Robert Shepner
Dr. John Avera
Carol McCarthy

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March 21,2004

Thom McCue, Senior Planner
Monterey County Planning and Building Inspection Department
Coastal Office
2620 First Avenue
Marina, CA 93933

Subject: Pebble Beach Company's "Del Monte Forest Preservation and Development Plan

Dear Mr. McCue:

This is in response to your February 2nd request for written comments on the DEIR Pebble Beach Company's "Land Use Plan, Implementation Program" dated May 1992 proposed a new golf course near the Hwy. 1 gate. This site would have minimized the specter of unbearable increased traffic congestion around the Lodge should the new golf course be developed near there.

The then proposed reclaimed water reservoir at the Sawmill Gulch site was approved. The Coastal Commission approval at the time mandated that in addition to the golf courses in Pebble Beach, reclaimed water from the project should fulfill the needs of the golf course and cemetery in Pacific Grove and encourage other suitable users. This approval, however, was intentionally abrogated by the imposition of a scenic easement on the Sawmill Gulch site. It would appear that this easement would eliminate this site for an equestrian center but allow a scenic water reservoir.

Should the Sawmill Gulch site reservoir be made available and the reservoir being renovated at Forest Lake be completed, more potable water would be made available for our pressing needs. More water is needed for the Development Plan. There appears to be no mitigation of this need. There is no existing additional supply of water, either reclaimed or potable for the project. Cal-Am is under mandate to eliminate the use of the Carmel River. Why should the plan, which will require additional water, be approved without an existing provision for additional water?

Regarding the Monterey Pine Forest, the counties surrounding Monterey have all been designated as Environmentally Sensitive Habitats. Monterey should also be declared an ESH County. The loss of thousands of trees in Pebble Beach is envisioned. Mitigation replacing the trees lost in Pebble Beach in areas outside of Pebble Beach is not relevant. Is mitigation of this loss to Pebble Beach possible?

The subject plan and the still incomplete CAWDPBCSD Wastewater Reclamation Project are inextricably entwined. One is not viable without the other. Yet the Reclamation Project is not included in the DEN. According to the Addendum to Expanded Initial Study Phase II -CAWD/PBCSD Wastewater Reclamation Project of May 2001 the Project "adopted a Negative Declaration for Phase II of the CAWDPBCSD Wastewater Reclamation on February 23, 1996. The Addendum subsequently states that "Since the adoption of the Negative Declaration, the Division of Safety of Dams has required more extensive modifications of the Forest Lake Reservoir north embankment than was described in the original study". These and other changes such as the relocation of the proposed golf course demand that the reclamation project be included in the DEIR. Why shouldn't the current Reclamation Project be included in the DEIR?

Golf courses in the area more than satisfy the demand. Why is another golf course necessary?

Tourist housing is more than adequate. Tourist employee's affordable housing is inadequate. The Plan does not sufficiently alleviate this problem. Why add to this problem until adequate affordable housing is provided?

I will look forward to your comments regarding the very significant negative impacts
outlined herein.



Robert W. Shepner
1151 Lookout Rd., Pebble Beach, CA 93953 rwshepner@aol.com

cc. Dave Potter, Fifth District Supervisor
be. Rich Hyman, Program Analyst, California Coastal Commission
Kelly Cuffe, Environmentalist Specialist

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Thom McCue
Senior Planner
Monterey Planning and Building Inspection Department
Coastal Office
2620 First Avenue
Marina, CA 93933

March 2 1,2004

Dear Mr. McCue,

As residents of Pebble Beach, we feel compelled to write to you. We strongly oppose the expansion plans proposed by the Pebble Beach Company.

It appears to us that Measure A was a deceptive ploy which successfully outwitted most county voters. Those with whom we have discussed the matter had no idea that Pebble Beach's meaning of "open space" included not only forested areas, but also the denuding of large forested areas for exclusionary golf courses and other golf and resort related developments. Their cleverly designed pamphlets, television and newspaper ads confused the average voter into thinking that their intention was truly to preserve the Del Monte Forest. At the semiannual meeting of the DMFPO, the speaker, Mr. Alan Williams, would not give us a count of how many trees would be destroyed in the development of new golf courses and driving ranges and hotel expansions. After reviewing the DEIR it appears that approximately 15,391 Monterey Pines, 1769 Coast Live Oak, 538 Cypress and over 250 other trees will be eliminated from the forest in the process of "improving" Pebble Beach. It is beyond our comprehension that the Del Monte Forest is being protected in any way with this number of trees being removed. Looking at an aerial map of the Monterey Peninsula, it is shockingly apparent that there is only a fraction of the original forest left. Of this small remnant, the trees are challenged by Pitch Canker Disease and Sudden Oak Death. How can the felling of over 17,900 trees "save" an already dwindling forest? We feel that the homes which supposedly were to have been built might never have been built because of water limitations. Even if they had been built, far fewer trees would have been removed. The land they have set aside as preserved areas appears to be topographically unfit for residential construction and is merely a ruse. We doubt that they ever would have developed these areas.

It is also most discouraging to learn that the land near Sawmill Gulch will become the new equestrian center. As we understood it, that land was to be preserved as scenic open space in perpetuity. This was an agreement made when the Pebble Beach Company quarried the area for materials to build the Spanish Bay Resort. The land has never been restored as promised. As Mr. Mark Stillwel1, the executive vice president of Pebble Beach Company, arrogantly stated at one of the semiannual meetings of the DMF'PO, when asked about the area being preserved open in perpetuity, "Things can always be changed." Currently, trees are being removed from this area, and we suspect they are being replanted in the newly remodeled golf course.

Before living on the beautiful Monterey Peninsula, we resided in Long Beach, CA in an area called Del Lago. There actually was no lake, but only a small pond which was fed mostly by runoff. While, living at Del Lago, we recorded over 135 species of birds including Skimmers, White-faced Ibis, Sora, Kingfishers, and Least Terns to name a few. We had lived in the general area for over 40 years and had no idea that these birds were there. While spending all of our free time enjoying the profusion of wildlife, we began to wonder why all of these species were in our pond. It occurred to us that they had no place else to go. Most of their habitat, vast wet lands, had long since been removed, drained, and replaced by houses, oil fields, shopping centers, freeways, etc. The wildlife was left with a postage stamp sized pond where once vast wetlands existed.

It is our fear that the same scenario is happening here. Habitat is being destroyed at an alarming rate. The elimination of 17,750 trees cannot be honestly and biologically mitigated. Habitat cannot be moved to another location. Not only the trees, but the plants growing beneath the forest canopy, the soil, and the organisms will be destroyed. They cannot be relocated. It just does not happen. The forest floor has evolved over eons, not just a few years. The flora and fauna live in the forest, not on a golf course or a driving range. A huge number of native plants, including rare native orchids will lose their habitat as well as native insects, birds, and animals.

Mr. Zander the biologist hired to complete the DEIR is of very limited scientific education with only a Bachelor of Arts degree in biology. We question his qualifications in determining the future of such a diverse ecosystem. Mr. Alan Williams of the Camel Development Company has no biological education at all as far as we know.

Enclosed, please see the photographs of the damage to Yadon's Piperia that occurred in July 2003 by the Pebble Beach Company, "The Stewards of the Del Monte Forest." This occurred after these Federally Endangered plants were tagged by the "biologists" for the DEIR. This is a federal offense. It is clearly evident that these people have no regard for the environment.

Our concern is that the true wealth of Pebble Beach is in jeopardy. The resorts and the golf courses are wonderful for rest and recreation for an exclusive few, but it is the location, the peninsula with its beaches, forest, and wildlife that are of priceless value and should be spared. It is our sincere hope that you will do everything in your power to protect it.


Dr. and Mrs. John B. Avera
2802 Forest Lodge Road
Pebble Beach, CA, 93953
avera@redshift. corn

cc California Coastal Commission
    Sierra Club, Ventana Chapter
    Department of Fish and Game, Enforcement Branch
    Concerned Residents of Pebble Beach

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TO: Thomas McCue, Senior Planner, Monterey County Planning Dept.

FROM: Carol McCarthy

DATE: March 22, 2004

RE: Response to Draft Environmental Impact Report (DEIR) for Pebble Beach's Company's Del Monte Forest Preservation and Development Plan

Dear Mr. McCue,

Thank you for the opportunity to respond to the DEIR. My comments are provided below. Should you have any questions, please feel free to email me (carol_mccarthy@ctb.com or phone (831-393-7333).


Project Description

pg2.0-3&4, ln38-40 &ln1-24: Talks about the dedication of preservation areas but neglects to mention that some, like Pescadero Canyon, have been repeatedly rededicated and would not be a result of this new PB Co development plan. Also, somewhere it needs to stated in paragraph text that, as a result of Measure A (if certified), that the EC site acreage would be upzoned from OF to OR in order to allow intense recreational development. This is an important point that never was brought to the public's attention by the media during the Measure A campaign and the government should take the responsibility to see that it appears in the DEIR and its other documentation on the PBC plan.

pg2.0-6, ln 22, 25-32 ; 2.0-7, ln 15-17: "Temporary events," what does that entail as far as other PB special events go? Not defined in EIR.


Land Use

pg. 3.1-7, The bulleted Equestrian Center statement says the immediate adjacent surrounding area is HHNA, but neglects to note that part of the Pygmy Forest is an adjacent area the top of the hill, right across the trail from the site. Also Gowen Cypress extends to adjacent area at the top left of the site.

pg3.1-7, ln 36-44, States that the County currently considers the new EC as compatible use in recognition of Measure A approval. I think not! Why is such a presumption being made in the DEIR? Measure A has not been certified by the CCC and the equestrian center may not be approved in its current form. This statement should be deleted from the DEIR!.

P3.1-7, ln 40: States the EC would provide a recreational transition between existing residential development and the HHNA. What about Coastal Commission's goal to preserve the health of forests by maintaining contiguous tracts instead of allowing intrusive developments such as a large, high-intensity EC to divide the environmentally sensitive Morse Preserve, HHNA including Gowen Cypress and Pygmy Forest?

pg3.1-26 Under "Measure A," please add a bulleted statement with the number of acres that would be upzoned from OF (RC) to OR for the proposed new EC.

Vol2, App D, D-14, #13 &endash; EC is marked as consistent with conditioned or mitigated as per deed restrictions, yet Land Use chapter talks about deed restrictions being inconsistent, What are we talking about here as far as being consistent? #13 invites voluntary easements while Pebble Beach wants to remove the conservation easements at EC. Please clarify this double-talk.


Biological Resources

pg3.3-14, pg3.3-16,ln 8-15 Mitigation Measure BIO-A5: Weed-free feed mitigation recommended. Define how would this mitigation be enforced.

pg3.3-17, ln 17-37 mentions Sawmill Gulch "foregone restoration" mitigations are additional avoidance, minimization, restoration, and enhancement to less-than significant levels. How will this be realized by developing a high-intensity EC there. Also what is definition of "foregone" restoration?? That term can be interpreted different ways. "Foregone" means having gone or been completed previously; departed; past ( American Heritage Dictionary of the English Language). Which definition of foregone is being referred to in context with restoration. The restoration certainly wasn't "completed previously." After complaints that PBC was not restoring the area as a condition of Spanish Bay sand mining, PBC finally planted some trees but did nothing to restoring the soil and nurture the trees. Please clarify.

3.3-19, ln42-44 &3.3-20, ln1-4 correctly states the permit intent of permit was to reforest the site and integrate it into the HHNA but complete reforestation will not occur with this project. What are the mitigations to uphold this very important oversite by PB?

3.3-28, ln 25-27. Contradictory to DEIR, planned buildings in upper sawmill are closer than 100 feet to wetland.

pg3.3-59, ln8-25: Mentions effects of human use but does not include an analysis of the biological effects of large crowds at EC special events, people roaming the woods, trailers, horses, etc. (producing a county fairgrounds-like impact on the HHNA, wetlands, and other sensitive surrounding areas).

pp3.3-68, ln6-29. I was glad to see that the Monterey Pygmy Forest was mentioned. But what about impacts on the section of Pygmy Forest that is right across the trail at the upper end of the planned EC? No mapping of Pygmy Forest is provided to indicate its proximity to the EC and its location in HHNA. Also, "Notice of Availability of a Draft Recovery Plan for Five Plants from Monterey County, CA, for Review and Comment," US Environmental Protection Agency, Federal Register Environmental Document, Vol 67, Number 92, May 13, 2002 needs to be cited in that section so the importance of the pygmy forest does not go unnoticed.

Grubs in the horse feces not addressed. At existing EC there are normally few flies except after special events. Do flies from grubs deposited by international horses have an impact on the ecology in a sensitive forest environment?

Nothing addressed about a plan for the monitoring of all these mitigations. Who, what, where, when will enforce mitigations?? SBDR App H-3;ln12-17 admits report doesn't specify what the controls are. Same for SBDR App H-3, ln18-21

The impact that a complete removal of trees to accommodate a driving range vs the effect of spot removal for building development needs to be addressed. DEIR doesn't address the significant impact on "clear-cutting" an entire swath of undisturbed forest trees to accommodate a driving range at SBDR. Goes against Coastal Commission goal that large, contiguous areas of forest remain preserved.

3.3-58, ln 15-21 &endash; In SBDR leave a few dead trees for mitigation for loss of pallid bat habitat? Please provide substantiation for this mitigation.

3.3-63, ln 14-16 &endash; Driving range - Replanting will occur around the driving range. How does this make up for the swath that will be cleared for the >2000 trees for the driving range itself?

Wetland buffer recognized for SBDR site but seasonal wetlands occurring inside the planned driving range corridor ignored. One cannot traverse there in the winter. County wetland mapping should be questioned.

Table 3.3-8 lists no wetland for actual driving range area.

Table 3.3-8 lists no Riparian LF for EC, yet it lies right in a riparian corridor on previous project maps.

App D-10: Incorporating environmental education to all trail users and special events at EC. How? Study groups? Patrols? Please define the education plan and how it will ensure enforcement of rules (weed-free feed, trail use, etc.)

Where in the DEIR is the criteria defined for determining that mitigations will turn a significant impact to one that is less than significant? Each mitigation given in the EIR should define the criteria and/or cross-reference an appendix or chapter in the EIR document that is readily accessible to the reviewer.

No explanation found of the impacts of perimeter security fencing shown in Figs 2.0-10 (EC) and 2.0-14. Am EIR on the impacts on wildlife corridor needs to be addressed.

Vol 2, AppD, D-15, ln14- For the SBDR, minimum removal of vegetation and disturbance is not marked.


Hydrology & Water Quality

3.4-18, ln8-29. Horse waste could degrade water quality downstream, pathogenic organisms. Could be significant, mitigation off-site transport of wastes and storm water runoff will adversely impact receiving waters and pacific ocean. Mitigation is monitoring. Shouldn't prevention via regular cleanup of EC and HHNA trails be added as a mitigation.


Transportation & Circulation

pg 3.7-2 "Parking accommodations" for EC special events not mentioned.

Temporary event area usage and mitigations not well defined. Also nothing about RV usage allowed at EC? Where do the people with RVs camp and what facilities are there for their sewage waste and gray water?

3..7-6;ln29-34. If appox 300-400 vehicles/day (plus 60 horse trailers) for special events why only 166 total parking spaces + 100 temp trailer on Fig 2.0-11? Where will the rest park? Another inconsistency is the statement, "Plans for new facility will include 126 spaces," yet and Fig 2.0-11 shows 150 spaces and 16 spaces shown in Fig 2.0-10)

3.7-7,ln 23-24: "Special event" needs to be defined in context with this statement that the lower area would be used for special event parking. Is that special event parking just for EC events or do they plan to use it for "other" special events? Please define.

Transportation. 3.7-24&25 Mitigation for Skyline Forest & Beverly Manor intersections at Rt 68 is traffic lights? That will back up through traffic even more. Include consequence of this mitigation in DEIR.

The closing of the Presidio has had an reflexive impact on Highway 68 .When Lighthouse Avenue in New Monterey has a traffic jam, drivers drive up David Ave or Prescott and jam Highway 68. This has caused some real traffic problems that I have personally witnessed, especially at the rush hours. This situation should be addressed in the DEIR.



Inconsistencies in figures for acreages and tree counts throughout the DEIR. Recommend a thorough edit.

This does not pertain to the DEIR but is related documentation that I wish to comment on...The "Coastal Development Permit Supplemental Application" says the upper EC area will accommodate Residential use. Is that allowed under LUP, LCP, Measure A zoning for Open Space Recreational?

Poor organization of DEIR document.

  • I found it extremely difficult to track project-specific impacts across so many chapters since the impacts are addressed for groups of projects instead of by individual project. This plan is too large and complex for any one person to comprehend and complete review in its existing format. It gives the appearance that the developer does not want the governing parties and public to clearly see what is being reported on.
  • Poor cross-references, e.g. in App D, on pg D-11 Policy 8 is mentioned. I searched for Policy 8 but never did find it and learn what it referred to. Clear citations should be provided and hyperlinked for each cross-reference.
  • Other problems in the DEIR PDFs sold to the public were that the text could not be copied & pasted, making it impossible to provide quotes in comments. The master TOC had no hyperlinks and there was no index or bookmarks. These are all easy enhancements that should have been done to make this comment period more efficient and easier forall concerned.