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Refinement Group Corrections and Comments - League of Women Voters Comparison of Community General Plan Initiative (GPI) and 2006 Monterey County General Plan (GPU4) 5-10-07 Description GPI – Measure A GPU4 – Measure C Refinement Group Corrections/Comments
Coverage	Amends ‘82 General Plan Land Use Element, North Coast Coastal Plan, and 2003 Housing Element.¹ Excludes Big Sur, Del Monte Forest, and Carmel Local Coastal Programs.² Other elements of ’82 Plan are unchanged; they could be amended by Board of Supervisors without voter approval.³	Updates all elements to the General Plan; excludes all Coastal Programs. Includes Agriculture and Winery Corridor Plan	Corrections: ¹LWV ignored the Nossaman legal analysis that indicates GPI amendments to the Housing Element are not lawful. (see Nossaman “Analysis of the Initiative…) ² GPI excludes lands within the land use plans of Big Sur, Del Monte Forest and the Carmel Area from only five GPI policies (see GPI Land Use Policies 26.1.3.1, 26.1.3.2, 26.1.3.3, 26.1.4 and Housing Policy H-3.0); the rest of the GPI changes apply everywhere. (see GPI Policy 26.1.4.6) ³ The 1982 General Plan portions not amended by GPI cannot be amended by the Board of Supervisors without voter approval; if GPI passes it is a readoption of the 1982 General Plan with the GPI changes. GPI specifies no subsequent general plan changes can be made without a countywide vote. (see GPI Section 4 B, pp 77, 78)
Areas for Development	5 Community Areas • Pajaro² • Castroville² • Fort Ord • Boronda² • Chualar¹ Lots of Record³	7 Community Areas • Pajaro • Castroville • Fort Ord • Boronda • Chualar • Rancho San Juan • San Lucas 9 Rural Centers • Prunedale • River Road • San Benancio/Corral de Tierra • Toro Park Estates • Lockwood • Pleyto • Bradley; San Ardo • Pine Canyon 16 Property Owners Requests (611 acres)⁴ 16 Special Treatment Areas (391 acres)⁴ 8 Study Areas (21 acres)⁴ 1,200 dwelling units outside Community Areas and Rural Centers⁴ 576 new units in Carmel Valley⁵ Lots of Record³	Corrections ¹ GPI ignores the prior community planning process underway in Chualar and imposes a limit on expansion of the community area boundary without regard to the desire of community residents and the economics of creating a viable community area. Any boundary area change would be subject to a county-wide vote. (see GPI Policy 26.1.3.2 (c) re boundary and Section 4 B re vote requirement) ² GPI restricts the boundaries of the Community Areas of Pajaro and Castroville to those created 20 years ago and the boundary of the Community Area of Boronda to that created 18 years ago, again ignoring current public planning processes or desires of community residents. (see GPI Policy 26.1.3.2 (b)) ³ Stating ‘lots of record’ are areas for development is both inaccurate and misleading. The correct number of lots of record based on a recent County review is 6,058. This does not reflect the fact that a number of these are owned by utilities that would not build homes. A substantial number of lots of record are parcels for roads and access easements, or parcels created for water wells, utility easements and related equipment. Further, many of the lots of record are subject to slope or environmental constraints and not eligible for development. (see Final EIR (FEIR) at page 486 for a correction of the number of residential-eligible lots of record). ⁴ Listing 1,200 dwelling units outside Community Areas and Rural Centers and listing the special treatment and study areas double counts existing parcels. These lots are part of “existing lots of record,” not in addition to those lots. ⁵Listing “576 new units” in Carmel Valley under GPU4 but not under GPI is misleading; that is the number of remaining lots to be created under the existing 1984 Carmel Valley Master Plan allocation system, a plan that pre-exists GPI. GPI creates a legal conflict between the pre-existing plan and the GPI provision prohibiting creation of new parcels without a county-wide vote. (see GPI Section 3 (3) (a) and Policy 26.1.3.3). Comment: Although GPI does not change the 1982 General Plan policy directing the County to achieve a jobs-housing balance, GPI does eliminate ‘community areas and rural centers’ south of Chualar, and assigns the lowest priority to developing and implementing the Chualar Community Area Plan (see comment on LWV footnote at the end of the matrix), thus preventing the County from achieving its housing responsibilities in those areas (as well as overall). LWV’s listing of the number of acres in Property Owner Requests, etc, is prejudicial because the total of acres does not equate to housing units. The total acreage involved in Property Owner Requests, Special Treatment Areas and Special Study Areas is 1,023, or .005% of the county’s unincorporated land area. (see DEIR Table 3-4) The total potential housing units in property owner requests and special treatment areas is 350. (see FEIR Table 3-5).
Dwelling Units	10,620 units¹ 18% over AMBAG 2030 growth forecasts for unincorporated area.²	21,517 units¹ 140% over AMBAG 2030 growth forecasts for unincorporated area.²	Corrections ¹The potential numbers of dwelling units under GPI is 13,973 and under GPU4 is 16,900. (see FEIR Table 4.2-2, DEIR Tables 5-1, 5-2, 5-3) One then has to adjust both downward by 2000 based upon the revised number of potential lots of record. ²The 2004 AMBAG Forecast of Population, Housing and Employment does not forecast housing needs. It predicts how many housing units will be built given certain assumptions including county and city general plans standards, population trends, employment trends and current building trends. Any estimation of housing needs would begin with an estimation of how badly the county is underserved at the beginning point of estimating need. (see DEIR at page 4.15-4 for an analysis of housing needs and page 4.15-7 and Table 4.15-8 for analysis of build-out potentials). Also see BAE report Table 1 at page 6 re buildout , GPI Illustration 37 and BAE report at pages 30 and 31 for analysis re meeting future housing needs). From 1990 to present, in every year but one (1990), Monterey County has actually built far fewer homes than AMBAG forecasts predicted. A review of AMBAG forecasts and California Department of Finance data detailing actual numbers of units for which permits have been issued shows Monterey County fell short of its housing needs by 11,000 units between 1990 and 2006. The DEIR notes at Table 5-2 that GPU3, which LWV supported, allowed 21,666 potential dwelling units.
Affordable Housing – Very Low, Low, Moderate and Workforce Income Housing; Farm worker housing; Accessory Units Calculations are based on Affordable Housing Requirements for each Plan	23% of units allowed under Initiative would be permanently affordable–2,440 units. Units offered first to County residents and workers.¹ Developers must provide • 30% in 4 community areas for residential development of 20 or more units. • 40% for residential developments of 20 or more units on County-owned land in the Fort Ord Community Area (excludes East Garrison) • For less that 20 units, in-lieu fees adopted by the Board of Supervisors Allows farm worker housing in Community Areas and on Rural and Agricultural Lands on legal lots of record.³ Allows accessory structures and secondary dwellings, (e.g., granny units) on legal lots of record.⁴	16% of units allowed under GPU4 would be affordable-3,380 units.¹ Supervisors have endorsed sale of these units after 15 years at market-rates with share of proceeds returned to County for reinvestment in affordable housing. Final action on ordinance scheduled for April.² Developers must provide • 20% affordable housing in community areas and rural centers for residential development of 5 or more units. • 50% in areas outside of community areas and rural centers (approximately 600 dwelling units) • For 3-4 units, in-lieu fees adopted by the Board of Supervisors Allows farm worker housing and accessory units⁴.	Corrections ¹LWV appears to misunderstand the affordable housing process, and uses incorrect numbers of potential dwelling units to calculate the percentage of units that would be affordable. “Affordable” housing falls into two categories: “Traditional” affordable housing (very low, low and moderate income housing), and “Workforce” housing. LWV appears to calculate only the Traditional affordable units. The correct number of GPI's affordable units is 2,340, not 2,440, plus the addition of 424 required Workforce units, a total of 2,780 affordable units of all kinds out of a total 13,973 allowed housing units equals 19.78%. Under GPU4, developers are not allowed to use the more expensive Workforce units to meet their affordable housing requirement; the requirement must be met using only Traditional (very low, low and moderate income) units. The correct number of potential affordable units under GPU4 is 2,797 (Traditional affordable only), or 16.55% of the total 16,900 potential housing units. Thus the 2006 General Plan will generate 457 more (20% more) of the most-needed very low, low and moderate income units than GPI. GPI caps the amount of affordable housing that can be built over the next 25 years to the 2,780 units. That figure is sufficient only to meet affordable housing targets for the County’s first 5-year affordable-housing-needs requirement. That would leave 20 years during which the GPI would effectively not provide any affordable housing. This ignores the current shortfall and any future need and new State targets for affordable housing, and shifts the burden to the cities. GPI proponents need to ask the citizens of the cities if they are willing to accept all of the future affordable housing that would be built in the County after the first 5 years should GPI become law. ²Supervisors discussed this change and asked staff to return to the Board with a detailed analysis of the issue. No action was taken and no action or discussion is yet scheduled. Title 18, Section 18.40.C., of the County's Inclusionary Housing Ordinance, currently provides in pertinent part, "For both for sale and rental inclusionary units, affordability and occupancy restrictions shall remain in effect in perpetuity..." It has been commonly misreported that affordable housing units can be sold at market rates under GPU4 after 15 years. Moreover, the initiative cannot legally amend the Housing Element (see Nossaman analysis mentioned above). “Locking in” housing policies for 25 years violates state law which requires the Housing Element be revised at least every five years. (see Government Code Section 65588(e)) ³LWV fails to note GPI allows farmworker housing on Agricultural Land only if it is restricted to workers on site; this is not the current model of farmworker employment and so is of extremely limited value. GPU4 allows development of farmworker housing that matches current employment practices (i.e., workers serve dozens of different farms, not one farm exclusively). Further, GPI dictates farmworker housing cannot be separated from the parcel on which it is constructed, which creates financing and insurance difficulties. (see GPI Policies H-3.0 (f) 1), 6) and 7)) ⁴GPI allows one primary residence and structures accessory to agricultural uses; GPI does not allow secondary dwellings. (see GPI Policies 26.1.4 (d) (i) and (iii))
Maximum Densities on Rural and Resource Conservation Lands	’82 Plan includes Area Plan land use maps with mapped maximum densities. These densities are frequently lower than the density range by land use category, e.g., Rural Grazing at 10 to 40 acres per unit.	All mapped maximum densities are deleted allowing for more dwelling units per acre in many areas.²	Corrections ¹GPI incorporates new land use maps with no maximum densities and incorporates the ’82 land use maps “for reference purposes only.” GPI states its new maps do not replace the 82 Plan maps but also limits Land Use Classifications to five, which eliminates the classifications in the 82 Plan reflected on Map 13a – Major Land Use Classifications. GPI does not designate “Resource Conservation Lands.” (see GPI Appendix A, Map 2 – Major Land Use Classifications, GPI Appendix B, Map 13a – Major Land Use Classifications, GPI Sections.3.h and 3.i., and GPI Policy 26.1.3.1) ²GPU4 provides mapped maximum densities in each Area Plan.
Undeveloped Office, Retail and Industrial Land	7,657,000 sq. ft. within Community Areas. 67,222,000 sq. ft. outside Community Areas which can be developed as long as lot divisions are not required.¹	9,887,000 sq. ft. within Community Areas. 447,667,000 sq. ft. outside Community Areas.²	¹ GPI does not allow office, retail and industrial uses on Rural Lands and Agricultural Lands, which is literally all lands outside Community Areas. Representing that under GPI 1,543 acres outside Community Areas can be developed for office, retail or industrial uses is not correct. GPI designates land use classifications that do not include these uses. GPI does say existing zoning will remain but because it changes underlying land use classification, under California law the zoning must be changed to conform to the land use classification. All existing commercial and industrial facilities will become legal, nonconforming uses under GPI, a fact which presents serious financing, insurance and replacement issues for existing properties. The goal of zoning is to eventually eliminate nonconforming uses. (see GPI Policy 26.1.3.1 and GPI Appendix A, Map 2 – Major Land Use Classifications) ² Under GPU4, there are 10,504 acres in the unincorporated area of the county, including in community areas and rural centers, designated for commercial and industrial uses. This is an increase of 183 acres over the ’82 Plan, not the 8,800 acre increase LWV indicates. 10,504 acres totals 457,554,000 sq. ft. of land area but does not mean that number of square feet of buildings would be realized as LWV implies by using square feet instead of acres. (see DEIR Table 3-4)
Winery Facilities	’82 Plan allows for winery facilities and requires environmental review (CEQA) for most projects, e.g., wine processing and tasting rooms.¹	Includes Agriculture and Winery Corridor Plan which facilitates project approval by exempting small wine processing facilities and tasting rooms from environmental review (CEQA).²	Corrections ¹ The ’82 Plan allowed wineries and wine processing facilities under some circumstances but GPI does not allow such uses outside Community Areas and does not allow subdivision of land, so parcel creation for small wineries or tasting rooms, therefore development of them, are effectively inhibited or eliminated. (see GPI Policies 26.1.3.1 and 26.1.4 (c)) ²GPU4 does not exempt small wine processing facilities and tasting rooms from CEQA. The DEIR analyzed the Winery Corridor and identified impacts which were mitigated with the final adoption of GPU4 and the FEIR. GPU4 establishes a permit process for development of a specific number of wineries and tasting rooms within the corridor(s); these impacts were analyzed in the DEIR. GPU4 requires additional environmental review for wineries and tasting rooms greater than the number identified in GPU4 or outside of the winery corridor(s). Additionally, some wineries and tasting rooms allowed within the winery corridor(s) may be required to complete additional environmental review depending on site-specific conditions and impacts. (see DEIR pg 1-5, Section 1.3. and GPU4 page AWCP-22, Section. 4.3) Comment By only revising pages 114 to 118 of the 1982 General Plan's general land use policies (see GPI Section 3.a., pg 2), which did not include the winery corridor, GPI effectively precludes development of this $1 billion industry, thus stifling economic growth and opportunity. LandWatch contended in its lawsuit to stop the D’Arrigo cooler project that such uses are not ‘agricultural.’
Level of Service (LOS) defines traffic congestion with LOS A being free-flowing and LOS F being the worst level of congestion with traffic demand exceeding capacity	The ’82 Plan has LOS C as the standard (FEIR p. 296).¹ LOS C generally means traffic moves at about 45 mph but is susceptible to congestion due to turning traffic.² Many County roads are below LOS D.³ However, many rural areas have roads at LOS C. New projects in these areas causing LOS to drop below C are required to mitigate to LOS C (Policies 37.1.2 and 39.1.4).	Drops standard to LOS D (i.e., unstable traffic flow with traffic moving at about 40 mph).^{1 & 2} New projects causing LOS to drop below C would not be required to mitigate to LOS C. DEIR states (p. 4.6-29) that by 2030: • Road segments operating at LOS E would increase from 15 to 33 (e.g., Hwy 101, Blackie Rd. to Orchard Lane)³ • Road segments operating at LOS F would increase from 14 to 30 (e.g., Hwy 1, northbound from Fremont St on-ramp to Hwy 218 off-ramp). GPU4 commits to meeting LOS D on County roads by 2026; however, funding is not identified (Policy C-1.2).⁴	¹ GPU4 does not drop the LOS standard. The 1982 General Plan does not set LOS C as a standard. (see 1982 General Plan at pages 129and 130 re levels of service standards and page 219 re unacceptable levels of service; LOS D is not described as udesireable. ²The definitions of LOS C and LOS D are incorrect. The correct definition of LOS C is “stable operations, acceptable delays.” The correct definition of LOS D is ‘approaching unstable, queues develop rapidly, but no excessive delays.” (Transportation Research Board 1994) The National Academy of Sciences 2000 Highway Capacity Manual states at page 2-3 “most design or planning efforts typically use service flow rates at LOS C or D to ensure an acceptable operating service for facility users.” It is important to note that LOS is determined only during any portion of peak commuting hours that may have additional congestion and does not represent traffic for the rest of the day or necessarily through the entire peak morning and afternoon hours. ³The FEIR states roads likely to operate at LOS E total 28, not 33 (currently 14), and roads likely to operate at LOS F total 32, not 30 (currently 14). (See FEIR ERRATA, Table 4.1-5 at page 682) ⁴ It is not accurate to say “funding is not identified” in GPU4, but that does accurately describe GPI. GPU4 details specific requirements for funding circulation improvements. (see GPU4 Circulation Element Policy C-1.2 a. through g. and Policies C-1.4 through C-1.11. Policies C-1.3 and C-1.4 prescribe the development constraints imposed if LOS D is not achieved or achievable)
New Daily Trips	129,000 to 132,000 New Daily Trips, a 29% increase over year 2000 daily trips for unincorporated areas.	231,000 to 273,400 New Daily Trips, a 52-61% increase over year 2000 daily trips for unincorporated areas¹	Correction ¹ The DEIR estimates GPU4 would generate 27,000 more daily vehicle trips than the 82 Plan. (see DEIR at page 5-6) Comment Does GPI intend fewer people or fewer jobs? Vehicle trips are a function of population and jobs, as noted in the DEIR. If GPI would yield significantly fewer daily vehicle trips, GPI policies must reduce population or reduce jobs, or both.
Agricultural Land Lost ⁽¹⁾	600 acres lost in Community Area.¹ Retains ’82 Plan prohibition against development on all other farmland except for property owners’ families and farm worker housing. Requires voter approval to change designation of agricultural lands for development (26.1.3.1).	4,900 acres lost.¹ Allows development on farmland when it can be shown that it would not be detrimental to agricultural viability of adjoining parcels. Criteria to show project impact not identified.	Corrections ¹ GPU4 has lesser impacts on farmland than GPI. (see DEIR at page 5-17 which states that “build-out of GPI would have greater impacts on agriculture resources than the 2006 General Plan” and explains why GPI policies forcing all future growth into Salinas Valley cities would cause Salinas Valley cities to expand onto “Prime Agricultural lands,” thus resulting in more conversion of agricultural lands to urban uses. The DEIR also notes that GPI does not have any policies with respect to city growth as does GPU4 and that the GPU4 provisions for community areas and rural centers direct growth to less productive agricultural lands and away from more productive agricultural lands. Comments The LWV comparison chart includes a footnote explaining how it concludes more farmland is lost under GPU4 than under GPI. The footnote is reproduced at the end of this matrix along with comments on the LWV calculations and noting LWV did not file any comments questioning this conclusion of the DEIR. If LWV calculations had any merit the DEIR conclusion would have been changed.
Cultivation on Steep Slopes	’82 Plan and zoning ordinance prohibit cultivation on slopes over 25-30%.¹	Allows cultivation on slopes over 15-30% with a permit.² About 505,000 acres of private land are on slopes greater than 25%.	Corrections ¹1982 Plan Policy 26.1.10 ‘prohibits’ development on slopes greater than 30% but provides an exception whereby development on slopes of 30% or greater may be allowed if certain findings are made. The ’82 Plan and GPI require no permits for development on slopes up to 30% (25% in north county and Central Salinas Valley areas). ²GPU4 Policy OS-3.5 requires a permit for development on slopes over 25% in all areas of the County, and requires specific criteria and design techniques for erosion control, slope stabilization, visual mitigation, drainage and construction techniques – while minimizing development in areas where unstable slopes, soil and geologic conditions, or sewage disposal pose substantial risk. GPU4 Policy OS-3.5 also requires a grading permit for conversion of uncultivated lands to ag use on slopes over 25%. The issuance of a grading permit requires the applicant to address all of the criteria and design techniques stated above. GPU4 Policy OS-3.5 also requires a permit for development , including the conversion of previously uncultivated lands, on slopes between 15% -24% and 10%-15% on highly erodible soils. Comment This part includes more false and misleading statements. GPU4 is more restrictive than the ’82 Plan and GPI regarding development on slopes.
Biological Resources	‘82 Plan has policies that protect limited or threatened plant communities, maintain wildlife habitat, and require consultation with the California Native Plant Society and measures that protect rare and endangered plant species and habitats remain unchanged. Limiting development to 5 Community Areas prevents encroachment into in biologically rich resource areas.¹	GPU4 addresses listed endangered State and federal species only and omits consultation with the California Native Plant Society. State and federal requirements protect listed endangered species.² Maintenance of natural areas is encouraged, not required.²	Corrections ¹GPI does not limit development to Community Areas. Rather, it allows development of a residence and accessory structures on existing lots of record. GPI does not preclude subdivisions in three coastal areas (Carmel Area, Del Monte Forest, and Big Sur) or in Community Areas. ²GPU4 protects: (a) species listed as threatened and endangered pursuant to state and federal law, (b) state-listed rare species, (c) designated critical habitat, and (d) habitat protected in an Area Plan. Also, "additional focused surveys for certain species may be required" after the initial biological survey. Further, the biologist shall recommend mitigation measures to reduce impacts on "sensitive biological resources" to a less-than-significant level. (See GPU4 Policy OS-5.16 and Glossary for "special status species")
Provision of Infrastructure and Development	Roads/Infrastructure: New development shall be phased so that all necessary public infrastructure and services are completed prior to or concurrent with new development [26.1.4 (a)]. ’82 Plan provides that developments consistent with the land use plan designations may be denied due to factors such as lack of public facilities and services, infrastructure phasing problems, water availability and sewage problems, or presence of environmental and/or plan policy constraints which cannot be mitigated. Water: New development within Community Areas shall not proceed without establishing that there is a permanently sustainable water supply available. County decision-maker is required to make a finding based on substantial evidence provided by the water supplier (or the landowner if there is no water supplier) that there is a permanent sustainable water supply [26.1.4 (b)].¹ Single family units on lots of record would proceed under ’82 Plan provisions.	Roads/Infrastructure: Subdivisions in Rural Centers that are consistent with specific requirements can proceed before preparing an Infrastructure and Financing Study and assuring a funding mechanism (Policy LU 2.29).¹ Projects outside Rural Centers that reduce County roads to below LOS D require phasing programs so that development is concurrent with improvements that maintain LOS D (Policy C-1.2). Policy PS-1.5 allows development to start with only infrastructure phasing plan approved in concept.² Water: Development located in an area that does not have a proven long term sustainable water supply that intensifies water use shall not be allowed (PS-2.3).³ No new development, except for the first single family dwelling, shall be approved without proof, based on specific findings and supported by evidence, that there is a long term, sustainable water supply (PS-3.1). Long term water supply is defined as available water supply that can be extracted from a basin to service the existing and projected development in that basin for 20 years without degrading water quality, damaging the economical extraction of water, or causing significant unavoidable adverse environmental impacts.	Corrections ¹ Subdivisions may not proceed without provision of infrastructure. (see Monterey County Codes, Title 19) ²This representation is false. GPU4, Policy PS-1.5 states in full “Improvements shall be installed concurrently with each phase of new development in accordance with an infrastructure phasing plan. An infrastructure phasing plan, if needed, shall be approved in concept at the time of project approval.” [emphasis added] ³GPU4 Policy PS-3.1 is the correct citation for this policy. Comment re Water There is no such thing as a ‘permanent’ water supply and no expert can establish that a ‘permanently sustainable” water supply exists. This is an unrealistic and unattainable standard, particularly with respect to the areas where GPI directs all growth is to take place. This policy is tantamount to decreeing no growth will take place because a ‘permanently sustainable’ supply cannot be established. GPI does not address water supply outside of Community Areas but does say “areas outside the urban development boundaries are suitable for long-term protection of agriculture, natural resources, public health and safety, and buffers between community areas and cities.” (see GPI policy 26.1.4) GPI does not address many critical water issues; GPU4 does. These differences in water policy between GPI and GPU4 are significant. GPU4 requires proof of a long-term water supply for all development beyond the first single family dwelling; GPI only addresses standards within the Community Areas. GPU4 also imposes the following requirements: 1) new development to connect to existing water service providers where feasible (GPU4, Policy PS-2.3); 2) requires the establishment of standards and criteria for all new wells (even for a SFD on an existing lot of record) (PS-2.5); 3) requires specific criteria be developed for proof of a long term water supply (PS-3.3); 4) requires specific criteria be developed for the adequacy of all new wells (PS-3.4); 5) prohibits the drilling or operation of any new wells in saltwater intruded areas (Policy PS-3.6); 6) requires that a program to eliminate overdraft be developed and implemented (PS-3.9).
Maximum Emergency Response time for Fire, Sheriff and Ambulance	’82 Plan does not address maximum emergency response times.	Maximum emergency response times are 45 minutes for rural areas; 15 minutes for structural coverage in Rural Centers, and 5-8 minutes for structural coverage in Community Areas.¹	Correction ¹ GPU4 details required response time for creation of new parcels. (see GPU4 Table PS-1) Comment Neither the 82 Plan nor GPI deal with response times.
City-Centered Growth	Not a stated goal. Policies would not prevent cities from expanding onto farmland^{1, 2}	Stated goal; however, policies would not prevent cities from expanding onto farmland³	Corrections ¹GPI requires a countywide vote if agricultural lands are converted to other uses. City annexations of farmlands are ipso facto conversions, therefore the GPI requirement for a vote would be triggered. ² GPI would use more farmland than GPU4. (see DEIR at Page 5-17) ³ GPU4 requires development of a farmland loss mitigation program. Comment City-Centered Growth is not a stated policy under either plan; it is the subject of a memorandum endorsed by Salinas Valley cities but not the county. GPU4 includes an Agricultural Element, an indication of the importance of agriculture in Monterey County. GPI does not include an Agricultural Element. GPU4 therefore includes policies that protect and enhance agriculture. GPI short-sightedly assumes, with apparent agreement from LWV, that restrictions to preserve farmland are all that is required to promote agricultural viability. All major agricultural groups oppose GPI, a fact LWV does not note in its comparison.
Environmental Impacts	DEIR on GPU4 (p. 5-22) identified CGPI as the Environmentally Superior Alternative of all those considered – GPU3, GPU4, 1982 Plan and CGPI.¹ All alternatives evaluated would avoid or substantially lessen several of the unmitigated significant environmental effects of GPU4 (FEIR, p. 42). DEIR on GPU4 (p. 5-21) identified the following significant impacts: agricultural resources; water resources; aesthetics, light and glare.	The 1/2/07 staff report identified the following significant unavoidable impacts: Loss of important Farmland; conflicts with Williamson Act contracts; agricultural and resource use soil erosion; groundwater overdraft; saltwater intrusion; roadway level of service on County and regional roads; visual character; light and glare; impacts to special status species; degradation in water quality from increased soil erosion; and erosion hazards.²	Corrections ¹ The full quote from DEIR, pg 5-22 is, "Based on this review, the GPI is considered the Environmentally Superior Alternative. However, this alternative does not meet the project objectives accommodating forecasted growth and incorporating public input from all segments of the County population." [emphasis added] In other words, GPI achieves its lower impact by not allowing sufficient development to meet projected growth. Further, DEIR Table 5-4 shows that in all but three categories, the listed 2006 GPU4 impacts are "Less Than Significant," i.e., GPI impacts are merely lower than "Less Than Significant." Moreover, according to the table, of the three "Significant" impact categories for the GPU4, GPI impacts are "Greater" for one, "Same" for one, and "Less" only for one. ² The correct citation is the 1/3/07 report and resolution; it contains Findings and Evidence and Statement of Overriding Considerations and Certification of the Final EIR and adoption of Mitigation Monitoring Plan and are the correct sources for this information; pursuant to the California Environmental Quality Act, the County adopted the evidence and findings of overriding considerations justifying these impacts.
Right to Vote	Requires voter approval for subdivisions in unincorporated areas outside of Community Areas, expansion of Community Area boundaries and change to designation of agricultural lands for development.¹	No provisions for allowing Monterey County voters to vote on subdivisions in unincorporated areas.²	Corrections ¹GPI states that no provision of the General Plan can be changed, amended, or repealed “except by a vote of the People.” (see GPI Section 2 at page 2) GPI only allows the construction of one single family dwelling on lots of record (see GPI Policy 26.1.4 (d) (iii)) and would require voter approval to construct a second home – even on a 500 acre farmland parcel. ²This is an inaccurate and misleading statement. Even though GPU4 does not expressly ‘provide’ for voter approval, voter approval or disapproval is available through initiative or referendum processes under the California Constitution. The Superior Court agreed this statement in ballot arguments was “false and misleading” and ordered it changed.
Initiative/Plan Development	The Initiative is based on the Community General Plan sponsored by 18 non-profit groups. Land use policies were developed at 7 workshops held throughout the county (2 conducted in Spanish) attended by hundreds from the community. Technical consultants developed the Plan based on public initiated policies. The Initiative was developed by representatives from many of the sponsoring groups with assistance from consultants.¹	The Board of Supervisors developed land use policies at 18 public hearings and workshops in Salinas. The County Planning Commission also conducted multiple hearings. Public comments were provided at public hearings and during review of the Plan. Technical staff developed GPU4 based on policies developed at these public meetings and comments submitted through the review process.²	Corrections ¹These representations are false. GPI was written by two out-of-town attorneys, a fact confirmed by LandWatch Executive Director Chris Fitz who stated during a public forum that the initiative was written by Fred Woocher of Santa Monica and Bill Yeates of Fairfield/Sacramento. Some GPI policies are similar to policies in the Community General Plan of 2004 but GPI is not the Community General Plan and should not be confused with it. The identified 18 non-profit groups may support the Initiative but it was not ‘developed’ by them. ²These representations are also false. GPU4 is the product of over 7 years of public workshops and hearings conducted throughout the county by county staff, the LUACs, the Planning Commission and Board of Supervisors. There have been 5 different draft general plans during this time, 3 DEIRs, and independent economic analysis. Thousands of pages of comments by the public and reviewing government agencies were submitted. All of these things were considered in preparing GPU4 - a matter of public record. Comment The public process and the public record leading to development of GPU4 were extensive. No public meetings were ever held on GPI.
Plan Implementation	Policies and program are defined and complete except for development of Chualar and Pajaro Community Area Plans.	Over 60 policies require future implementation. Many problems (e.g., inadequate roadways) are identified but solutions are deferred.	Comment LWV implies it is better to have no plan than a not-yet-executed but specific, and specifically required, plan. GPI makes no provision for needed circulation/traffic improvements. GPU4 requires development of Capital Improvement and Financing Plans (CIFP) and implementing ordinances to accomplish circulation and transportation infrastructure improvements. (see GPU4 Policy C-1.2 a through g and Policies C-1.4 through C-1.11) GPU4 also specifies development restrictions and constraints if the requirements are not met. (see GPU4 Policies C-1.3 and C-1.4)
LWV footnote to Agricultural Land Lost ⁽¹⁾	(1) The DEIR finds, "Given that GPI has a much lower development potential relative to the 2006 General Plan..., it is reasonable to expect that smaller acreages of agricultural lands would be converted to non-agricultural uses..." However, based on the fact that the Initiatives does not have policies with respect to city growth as are proposed in GPU4, "...buildout of GPI would have greater impacts on agricultural resources than the 2006 General Plan." The DEIR does not quantify either the agricultural land converted as the result of development in the 5 community areas proposed under the Initiative or land that would be converted as the result of city growth. None of the policies in the Final GPU4 would prevent cities from expanding on to agricultural land. Additionally, GPU4 states that one of its goals is city-centered growth (Policy LU-2.14) in contrast to the Initiative which only focuses on growth in unincorporated areas. These findings contradict the conclusion in the DEIR. Thus, we find that the actual agricultural land lost under the Initiative would be 600 acres resulting from development within the 5 Community Areas as measured through GIS mapping and 4,900 acres for GPU4 as identified in the DEIR.		Comment The DEIR conclusion that the GPI would have greater impacts on agriculture than the 2006 General Plan did not change in the FEIR. Significantly, neither chapter of the League of Women Voters submitted comments on the DEIR protesting or questioning its conclusion that the GPI would have greater impacts on Agricultural Resources than GPU4. DEIR Table 3-4 shows a 2006 General Plan loss of agricultural land of 1,029 acres, less then one tenth of 1% of agricultural lands. The GPI eliminates opportunities for unincorporated area housing south of Chualar and specifies that Chualar Community Area development is to take place after the other four Community Areas have plans in place. The GPI also states at Section 3.e.5 that the Chualar Community Area is “not essential to meeting the county’s housing needs.” The DEIR/FEIR analysis took into account the fact that GPI policies force needed housing and other growth to take place in the cities, making it likely cities will expand into prime ag land, therefore using more farmland than the 2006 General Plan. Because the GPI does not identify any growth areas south of Chualar, Salinas Valley growth would necessarily be forced into cities, which would have to expand onto prime agricultural land. Development areas designated by the 2006 General Plan are existing developed areas, away from the prime farmlands.