"Boot Camp" Materials

March 20, 2004

Monterey County General Plan “Boot Camp"



I. Introductions/ Boot Camp Goals


II. General Plan Basics (Gary Patton)


III. How to Make the General Plan Better (Terry Watt)

  • What the General Plan Does Well
  • Where the General Plan Falls Short
  • Recommended Comments on the General Plan
  • Q & A

IV. How to Comment on the DEIR (Terry Watt)

  1. EIR Basics
  2. What the DEIR Does Well
  3. Where the DEIR Falls Short
  4. How to Use the EIR to Support GPU Recommendations
  5. How to Comment on the EIR
  6. Q & A

[12:15—Working Lunch]

V. Effective Message Delivery (Catherine Lew)

Boot Camp Goals

  1. Provide information about the current draft of the General Plan Update and the Draft EIR.

  2. Provide direction on how effectively to comment (orally and in writing) on the General Plan and Draft EIR.

  3. Respond to key questions about the General Plan and Draft EIR.

  4. Learn from participants about key issues/suggestions for commenting.

  5. Inspire citizen participation as the General Plan Update process enters its final stages.

General Plan Basics

The single most important policy document for guiding decisions and conditions related to land use in the County. GPU at 3-1.

Provides a vision for the County’s future and the regulatory framework. GPU at 3-1

General Plans must be legally adequate and internally consistent. They must contain seven Mandatory Elements, which can be combined:

The Housing Element must be updated every five years and “certified" by the State.

The Draft Monterey County General Plan contains five elements to address the required topics:

AND several non-mandatory, “optional" elements:

It also has several Appendices

A General Plan must be internally consistent:

The Land Use and Circulation Elements Must be Correlated:

The Land Use Element must:

? Identify the proposed general distribution and intensity of uses of the land for housing, business, industry, open space, natural resources, public facilities, waste disposal sites, and other categories of uses.

? Include standards of population density and building intensity.

How To Make The General Plan Better

What the General Plan Does Well:

Contains 12 Guiding Objectives:

#1 Preserve the unique character of areas throughout Monterey County as represented by the different Area Land Use Plans.

#2 Identify land that is adequate and appropriate for the residential, commercial, and industrial development needs of Monterey County during the next twenty years, taking into account land located within the cities, existing legal lots of record, and resource and infrastructure constraints.

#3 Preserve a distinction between urban and rural areas. Channel new growth to areas already committed to an urban level of development (e.g. cities, areas directly adjacent to cities, and densely developed unincorporated communities). Preserve rural areas for resource-based industries (e.g. farming, livestock, grazing, mining), natural resource protection, and open space recreation uses.

#4 Strongly encourage new commercial, industrial, and residential development to provide actual, new, permanently affordable living quarters, including housing for people with low, very low, and moderate incomes who live and/or are employed in Monterey County. Promote density, creative and innovative design concepts, and employer-produced housing which will increase affordable housing opportunities convenient to the workplace. Promote a healthy job and housing balance in all areas.

#5 Promote the development of walkable communities that meet the daily needs of their residents, offer a high quality of life for residents, and reduce the need for automobile trips.

#6 Promote, preserve, and support agriculture and the industries that serve it. Promote industries that preserve and support environmental quality or serve the local needs of our communities.

#7 Minimize development of commercially viable agricultural land. Ensure that recognized needs for growth are met by infill and contiguous, compact development.

#8 Provide adequate infrastructure and public services for existing residents and businesses. Ensure that infrastructure and public services are available, fully funded, and constructed concurrently with new development. Ensure that new development neither increases the infrastructure and public service cost for existing residents and businesses nor reduces their quality of service by any significant amount.

#9 Provide long-term protection of identified resource-rich and critical habitat areas.

# 10 Protect the visual integrity of ridgelines, designated scenic corridors, and other identified sensitive visual resources throughout Monterey County.

#11. Seek to provide an adequate and sustainable water supply while protecting the county’s watersheds and marine environment, including surface water, ground water, and aquifer recharge areas.

#12 Provide a clear statement of county land use values and policies to provide clarity in the county’s permit processing system and to simplify review of projects that are consistent with the General Plan.

What the General Plan Does Well, continued:

Attempts to base policies and land use on a theme of “focused growth:"

“The major thrust of this Plan is to manage growth by preserving a clear distinction between urban and rural areas. This means channeling new growth into planned urban areas and preserving rural areas for agricultural and other resource-based industries and for natural resource protection." (GPU at Page 24)

What the General Plan Does Well, continued:

Where the General Plan Falls Short:

The proposed General Plan is internally inconsistent in numerous respects.

Where the General Plan Falls Short, continued:

The proposed General Plan fails to provide adequate direction for future development:

Practice Tips

Comments on the General Plan

Intent of Comments on the General Plan

Example Comments on the General Plan:

Work for the bottom line

We cannot afford the General Plan proposed: “The General Plan analysis identifies an 11 million deficit that will be associated with full development of the 7 community areas." Economic Impact Analysis at ii.

Keep it Simple

Make the Tough Choices Now

The proposed General Plan will result in significant and unavoidable impacts to prime farmland.

Example Comments on the General Plan cont:

(1) Either delete the clustering policy or include a detailed clustering policy that complies with State law requirements to identify the location and density of housing. The DEIR provides some direction on a more detailed policy, including:

(2) Provide “adequate and appropriate land for the County’s development needs" by identifying Castroville, Boronda, Pajaro and Fort Ord as Community Areas. In combination with existing lots of record, these four areas achieve Guiding Objective #2. Inclusion of this policy will restore internal consistency to the General Plan.

How To Comment on the DEIR

EIR Basics

Purposes of an Environmental Impact Report (as required by CEQA):

Purposes of a “Program" EIR on a “General Plan" document:

[A program EIR addresses a series of actions that can be characterized as one large project and are related.]

CEQA Authorizes Agencies to:

Process for Review of the EIR:

Required Contents of DEIR:

Key Concept:

The EIR may direct that changes be made to the General Plan policies or land uses to lessen or avoid significant effects, when feasible, typically in the form of:

  1. Modified or new policies in the form of mitigation measures. [same policy recommendations as on the General Plan]

  2. Changes to the proposed land uses and locations in the form of alternatives.

  3. Changes to the type or mix of land uses (for instance, a higher proportion of affordable housing).

What The DEIR Does Well:

Tells much of the truth about the severity of impacts:

Where The DEIR Falls Down:

Fails to recommend feasible and clear policy choices in the form of mitigation measures that would reduce or eliminate the significant impacts of the General Plan.

The Project Description and Environmental Setting Sections together create the FOUNDATION of the EIR.

If information is omitted or incorrect in these sections, the EIR’s analysis of environmental impacts cannot be adequate.

Project Description Should Include:

Questions to Ask When Reviewing the Project Description (the General Plan):

  1. Is the Project Description (GP) complete? Are there aspects about the project that are not described accurately? Adequately?

  2. Is the Project Description of the GP consistent throughout the DEIR?

  3. What is the Description (GP) missing that is needed to fully and accurately disclose and analyze the impacts of the project? to agricultural resources? to traffic? etc.

How To Use The EIR To Support GPU Recommendations

The goal of commenting on the DEIR is threefold:

(1) Identify flaws in the DEIR that need to be rectified in order for the document to support informed decision-making = be legally adequate.

(2) Cite information in the DEIR that supports stronger policies in the General Plan. E.G. The numerous impacts to prime farmland support focusing growth in urban areas and additional protection for farmland.

(3) To create “leverage" for stronger policies in the General Plan. E.G. The DEIR fails to adequately analyze impacts associated with the cluster policy. Therefore, the cluster policy should either be eliminated or further defined so the cluster development does not result in significant impacts.


Comments on the Project Description

Practice Tips
Follow-up Your Comment With a Specific Question

The project description fails to adequately describe a number of key General Plan policies and proposed land uses in sufficient detail for their impacts to be adequately analyzed including, but not limited to:

1) Clustering Policy. How many cluster units will result from the GP policy with and without the mitigation measure suggested in the DEIR? Where will they be located? How will they be served by infrastructure and services? What will be the “cost" to the County of serving these units? Do they provide needed housing? Without this information, the EIR’s analysis of potentially significant impacts cannot be adequate. To address this DEIR omission, the cluster policy could either be eliminated or restricted so that cluster development does not result in a significant impact.

2) Rural Centers. How many new units/non-residential square feet will result from development in Rural Centers? Without this information, the DEIR’s analysis of potentially significant impacts is incomplete. To address this DEIR omission, the major land group “Rural Centers" could be eliminated and these areas included in Rural Lands.

3) Estate Units in Agricultural and Resource Lands. How many new units can be built in these areas? What will be the impact on ongoing agricultural uses if these units are permitted (e.g. replace units needed for ag families and workers; create conflicts with ag uses, etc.). Potentially significant impacts of this policy must be addressed or the policy changed to require first units on Agricultural parcels be accessory to agricultural purposes.

4) Special Treatment Areas. Please provide information about the number of special treatment projects, their locations and total development allowed under the Plan policies (DEIR at 5.1-62). The DEIR states that it is not possible to know at this time how many STA projects there will be or what the specific impacts of these projects will be. Removal of STAs from the General Plan would resolve this potential omission.

5) What is the assumed build-out capacity of future proposed wineries and related impacts? Please provide detailed information about the scale, type and quantity of winery uses as permitted by the General Plan with and without the proposed mitigation measure. How much water will these uses require? Other services? A General Plan policy to require a specific plan prior to implementation of winery corridors would go a long way to address these omissions in the DEIR.

Environmental Setting Must Include:

A description of the physical environmental conditions in the vicinity of the project from both a local and regional perspective, as it exists at the time the NOP is published. The regional setting must be sufficiently large in geographic extent to adequately analyze cumulative impacts.

Examples of setting information --

Questions to ask when reviewing the environmental setting sections:

  1. Does the DEIR accurately and completely describe conditions as they currently exist? (e.g. sources and uses of water, etc.)
  2. Is setting information based on adequate and current surveys, other credible and complete information sources?
  3. Is the geographic study area for cumulative analyses sufficiently large? (e.g. sufficient to account for impacts associated with employee housing? For biological resources? For traffic?)
  4. What missing setting information should have been developed and included in the DEIR and why?

Example Comments on Setting Information:

Please include the following information in a revised DEIR and revise impact discussions accordingly:

Environmental Impact Analyses


Water: An EIR must identify the water supply and analyze whether the water supply is adequate to meet demand from the project, current users and cumulative projects. The EIR must analyze the impacts of development of new water on biological resources.

Biological Resources: An EIR must go beyond the analysis of loss of habitat and evaluate effects of development (including new roads and utility corridors) on habitat fragmentation, interference with wildlife corridors, etc.

Questions to ask when reviewing the Environmental Analysis Sections:

  1. Are the underlying assumptions accurate? (e.g. amount of development at buildout allowed by the Plan; trips generated by new development, etc.)

  2. Does the DEIR analyze and disclose the impacts associated with the proposed physical development in terms of its scale/amount, location, type?

  3. Does the DEIR analyze potential impacts associated with policies?

  4. Does the DEIR accurately characterize the “significance" of the impact? If not, why not? (lack of information, incorrect information, lack of analysis, other?)

  5. If the DEIR relies on a Plan policy or mitigation measure to reduce a significant impact to less than significant, can you follow the logic? Does the DEIR clearly state how the policy or measure reduces the significance of the impact?

  6. Does the DEIR omit any significant impacts?


Comments on Adequacy of Environmental Analysis

The DEIR states that “the impacts of future growth under the GPU on regional water supply is difficult to assess because the prospects for alleviating current basin-wide deficits are both uncertain and complex." DEIR at 5.13-17. The section continues on to discuss potential impacts with respect to Community Areas and Rural Centers. For example:

If the General Plan is to continue to include a policy to develop RSJ, a revised analysis must include additional information concerning water use and water impacts associated with development of RSJ. In the alternative, the DEIR should recommend that development not be permitted at RSJ.

Moreover, the General Plan should plan for only that amount of development that can be served by environmentally sound water supplies.

Cumulative Impacts Analysis

Questions to ask when reviewing the cumulative discussions:

  1. Are cumulative projects or plans adequately disclosed and quantified?

  2. Are cumulative impacts adequately disclosed and quantified where possible?

  3. Are the study areas for each impact large enough to identify cumulative impacts? (e.g. the study area is limited to Monterey County for the most part).

  4. Does the DEIR identify mitigation measures for cumulative impacts?

  5. Are projects or planned development potential omitted from the analysis?


Comment Concerning Cumulative Impacts

The DEIR’s analysis of cumulative impacts to water supply is adequate for at least the following reasons:

First, the DEIR fails to fully describe project-related and cumulative water demand, including demand by foreseeable growth in the cities and all uses allowed by the proposed Monterey County GP, and therefore impacts are underestimated.

Second, the DEIR does not describe all likely sources of new water, and therefore fails to identify the significant impacts associated with development of new water.

Third, the DEIR lacks “analysis" of cumulative water impacts and simply concludes that impacts will be significant:

“All potential sources of growth within constrained water basins contribute to the water supply impacts identified above (e.g. substantially deplete supplies, groundwater sources, create demands that exceed supply, etc.). These impacts are cumulatively significant for the same reasons the impacts of growth in the areas above are significant." DEIR at 5.13-29.

Please provide additional information about TOTAL countywide water demand and potential new supplies. Based on this information, what are the impacts associated with new water development necessary to serve proposed new development without adversely impacting environmental resources and ground and surface water sources? If water imports are a source of water, please disclose the out-of-county impacts associated with such water transfers.

The DEIR concludes that “additional measures to help in mitigating cumulative impacts can be achieved through a project alternative that limits GPU growth to a level necessary to achieve project objectives. What level of new development in the County unincorporated areas/in the whole County, can be served by existing “safe yield" water supplies? (e.g. without further degradation of environmental resources, ground and surface water sources). Please analyze such an alternative in the FEIR. Planned development under the new General Plan should not exceed safe yield water supplies or result in significant adverse impacts as a result of water development, storage or transfer. That may require the General Plan to limit new development to existing lots of record in some areas.

Growth Inducing Impacts


Comment on Growth Inducing Analysis:

The DEIR fails to provide any meaningful analysis of the growth inducing potential of the General Plan’s approach to development. Specifically, policies in the General Plan will permit significant high end housing, which will likely result in increased demand for local services and affordable housing. The growth inducing impacts of producing an over-supply of high end housing are noted in the DEIR, but not analyzed.

Moreover, the DEIR fails to analyze the growth inducing impacts of new services, including expanded roads and water supply “proposed" by the General Plan and necessary to serve new development.

A revised environmental document must include an adequate analysis of the project’s potential for growth inducement, including, but not limited to the following:

Alternatively, the General Plan can include policies that: (1) prioritize development of housing for Monterey residents and workers and (2) direct growth to cities and urban areas where extension and expansion of infrastructure will not induce development beyond planned development.

Types of Mitigation Measures

Questionable Mitigation Measures

Inadequate Mitigation Measures

Questions to Ask About Mitigation Measures:

  1. Are feasible mitigation measures proposed for each significant impact, including significant cumulative impacts? The County may not put off identification of “measurable" mitigation until later.

  2. Does the EIR explain and document how and whether the measure will avoid or substantially reduce the impact to “less than significant." If not, why is the logic flawed and what measures might effectively address the impact?

  3. Are there other measures that should be identified?

  4. Does the EIR identify “secondary" impacts that may result from the mitigation measures.

Examples of Mitigation Measures that are Questionable/Unacceptable:

Measure 1i: “Since the Use of an Affordable Housing Overlay concept is new for Monterey County and is not yet known how many projects may be proposed, the County shall monitor AHO projects as a component of the 5-year review and evaluate the cumulative land use impacts of projects relative to land use incompatibilities and consistency with adopted policies, in particular the fundamental objective of the Growth Management Policy to preserve the distinction between rural and urban lands."

Acceptable Mitigation:

Delete the Affordable Housing Overlay policy and map (LU-5) and replace with a policy that gives priority to affordable housing developments located in the four Community Areas where services can be provided.Measure 1l: Since future Special Treatment Area overlay designations may lead to the creation of more lost than could otherwise be created by the underlying land use designations and it is not known how many projects may be proposed and where they may be located, the County shall monitor new STA designations as a component of the 5-year review and evaluate the cumulative land use impacts of such projects relative to land use incompatibilities and consistency with adopted policies, in particular the fundamental objective of the Growth Management Policy to preserve the distinction between rural and urban lands. Based upon the results of each 5-year review, the Board of Supervisors shall decide whether revisions to Policy LU-11.1 are required.

Acceptable Mitigation:

Eliminate the STA policy and direct new growth into the four Community Areas where services can be provided and development will be consistent with the Growth Management Policy.

Examples of Feasible Measures (New Policies/Deleted Policies) Omitted from the DEIR:


Questions to ask when reviewing alternatives:

  1. Are there other feasible alternatives that would reduce or eliminate significant impacts of the project or project alternatives?

  2. Does the DEIR adequately analyze the alternatives it does include? Specifically, does the DEIR identify the comparative impacts of the alternatives to the proposed project and other alternatives?

  3. Is a sufficient range of alternatives described?

Additional Alternatives We Request Be Analyzed:

There are other feasible alternatives that should be analyzed as follows:

Practice Tips

Select a topic area to review (for instance, land use, biological resources, transportation/circulation).

Review the section with the following questions in mind:

  1. Is the project sufficiently described to ascertain all potentially significant impacts related to the topic?

  2. Is there sufficient information about the project setting and regional setting to support a complete analysis of impacts?

  3. Does the section identify all potential impacts? Are they properly characterized as less than significant, significant, etc.

  4. Are all feasible mitigation measures identified for each significant impact?

  5. Does the discussion clearly state how each mitigation measure eliminates or reduces the level of significance of the impact it addresses?

  6. Are the cumulative impacts related to the topic area adequately analyzed and mitigated?

  7. What additional information related to each of the above questions is required to perfect the discussion? List as questions.

  8. Use information in the Economic Study, EIR and other reports to support your request for additional mitigation measures in the form of new or modified policies, modified land uses, deleted policies. EG. The economic study and DEIR provide numerous reasons why the General Plan must be improved:

The Economic Impact Analysis on the GPU, prepared by Applied Development Economics, convincingly demonstrates that stopping rural subdivisions, and focusing new growth into existing urban areas, will provide the best fiscal and economic effects for Monterey County. In other words, this study validates what the public has been telling the County, and what the Twelve Guiding Objectives mandate.

Specifically, the Economic Impact Analysis says:

  1. Unincorporated development exerts higher service costs on County government, than does growth in the cities. Of the $11 million incremental deficit created by the GPU growth, $10 million is associated with unincorporated development, and only $1 million with city growth, despite the much higher growth levels in the cities [Page ii; Page 18].

  2. More than 85 percent of workers need housing priced at $376,000 or less [Page v].

  3. Residential development should not outpace job development in each area [Page vii].

  4. From a policy perspective, the County may wish to avoid encouraging substantial industrial development in the unincorporated area in the Central Salinas Valley or South County [Page 7].

  5. Lower growth scenarios show a smaller deficit, while the higher growth scenarios increase the County’s fiscal deficit [Page 9; Page 17].The study…identified the cost to the County, per residence, for residents who live in the unincorporated County but work in another county. This cost is estimated at $466 per residence [per year], more than six times the cost per residence for those who both live and work in the unincorporated County [Page 18].

  6. The unincorporated County’s role as a bedroom community, either for workers employed in neighboring counties or for workers employed in Monterey County, is very expensive and a constant net drain on County resources [Page 20].

  7. Low density residential developments generate costs that are much greater than high or even medium density developments [Page 20].

  8. Studies documenting the fiscal benefits of compact development…have addressed the issue in all parts of the country…and California [Page 21].

  9. The County should avoid significant amounts of low density development in rural, poorly served areas…. [Page 22].

  10. Agricultural land reductions potentially impact this cluster [the Agricultural Services Cluster], and could erode its dominant position within the Monterey County economy.

  11. Policies that provide more flexibility regarding use … may improve agricultural land value or farm income but in aggregate and over time weaken overall agricultural viability by increasing land values beyond the point supported by agricultural value [Pages 42-43; emphasis added].

  12. The unincorporated areas around Rancho San Juan produce higher value crops such as strawberries, which results in a much higher potential impact per acre [for conversion of these agricultural uses to urban uses] [ Page 46].

  13. The extraordinary beauty of the communities along the coast draw very high income individuals, some of which [sic] retire in the area. It is also due in part to the demand for commuter housing from workers in silicon Valley….The primary evidence of the [county’s] economic transition is the rapid escalation of housing prices throughout the County [Page 62].

  14. It is critical that the public infrastructure not degrade further as new development proceeds [Page 63; emphasis added].

  15. Residential development should not outpace job development in each area [Page 63].

To improve our local economy, and to provide good jobs and good housing, the GPU must:

In fact, this is what the Twelve Guiding Objectives also require.

Useful Information

DEIR Comment Period Ends: April 2, 2004

Send comments to:

Genee Terada
Monterey County Environmental Resource Policy
230 Church Street, Bldg. 3
Salinas Ca, 93901

General Plan Comment Period Ends: March 26, 2004

Send comments to Genee Terada at above address

Public Hearing Dates:

March 22, 2004 (special evening meeting)
Last PUBLIC HEARING before the Planning Commission Decision


Board of Supervisors Chambers
County Courthouse
240 Church Street, 2nd Floor
Salinas, CA 93901

April 7, 2004
(Planning Commission special daytime meeting)

April 21, 2004
(Planning Commission recommendations to Board)

April 28, 2004 –If needed
(Planning Commission recommendations to Board)

County General Plan Website:

Landwatch Website:

Economic Impact Analysis:

[Return to County Plan Update Issues and Actions]