cottage Units - The road changes illustrated in Fig. 3.7-3 and Construction Truck Routing Fig. 3.7-4 are not adequate. When will both of these road maps be updated to clearly show where the final locations of the new extension of Stevenson Drive to Forest Lake Road will be?

Will Construction Trucks use Bristol Curve for work on the proposed Golf Course? Or will Bristol Curve be removed and a new extension of Stevenson Drive be completed before Construction Trucks begin traveling in this area? Why don't the two road maps (Fig. 3.7-3 and Fig. 3.7-4) illustrate the same road system in this area?

The required road changes, due to the Yadon's Piperia, and the required redesigned sections of the proposed golf course due to the Piperia and Wetlands need to be covered in an addendum to the DEIR. The public should be given time to respond to these changes and redesigned plans. It would be inappropriate for these changes to be incorporated in the final EIR without public comment.


Public Services

The Impact section PSU-A2 and the Mitigation Measure section PSU-A-2 in the DEIR that indicate the Pebble Beach Company should be obligated to develop a funding plan to insure that police service is available within the Del Monte Forest is not appropriate.

This is a Monterey County obligation that should be covered in the Final EIR.

In Chapter 3.5 -Public Services and Utilities, the Emergency Access and Wildland Fire Hazard sections do not adequately include a Forest Wide Fire Defense Plan and Emergency Routes for all sections of the Forest. The proposed major expansion of the resort complexes with a new location for the Equestrian Center and another golf course will involve many areas of the Forest. Where is a Emergency Plan for visitors and residents to follow in the event of a major fire or any other event that requires an evacuation of sections or all of the Forest?

Your consideration of these comments and suggestions with a reply will be appreciated.



Ted R. Hunter