SUMMARY: DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE VILLAS DE CARMELO PROJECT (Long Version)

ABSTRACT: For the proposed Villas de Carmelo Project, the POTENTIAL SIGNIFICANT ENVIRONMENTAL EFFECTS include, as follows, from the NOTICE OF AVAILABILITY DRAFT ENVIRONMENTAL IMPACT REPORT (DEIR) VILLAS DE CARMELO:

“The DEIR identifies impacts in the following resource areas that are either less than significant or are significant but can be mitigated to a less than significant level: air quality, biological resources, cultural resources, geology and soils, hydrology, traffic, water quality, land use, noise, public services, recreation, utilities and service systems.”

“The DEIR identifies significant impacts in the following resource areas that can be mitigated, but not necessarily to a less than significant level: aesthetics.”

A SUMMARY of the DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE VILLAS DE CARMELO PROJECT (DEIR) is presented consisting of selected excerpts from the DEIR, including the Environmentally Superior Alternative, the Reduced Density Alternative. The Reduced Density Alternative “consists of reducing development on the project site to avoid or lessen the proposed project’s significant unmitigable visual impacts. The Reduced Project Alternative consists of reducing the project to a residential multi-family development of 37 units from the original 46 condominium units.” As stated in 6.5 ENVIRONMENTALLY SUPERIOR ALTERNATIVE, “Among the alternatives aside from the No Project/No Development Alternative, the Reduced Project alternative would represent the environmentally superior alternative, since it avoids or reduces many of the project’s impacts associated with more intense development on the site. The Reduced Project alternative would allow the proposed project to meet its objectives, while insuring that adverse environmental impacts are reduced to the extent feasible. This alternative would reduce impacts in other impact areas in accordance with the decrease in development. Therefore, after the analysis of potential alternatives to the proposed project, the environmentally superior alternative is considered to be the Reduced Project Alternative.”

As stated in 4.9 LAND USE AND PLANNING “The project’s implementation would include approval of a Carmel Area Land Use Designation Amendment and a Coastal Implementation Plan Zoning Amendment, as highlighted below:"

"Carmel Area Land Use Plan Amendment: Change of land use designation from existing Medium Density Residential to proposed new designation for the area, High Density Residential."

"Coastal Implementation Plan (Zoning Code) Amendment: Rezoning of existing of MDR/2 (Medium Density Residential/2 units per acre to a proposed HDR/12.5 (High Density Residential/12.5 units per acre) zoning designation in the Coastal Zone."

“With the amendments, the project would be generally consistent with applicable land use policies and regulations pertaining to the development of the project site. If approved as it has been proposed, the project does not have the potential to result in conflicts with adopted land uses policies and regulations that are intended to avoid and/or mitigate an adverse environmental impact.”

“As proposed, project development would result in minimal changes in the physical environmental, such that development does not have the potential to conflict with adopted policies intended to avoid and/or mitigate an environmental impact. See Table 4.9-1 for more information regarding the project’s consistency with applicable General Plan and Local Coastal Program policies and regulations pertaining to the development of the project site. As seen in this table, some project elements are inconsistent with General Plan and Local Coastal Program policies, however these inconsistencies would not be in conflict with policies intended to avoid and/or mitigate environmental effects. Therefore, as the proposed project would not conflict with policies intended to avoid and/or mitigate an environmental impact, the impact is considered to be less-than-significant." Table 4.9-1 Project Consistency with Relevant County of Monterey General Plan and Carmel Area Land Use Plan (LUP) Policies is summarized, including “Project Consistent” and “Project Inconsistent” designations.

Note: Public Review and Comment Period: April 17, 2009 through June 5, 2009; Public Comment Instructions are provided.


DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE VILLAS DE CARMELO PROJECT
CARMEL, CALIFORNIA
VOLUME I: DRAFT EIR

Lead Agency:
MONTEREY COUNTY

Prepared by:
DENISE DUFFY & ASSOCIATES, INC.
947 Cass Street, Suite 5
Monterey, CA 93940

April 2009

Public Comment Instructions:

ENVIRONMENTAL IMPACT REPORTS
This Draft EIR has been distributed to responsible and trustee agencies, other affected agencies, surrounding cities, and interested parties, as well as all parties requesting a copy of the Draft EIR in accordance with Public Resources Code 21092(b). The Notice of Completion of the Draft EIR has also been distributed as required by CEQA. During the 45-day public review period, the Draft EIR, including the technical appendices, is available for review at the County of Monterey.

All written comments on the Draft EIR should be addressed to:
County of Monterey
Resource Management Agency – Planning Department
Attn: Mike Novo, Director of Planning
168 West Alisal, 2nd Floor
Salinas, CA 93901

We welcome your comments during the 45-day public review period. You may submit your comments in hard copy to the name and address above. The Department also accepts comments via e-mail or facsimile but requests you follow these instructions to ensure that the Department has received your comments.

To submit your comments by e-mail, please send a complete document including all attachments to:

ceqacomments@co.monterey.ca.us

An e-mailed document should contain the name of the person or entity submitting the comments and contact information such as a phone number, mailing address and/or e-mail address and include any and all attachments referenced in the e-mail. To ensure a complete and accurate record, we request that you also provide a follow-up hard copy to the name and address listed above. If you do not wish to send a follow-up hard copy, then please send a second e-mail requesting confirmation of receipt of comments with enough information to confirm that the entire document was received. If you do not receive e-mail confirmation of comments, then please submit a hard copy of your comments to ensure inclusion in the environmental record or contact the Department to ensure the Department has received your comments.

Facsimile (fax) copies will be accepted with a cover page describing the extent (e.g. number of pages) being transmitted. A faxed document must contain a signature and all attachments referenced therein. Faxed documents should be sent to the contact noted above at (831) 757-9516. To ensure a complete and accurate record, we request that you also provide a follow-up hard copy to the name and address listed above. If you do not wish to send a follow-up hard copy, then please contact the Department to confirm that the entire document was received.

Upon completion of the 45-day public review period, written responses to all significant environmental issues raised will be addressed in the Final EIR. The Final EIR will be made available for review at least 10 days prior to the public hearing before the final decision-making body, at which time the certification of the Final EIR will be considered. These environmental comments and their responses will be included as part of the environmental record for consideration by decision-makes for the project.

2.0 SUMMARY

2.1 INTRODUCTION

This summary provides a brief description of the proposed project, project alternatives, and the significant impacts identified during the environmental analysis. Responsibility for implementation of mitigation measures is with the project applicant, unless otherwise noted. This summary is intended as an overview and should be used in conjunction with a thorough review of the DEIR. The text of this DEIR, including figures, tables, and appendices, serves as the basis for this summary.

2.2 SUMMARY OF PROJECT DESCRIPTION

The Villas de Carmelo project would be located at 24945 Valley Way on a 3.68-acre site in the unincorporated Coastal Zone of Monterey County bordered by the city of Carmel-by-the-Sea (See Figure 3-2, Vicinity Map). The project site is located roughly 90 miles south of San Francisco. The project site is bounded to the southwest by Valley Way and to the east by State Route 1 (Highway 1) and southeast by a private drive leading to a four-building apartment complex. Single-family homes are located on the northern and northwestern borders of the property.

Full implementation of the Villas de Carmelo project would introduce a new residential village community consisting of 46 condominium units with a mix of market rate and affordable housing. New housing would include 33 market rate condominiums, 9 affordable housing units, and 4 workforce housing units. The proposed project would create a residential village on the 3.68-acre project site with the existing hospital structure as the focal point of the project. Implementation of the project would involve a standard subdivision to convert 10,350 square feet of the existing hospital structure into 9 condominium units and construction of 37 additional condominium units in 10 to-be-constructed buildings, for a total of 46 condominium units. The project would include common residential village space for underground and surface parking, a recreation room, and storage facilities. The project entitlements will include, but not be limited to, Local Coastal Plan Designation Amendment, Zoning Amendment, Coastal Development Permit, Housing Element Amendment, Tentative Subdivision Map, and Development Agreement approval to allow for the proposed development. A full project description is provided in Section 3.0 of this DEIR.

2.3 ALTERNATIVES EVALUATED IN THIS DEIR

CEQA Guidelines require that an EIR describe and evaluate a range of project alternatives that could eliminate significant adverse project impacts or reduce them to a less-than-significant level. The alternatives to the proposed project that are analyzed in the Draft EIR are summarized below. The Alternatives Section in the Draft EIR fully describes the alternative and discusses whether the alternative meets the identified project objectives.

In compliance with CEQA, this Draft EIR evaluates the comparative advantages and disadvantages of the following five alternatives:

􀂃 No Project
􀂃 Alternative Land Use – Visitor Serving Development
􀂃 Existing Zoning Project Alternative
􀂃 Applicant’s Modified Design Project Alternative
􀂃 Higher Percentage Low Income Project Alternative

Reduced Density: The Reduced Density Alternative consists of reducing development on the project site to avoid or lessen the proposed project’s significant unmitigable visual impacts. The Reduced Project Alternative consists of reducing the project to a residential multi-family development of 37 units.

2.4 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
CEQA requires that an environmentally superior alternative to the proposed project be specified, if one is identified. In general, the environmentally superior alternative is supposed to minimize adverse impacts to the project site and surrounding environment while achieving the basic objectives of the project. The "No Project" alternative could be considered the environmentally superior alternative because all adverse impacts associated with project construction and operation would be avoided. However, CEQA Guidelines section 15126.6(e)(2) states: “If the environmentally superior alternative is the “no project” alternative, the DEIR shall also identify an environmentally superior alternative among the other alternatives.

Based on the analysis in the alternatives discussion, several design changes could reduce the environmental impacts of the project as proposed. The Alternative Land Use – Visitor Serving Development Alternative would involve the construction of a hotel facility on the project site. This Alternative would have similar impacts as the proposed project in all areas aside from its significant increase to traffic in the project site’s vicinity. This Alternative would also be inconsistent with the surrounding land use of the project site and would not meet a primary project objective of the establishment of a residential community on the project site. The Modified Design alternative would avoid the significant unavoidable impact associated with the development of buildings within the Highway 1 scenic corridor that would adversely impact this scenic resource, however would result in impacts similar to the project as proposed. The Existing Zoning Alternative consists of developing the project site with residential uses as proposed, but under the existing zoning for the site of MDR/2. This Alternative would avoid the unmitigable impact of the proposed project to a scenic resource. However, this Alternative would not be capable of meeting the majority of the project objectives, including a principal project objective of the adaptive re-use of a historic building and the establishment of a residential community on the project site. The Increased Percentage of Low and Moderate Income Units Alternative would increase the amount of low and moderate income units amongst the residential units proposed for construction on the project site; however, would otherwise result in the same impacts as the proposed project. The Reduced Project Alternative would not only avoid the unmitigable impact upon a scenic resource by reducing construction within the Highway 1 viewshed but would also reduce impacts in most other areas by decreasing the development density and building footprint on the project site.

Therefore, the environmentally superior alternative would be the Reduced Project Alternative since this alternative would reduce impacts in most areas by decreasing the development densities and footprint on the project site. For further discussion of alternatives to the proposed project see Section 6-0 Alternatives.

Table 2.5-1
Summary of Significant Environmental Impacts and Mitigation
Environmental Impact----Mitigation-----Level of Significance After Mitigation

Includes all “Significant and Unavoidable” Level of Significance After Mitigation, i.e., not including Less than Significant Level of Significance After Mitigation

1. Environmental Impact: The project would result in the removal of existing mature vegetation adjacent to Highway 1 to accommodate buildout of the project site into a residential condominium complex. Existing vegetation, particularly mature pine and oak trees, located west of Highway 1 is considered a scenic resource that is an important component of the visual integrity of the Highway 1 corridor. Removal of vegetation and construction of two buildings of the overall complex as close as 30 feet from the highway would impact views from Highway 1 looking west towards the project site.

Mitigation: 4.1-1 See mitigation regarding potential impacts to a Scenic Vista.

4.1-2 See mitigation regarding potential impacts to a Scenic Vista.

4.1-3 In order to assure that impacts to a scenic resource, the Highway 1 corridor, are minimized, the two buildings housing Units 1-8 located adjacent to Highway 1 on the proposed project site plan shall be constructed with a maximum elevation of 28 feet. This maximum elevation shall be uniform for both of the buildings and shall be recorded on the project’s final map, subject to approval by the County of Monterey.

4.1-4 In order to assure that impacts to scenic resources as viewed from the Highway 1 corridor are minimized, the project applicant/developer shall ensure that at no time shall any development, including project signage, parking, or construction-related activities, be permitted within the 10' property-line setback. All existing mature trees within the 10' setback shall be retained to the extent possible consistent with mitigation measures 4.1-1 and 4.1-2. This measure shall be recorded on the project’s final map, subject to approval by the County of Monterey

3.5 PROJECT CHARACTERISTICS – VILLAS DE CARMELO PROJECT

Land Use: The project site is currently designated as Medium Density Residential (MDR) and zoned for Medium Density Residential, 2 units per acre in a design overlay district in the Coastal Zone (MDR/2- D(CZ)). (See Figure 3-5, Land Use Zoning Map). Existing zoning allows 2 units per acre. Development of the proposed project requires amendment of the Carmel Area Land Use Plan/Local Coastal Program to: 1) include HDR designation and 2) amend the land use designation on the project site from existing Medium Density Residential to proposed High Density Residential. The project also proposes rezoning from the existing designation of MDR/2 (Medium Density Residential/2 units per acre) to proposed HDR/12.5 (High Density Residential/12.5 units per acre) in the Coastal Zone.

In order to develop the site at the density proposed, a new zoning designation is required for the Carmel Area Land Use Plan. The County has provided a description of the proposed zoning language for the proposed zoning district (High Density Residential Zoning District “HDR (CZ)”. A summary of the text is provided below.

High Density Residential (HDR): High Density Residential areas are appropriate for a broad range of higher intensity residential uses (5-20 units/acre) and a blend of housing types. Recreational, public/quasi-public, and other uses are incidental and subordinate to the residential use and character of the area. High density use is allowed in accordance with the site-specific evaluation of resource and public facility constraints, and where urban services - i.e., public water, sewer, roads, public transit, fire protection - are available. New development in these areas
is designated at densities to allow a mix of housing types, including moderate to low income housing, in order to facilitate a comprehensively planned project. Direct access from Highway One shall not be allowed where alternative access is possible.

The project would also require an amendment to the Carmel Area Coastal Implementation Plan (CIP) to add the zoning designation category of High Density Residential District to the CIP. The full text of the proposed land use plan amendment is presented in the Land Use Section of this DEIR.

3.6 REQUIRED PERMITS AND APPROVALS
This Draft EIR is an informational document for both agency decision-makers and the public. Monterey County is the lead agency responsible for certification of the Final EIR and approval of potential future project permits. The following is a listing of permits and approvals under the County and other jurisdictions that would be required for the proposed project’s implementation.

Monterey County• Certification of the EIR and Adoption of Mitigation Monitoring Program;
• Amendment of the Carmel Area Land Use Plan/Local Coastal Program including new and amended policies to incorporate the High Density Residential land use designation and tree removal;

• Amendment of the Coastal Implementation Plan to add the zoning designation of “High Density"

Residential/12.5” within the project area;

• Modification to Inclusionary Ordinance #04185 pursuant to Section 18.40.050B2 for approval of all onsite inclusionary housing units of the proposed project to be designated as moderate income level housing;

• Approval of Site Plan and Design Review;

• Tentative Subdivision Map Review and Approval consistent with the proposed design and zoning standards;

• Approval of Final Maps and Improvement Plans; and

• Review and approval of all required permits that include, but are not limited to, tree removal, building, grading, encroachment, and occupancy permits.

Agencies
• California Coastal Commission – Certification of Amendment to the Carmel Area Land Use Plan/Local Coastal Program

• Monterey Peninsula Water Management District – Water Release Form

• Carmel Area Wastewater District – Utility Connections.

• Regional Water Quality Control Board – NPDES Permit.

• Caltrans – Encroachment Permits for abandonment of access, infrastructure improvements, landscaping, etc.

• Other agencies with permit or review authority over some aspect of the project include the Monterey Regional Waste Management District, Monterey Regional Water Pollution Control Agency, Monterey Bay Unified Air Pollution Control District, Carmel Unified School District, and the California Department of Fish & Game.

+Impacts and Mitigation (Includes only “significant and unavoidable impacts,” i.e., not including potentially significant impacts that can be reduced to a less-than-significant level with implementation of mitigation measures.), as follows:

4.1 AESTHETICS
Impacts and Mitigation

Scenic Vista
Impact Development of the proposed project would result in the removal of existing trees and alteration of the natural landscaping of the project site, resulting in a potential impact to a scenic vista. This would represent a potentially significant impact that can be reduced to a less-than-significant level with implementation of the following mitigation measures.

Scenic Resources
Impact The project would result in the removal of existing mature vegetation adjacent to Highway 1 to accommodate buildout of the project site into a residential condominium complex. Existing vegetation, particularly mature pine and oak trees, located west of Highway 1 is considered a scenic resource that is an important component of the visual integrity of the Highway 1 corridor. Removal of vegetation
and the construction of two buildings would impact views from Highway 1 looking west towards the project site. To the extent that buildout of the proposed project would be inconsistent with its surrounding area bordering a scenic highway, this represents a significant and unavoidable impact.

Visual Characteristics
Impact: Development of the proposed project would result in the rehabilitation and adaptive reuse of the existing hospital structure and garage/shop building and construction of 10 additional detached buildings on the project site, to accommodate a total of 46 condominium units. The proposed project would include common space for underground and surface parking, a recreation room, gym, and storage facilities. The project would thus alter the existing visual character of the site through the introduction of new urban features. This would represent a potentially significant impact that can be reduced to a less-than-significant level with implementation of the following mitigation measures.

Light and Glare
Impact The project would create a new source of light or glare that would adversely affect day or nighttime views in the area. This would represent a potentially significant impact that can be reduced to a less-than significant level with implementation of the following mitigation measures.

Cumulative Impacts
Localized Area:
Therefore, the proposed project would not contribute cumulative change in the visual quality to the localized Carmel Land Use Planning Area.

Highway 1 Corridor – County wide:
Considering the level of development potential in the Highway 1 corridor area within the Carmel Land Use Planning Area, the potential mitigating impacts of the planning documents for the Carmel Land Use Planning Area and mitigation provided within this Draft EIR, the proposed project would have a less-than-significant cumulative impact on aesthetics resources within the Highway 1 corridor.

4.2 AGRICULTURAL RESOURCES
Impacts and Mitigation
The project would have no impact on agricultural resources.

Cumulative Impacts
The project would not have a cumulative impact on agricultural resources.

4.3 AIR QUALITY

Impacts and Mitigation
Construction Period Impacts –PM10 from Fugitive Dust
Impact Construction activities, including clearing, excavation, and grading operations, construction vehicle traffic on unpaved ground, and wind blowing over exposed ground would generate dust and particulate matter emissions that may exceed MBUAPCD thresholds. This is a significant impact that can be reduced to a less-than-significant level with the following mitigation measures.

Construction Period Impacts –Diesel Exhaust from Equipment
Impact Construction activities would involve use of the heavy-duty off-road equipment and large trucks that would generate diesel exhaust, compounds of which may result in unacceptable health risks to nearby sensitive receptors. This is a significant impact that can be reduced to a less-than-significant level with implementation of the following mitigation.

Operational Impacts
Since build-out of the proposed project would not result in emissions of CO, PM10, NOx, or VOCs that exceed MBUAPCD thresholds, the impact is considered less-than-significant.

Local Carbon Monoxide Concentrations
The proposed project would have less-than-significant impact on sensitive receptors near impacted roadways and intersections. As a result, the impacts related to local carbon monoxide concentrations are considered less-than-significant.

Project Stationary Sources
The project would not result in impacts associated with stationary source emissions.

Construction Nuisances and Odors
Impact Construction activities would involve earthmoving, use of the heavy-duty off-road equipment and large trucks that would generate diesel exhaust, volatile organic compounds, and particulate matter emissions that may result in unacceptable nuisances or odors to nearby sensitive receptors. This is a significant impact that can be reduced to a less-than-significant level with implementation of mitigation measures 4.3-1, 4.3-2, and 4.3.3.

Operational Nuisances and Odors
The project would not create a significant operational odor impact. The project would not generate or be subject to significant odor impacts.

Cumulative Impacts: Regional Ozone and Consistency with the AQMP
The project would not result in a significant cumulative impact on regional air quality.

Cumulative Impacts: CO Hotspots
The CO local concentrations will remain below applicable ambient air quality standards; therefore, the project would not result in significant cumulative CO concentration impacts.

Cumulative Impacts: Greenhouse Gas and Global Climate Change
Given the project’s low GHG emissions compared to even the most conservatively low suggested numeric thresholds, the proposed Villas de Carmelo Project would not make a considerable contribution to the significant cumulative impact of global climate change. The project would not conflict with any proposed climate change policies in the Draft 2007 General Plan Update for the County and would be consistent with that plan and its EIR analysis. The project would not hinder or delay California’s ability to meet the reduction targets contained in AB 32. For these reasons, the project would have a less-than-significant impact on global climate change.

4.4 BIOLOGICAL RESOURCES

Impacts and Mitigations
Impacts to Vegetation
Impact The proposed project would represent temporary and permanent impacts to on-site vegetation, and will result in the removal of 3 or more Monterey pine and/or Coast live oak trees. Temporary impacts to vegetation include grubbing and grading associated with development of the site; permanent impacts include the placement of structures, roads, driveways, etc. This is a less-than-significant impact with implementation of the following measures.

Impacts to Special Status Plant Species
Impact The proposed construction of 46 new residences at the Carmel Convalescent Home site will remove 104 of 125 on-site trees >12 inches diameter at DBH (21 coast live oak, 75 Monterey pines, and eight miscellaneous species). The removal of native trees for development is subject to the policies contained within the Carmel Area LUP and CIP. Requirements for replacement are 1:1 for each native tree 12 inches DBH or larger that is removed.

Removal of 52 of 87 on-site trees between 6-11 inches diameter at DBH (30 Coast live oak, 8 Monterey pine, and 14 “others” (horticultural species including olive, acacia, pittosporum, cedar, etc.) will further degrade the site from a wildlife habitat perspective. Although the Carmel Area LUP does not require mitigation for native tree removals less than 12 inches DBH, removal of these trees will further degrade the site from a wildlife habitat perspective. These represent potentially significant impacts that can be reduced to a less-than-significant level with implementation of the following mitigation measures.

Impacts to Special Status Wildlife Species
Impact The project would require grading, excavation, tree limbing and removal, and other activities that may result in the loss or abandonment of on-site raptor nests and/or other native/migratory bird species nests. This would represent a potentially significant impact that can be reduced to a less-than-significant level with implementation of the following mitigation measures.

Impact The project would require tree limbing and removal and modification of on-site buildings that may result in direct take of special status bats and/or bat roosting habitat. Bats and their roosts are protected under CDFG code and provided planning consideration under CEQA for any special status species. Impacts to special status bats and/or maternity roosts would represent a potentially significant impact that can be reduced to a less-than-significant level with implementation of the following mitigation measures.

Impact The project proposes placement of new light sources throughout the site (see Conceptual Lighting Plan in Aesthetics section). New light sources may further reduce on-site habitat quality for any wildlife utilizing the site, including special status bats and raptors. Artificial light disrupts the natural habits of many indigenous wildlife species. The addition of artificial lights may represent a potentially significant impact to special status wildlife species that can be reduced to a less-than-significant level with implementation of the following mitigation measures.

Impacts to Sensitive Habitats
Therefore, impacts related to biological policy consistency are considered less-than-significant.

Conflict with the Provisions of an Adopted Habitat Conservation Plan
The project does not represent a conflict with the provisions of an adopted HCP.

Cumulative Impacts
Mitigation provided herein would ensure that this project’s contribution to any cumulative impacts are not cumulatively considerable, and therefore, are considered to be less-than-significant.

4.5 CULTURAL RESOURCES
Impacts and Mitigation

Historic Resources
Impact Development of the project and the resulting rehabilitation and renovation of the two historic resources on the project site would cause a substantial, adverse change to a historical structure eligible for listing in the California Register on the site. This represents a potentially significant impact that can be reduced to a less-than-significant level with implementation of the following mitigation measure.

Archaeological and Unidentified Cultural Resources
Impact Construction of the project may result in the discovery and disturbance of unknown archaeological resources and/or human remains. This represents a potentially significant impact that can be reduced to a less-than-significant level with implementation of the following mitigation measure.

Paleontological Resources
Impact Construction of the project may result in the discovery and disturbance of unknown, unique paleontological resources. This represents a potentially significant impact that can be reduced to a less-than-significant level with implementation of Mitigation Measure 4.5-9.

Cumulative Impacts
Therefore, the project would have less-than-significant cumulative impacts on cultural resources.

4.6 GEOLOGY, SOILS, AND MINERAL RESOURCES
Impacts and Mitigation

Seismic Hazards
Impact The project would be exposed to potential adverse effects from strong seismic ground shaking that may result in damage to proposed structures. This would represent a potentially significant impact that can be reduced to a less-than-significant level with implementation of the following mitigation measures.

Grading and Soil Erosion
Impact The hospital building may be adversely affected by the grading on the project site. This would represent a potentially significant impact that can be reduced to a less-than-significant level with implementation of the following mitigation measures.

Liquefaction
Therefore, there would be no impact from liquefaction.

Landslides, Debris Flow, and Lateral Spreading
Therefore, there would be no impact from landslides, debris flow, or lateral spreading.

Expansive Soil
Therefore, the project would have no impact on expansive soils.

Mineral Resources
There would be no impact to mineral resources.

Cumulative Impacts
Soil and Seismic-Related Hazards
Therefore, the proposed project would not make a considerable contribution to any cumulative soil and seismic-related hazard impact.

Erosion
Therefore, the proposed project would not make a considerable contribution to any cumulative soil erosion impact.

4.7 HAZARDS AND HAZARDOUS MATERIALS
Impacts and Mitigation

Exposure to Existing Hazards
Impact Development of the proposed project, including site grading, excavation, demolition, and other land-disturbing activities, may result in the exposure of construction personnel and site occupants to health and safety risks. This represents a significant impact that would be reduced to a less-than-significant level with the following mitigation measures.

Accidental Hazard Protection
However, with the implementation of mitigation measures 4.7-1 through 4.7-6, the impacts would be reduced to a less-than-significant level.

Hazardous Material Use
Therefore, impacts relating to hazardous materials use are considered less-than-significant, and no mitigation measures are required.

Airport Hazards
The project would have no airport-related hazardous impacts.

School Hazards
As such, there are no hazard-related school impacts.

Cumulative Impacts
The cumulative impacts associated with hazards and hazardous materials would be less-than-significant.

4.8 HYDROLOGY AND WATER QUALITY
Impacts and Mitigation

Surface Drainage/Flooding
Impact The proposed project has the potential to increase stormwater run-off from the project site. This would represent a potentially significant impact that can be reduced to a less-than-significant level with implementation of the following mitigation measure.

Water Quality and Stormwater Management
Impact Construction and operation of the proposed project could result in an impact to surface water quality. This is potentially a significant impact that would be reduced to a less-than-significant level with the following mitigation.

Cumulative Impacts
The project would therefore have a less-than-significant cumulative impact on hydrology and water quality.

4.9 LAND USE AND PLANNING
Introduction
The following section analyzes the project’s land use effects, specifically its consistency with applicable plans and zoning ordinances, including the Monterey County General Plan, Carmel Area Land Use Plan (LUP), Monterey County Coastal Implementation Plan, and other relevant planning documents.

Setting
The project’s implementation would include approval of a Carmel Area Land Use Designation Amendment and a Coastal Implementation Plan Zoning Amendment, as highlighted below:

Carmel Area Land Use Plan Amendment: Change of land use designation from existing Medium Density Residential to proposed new designation for the area, High Density Residential.

Coastal Implementation Plan (Zoning Code) Amendment: Rezoning of existing of MDR/2 (Medium Density Residential/2 units per acre to a proposed HDR/12.5 (High Density Residential/12.5 units per acre) zoning designation in the Coastal Zone.

Impacts and Mitigation
Physically Divide an Established Community
Therefore, the proposed project would not physically divide an existing established community.

Conflict with Any Applicable Land Use Plan, Policy, or Regulation
Consistency with Carmel Area Land Use Plan /Local Coastal Program
Consistency with County of Monterey Housing Element
Consistency with County of Monterey Inclusionary Housing Ordinance

Conclusion

Project development proposes amendments to the Local Coastal Plan (Carmel Area Land Use Plan), Carmel Area Coastal Implementation Plan (Part 4), and Part 1 of the Coastal Implementation Plan (Title 20 Zoning Ordinance), as discussed above. With the amendments, the project would be generally consistent with applicable land use policies and regulations pertaining to the development of the project site. If approved as it has been proposed, the project does not have the potential to result in conflicts with adopted land uses policies and regulations that are intended to avoid and/or mitigate an adverse environmental impact.

Pursuant to CEQA, a significant environmental effect must involve an adverse change in the existing physical condition of the site. As proposed, project development would result in minimal changes in the physical environmental, such that development does not have the potential to conflict with adopted policies intended to avoid and/or mitigate an environmental impact. See Table 4.9-1 for more information regarding the project’s consistency with applicable General Plan and Local Coastal Program policies and regulations pertaining to the development of the project site. As seen in this table, some project elements are inconsistent with General Plan and Local Coastal Program policies, however these inconsistencies would not be in conflict with policies intended to avoid and/or mitigate environmental effects. Therefore, as the proposed project would not conflict with policies intended to avoid and/or mitigate an environmental impact, the impact is considered to be less-than-significant.

Conflict with Any Applicable Habitat or Natural Community Conservation Plan
The project would not adversely impact any habitat or natural community conservation plans.

Cumulative Impacts
Therefore, implementation of the proposed project would have a less-than-significant cumulative impact upon land use planning.

Table 4.9-1
Project Consistency with Relevant County of Monterey General Plan and Carmel Area Land Use Plan (LUP) Policies
Policy Number---Policy Summary---Consistency

GENERAL PLAN / AREA PLAN (LUP) – Visual Resources
26.1.8 Development in scenic road and highway corridors shall be governed by policies located in the transportation section of this General Plan.

Project inconsistent. The proposed project would result in a significant and unavoidable impact to a scenic corridor as discussed in Section 4.1 Aesthetics. Mitigation measures identified in Section 4.1 Aesthetics shall assist in reducing the project’s impacts upon the scenic highway corridor.

GENERAL PLAN / AREA PLAN (LUP) – Air Quality
Project consistent.

GENERAL PLAN / AREA PLAN (LUP) – Biology
Project consistent.

GENERAL PLAN / AREA PLAN (LUP) – Cultural Resources
Project consistent.

GENERAL PLAN / AREA PLAN (LUP) – Geology & Soils
Project consistent.

GENERAL PLAN / AREA PLAN (LUP) –Hydrology & Water Quality
Project consistent.

GENERAL PLAN / AREA PLAN (LUP)– Land Use
26.1.6 Development which preserves and enhances the County's scenic qualities shall be encouraged.

Project inconsistent. Consideration of potential significant impacts to the County’s scenic qualities from the proposed project has been included with mitigation measures in Section 4.1 Aesthetics.

27.1.3 Residential development should be concentrated in growth areas.

Project inconsistent. While the proposed project would be infill of a primarily abandoned lot located within a residential neighborhood, the Carmel area is not considered to be an area of future growth within Monterey County.

27.2.1 Residential areas shall be located with convenient access to employment, shopping, recreation, and transportation. High density residential areas should also be located with convenient access to public transit.

Project inconsistent. Although the proposed project would establish residents within convenient access to employment, shopping, recreation, and transportation, the nearest Monterey Salinas Transit bus station is located greater than 0.5 miles southwest of the project site at the intersection of 6th Avenue and Mission Street in the City of Carmel-by-the-Sea, which is not considered convenient access to public transit by various rating systems.

4.4.3.D.2 (LUP) Medium-density residential development shall be directed to existing residential areas where urban services -- water, sewers, roads, public transit, fire protection, etc. – are available. The density for new subdivision is two units per acre except for the Portola Corporation property in Carmel Meadows. As a condition of development, covenants must be recorded acknowledging agricultural use on the adjacent parcel and holding the owner (State) harmless for any nuisance due to the agricultural use.

Project inconsistent. The Carmel Area Land Use Plan / Local Coastal Program does not distinguish the project’s proposed rezoning to allow high density residential zoning on the project site. The project also proposes a density of 12.5 units per acre. However, the proposed project would be within an existing residential area where urban services exist and area available. Additionally, approval of the proposed project would allow for high density residential zoning in the Carmel Area Land Use Plan.

GENERAL PLAN / AREA PLAN (LUP)– Noise
Project consistent.

GENERAL PLAN / AREA PLAN (LUP)– Population & Housing
27.1.3 Residential growth should be concentrated in growth areas.

Project inconsistent. While the proposed project would be infill of a primarily abandoned lot located within a residential neighborhood, the Carmel area is not considered to be an area of future growth within Monterey County.

27.2.1 Residential areas shall be located with convenient access to employment, shopping, recreation, and transportation. High density residential areas should also be located with convenient access to public transport.

Project inconsistent. Although the proposed project would establish residents within convenient access to employment, shopping, recreation, and transportation, the nearest Monterey Salinas Transit bus station is located 0.62 miles southwest of the project site at the intersection of 6th Avenue and Mission Street in the City of Carmel-by-the-Sea, which by most standards would not be considered convenient access to public transit.

GENERAL PLAN / AREA PLAN (LUP)- Public Services
Project consistent.

GENERAL PLAN / AREA PLAN (LUP)– Traffic & Circulation
37.2.1 Transportation demands of proposed development shall not exceed an acceptable level of service for existing transportation facilities, unless appropriate increases in capacities are provided for.

Project inconsistent. Implementation of the proposed project would exceed acceptable levels of service for surrounding existing transportation facilities. Mitigations measures are provided in Section 4.13 Traffic & Circulation.

GENERAL PLAN / AREA PLAN (LUP) – Utilities
Project consistent.

4.10 NOISE
Impacts and Mitigation

Noise and Land Use Compatibility
Exterior Noise Exposure
This represents an impact that would be reduced to a less-than-significant level with mitigation incorporated.

Interior Noise Exposure:
Impact Residential uses developed at portions of the project site would be exposed to
exterior noise levels exceeding the “normally acceptable” noise and land use compatibility standards presented in the County’s General Plan for multiple-family residential land uses. Interior noise levels would exceed acceptable levels at portions of the project site without the incorporation of noise insulation features into the project’s design. This represents a potentially significant impact that can be reduced to a less-than-significant level with implementation of the following mitigation measures.

Construction Noise
Impact Noise generated by construction activities would temporarily increase noise levels at adjacent residential land uses. This represents a potentially significant impact that can be reduced to a less-than-significant level with implementation of the following mitigation measures.

Project-Generated Traffic Noise
Therefore, the project would have less-than-significant impacts from project generated traffic noise.

Groundborne Vibration
Therefore, the project would have less-than-significant impacts related to groundborne vibration.

Aircraft Noise
Therefore, the project would have less-than-significant aircraft noise impacts.

Cumulative Noise Impacts
Cumulative Construction Noise Impacts
Therefore, the proposed project would not make a considerable contribution to a cumulative noise impact.

Therefore, the proposed project would not result in a considerable contribution to a cumulative noise impact.

Cumulative Traffic Noise Increase
Therefore, the project would have less-than-significant impacts due to cumulative traffic noise increases.

4.11 POPULATION AND HOUSING
Impacts and Mitigation
Displacement
The project would have no impact on displacement of housing.

Population Growth
This impact is considered less-than-significant and no mitigation is necessary.

Affordable Housing
This impact is considered less-than-significant, and no mitigation is necessary. Application of County conditions of approval for compliance with the Inclusionary Housing Ordinance will be required as discussed above.

Cumulative Impacts
Therefore, the proposed project would not contribute to the cumulative change in the population projections of the surrounding area.

4.12 PUBLIC SERVICES AND RECREATION
Impacts and Mitigation
Police
This represents a less-than-significant impact, and no mitigation measures are necessary.

Fire
This represents a less-than-significant impact, and no mitigation measures are necessary.

Schools
Impact The project would result in an increased demand for educational services. This would represent a potentially significant impact that can be reduced to a less-than-significant level with implementation of the following mitigation measure.

Parks and Recreation
This represents a less-than-significant impact, and no mitigation measures are necessary.

Cumulative Impacts
Although the incremental demands on public services associated with projected regional development represents a potentially significant cumulative impact, the project as proposed would have a less-than-significant impact upon any of these services, therefore, the project’s contribution to any cumulative significant impacts is not cumulatively considerable and therefore less-than-significant.

4.13 TRAFFIC AND CIRCULATION
Impacts and Mitigation

Increase in Traffic Load
Impact The proposed project would add an estimated 269 total daily trips to the local street system and Highway 1, which have been identified as deficient in LOS standards. This is a potentially significant impact that can be reduced to a less-than-significant level with the following mitigation measure.

Project Access and Circulation
Impact The project has the potential to result in unsafe conditions for immediate driveway access to Highway 1. This is a potentially significant impact that can be reduced to a less-than-significant level with the following mitigation measure.

Construction Related Traffic
Impact The project would result in increased traffic loads in the project vicinity due to construction related traffic. This would represent a potentially significant impact that can be reduced to a less-than-significant level with implementation of the following mitigation measure.

Indirect Traffic Impacts
Therefore, indirect traffic impacts would be considered less-than-significant.

Cumulative Impacts
Impact All of the study intersections and road segments would contribute an increase to the total trips generated by all cumulative projects, resulting in unacceptable LOS ratings for one study intersection and one road segment under cumulative plus project conditions. These are significant impacts that can be reduced to a less-than-significant impacts with the following mitigation measure.

4.14 UTILITIES AND SERVICE SYSTEMS
Impacts and Mitigation

Water Supply
Impact The proposed project will be using an incremental amount of water compared to existing conditions at the time of the initiation of the EIR for this project, specifically water from the Cal-Am system that have not been accessed in the recent past. This incremental increase in water demand in comparison to current conditions has the potential to impact water supply. This would represent a potentially significant impact that can be reduced to a less-than-significant level with application of existing rules and regulations of the MPWMD, Monterey County Code and implementation of the following mitigation measure.

Water System Distribution
Implementation of the proposed project would therefore represent a less-than-significant impact on the existing water system infrastructure.

Wastewater
Based on the anticipated wastewater flow associated with the proposed project per CAWD factors, 100 gallons per day per capita and 3.15 residents per unit which would result in an increase in wastewater generation as 14,490 GPD or 0.01 MGD, wastewater treatment of the Carmel Area Wastewater District would not be significantly impacted by buildout of the proposed project.

Solid Waste
The project would result in a less-than-significant impact on solid waste disposal systems.

Electricity and Natural Gas
According to the CEC, approximately 20% of greenhouse gas emissions are associated with the energy sector in California. As a result, increased energy demands associated with the construction and operation of the proposed project would contribute toward climate change. However, as identified in Section 4.3 Air Quality, the project’s contribution towards climate change is considered incremental, and thus not significant.

Cumulative Impacts
Given the shortage of water supply in the Carmel River system, the buildout of the Area Plan would result in an unavoidable significant cumulative impact until adequate water becomes available. However, buildout in this planning area is currently constrained in accordance with policies and programs and regulations of the Monterey County General Plan, the Carmel Area Land Use Plan, as well as MPWMD regulations.

5.0 CEQA Considerations

5.3 SIGNIFICANT UNAVOIDABLE IMPACTS

The proposed project would result in significant impacts in the following categories, as described in this Draft EIR: aesthetics, air quality, biological resources, cultural resources, geology, hazards, hydrology, noise, public services, and traffic. All project impacts can be reduced to a less-than-significant level with implementation of mitigation identified in this Draft EIR, with the exception of the following:

􀂃 A significant unavoidable impact due to development in the Highway 1 viewshed which would impact a scenic resource.

6.0 Alternatives

6.2 SUMMARY OF PROJECT OBJECTIVES AND SIGNIFICANT IMPACTS

Proposed Project Characteristics

The proposed project includes a subdivision and a combined development permit to allow the construction of 46 residential units on a 3.68-acre site. The following are project components:

• a local coastal plan amendment to change land use designation from medium density residential to high density residential;

• rezoning from MDR/2 to HDR/12.5 in the coastal zone;

• a coastal development permit and standard subdivision to convert a 10,350-square foot former convalescent hospital site into nine condominium units and develop 37 additional condominium units for a total of 46 units;

• a coastal administrative permit to demolish one existing structure and construct 12 buildings for a total of 46 condominium units;

• a coast development permit to allow development on slopes of 30% or greater and removal of approximately 97 trees over 12” in diameter (21 Coast Live Oak, 76 Monterey Pines); and

• design approval.

Objectives

The primary objectives of the project, as described in 3.0 Project Description of this Draft EIR and as identified by the applicant, are as follows:

• Rehabilitate and preserve a historic community institution;

• Establish a high quality residential village community to house future residents within the County;

• Provide market rate, affordable, and work force housing stock to the Monterey Peninsula with 20% designated as affordable and workforce housing; and

• Reuse vacated buildings on a site with infill development.

Significant Impacts
The proposed project would result in potentially significant impacts in the following categories, as described in this Draft EIR: aesthetics, air quality, biological resources, cultural resources, geology, hazards, hydrology, noise, public services, population/housing, traffic, and utilities. All project impacts can be reduced to a less-than-significant level with implementation of mitigation identified in this Draft EIR, with the exception of the following:

􀂃 A significant unavoidable project impact upon aesthetics, associated with the proposed project’s impact upon a scenic resource (Highway 1).

6.4 ANALYSIS OF ALTERNATIVES SELECTED FOR FURTHER REVIEW

The following section discusses the alternatives evaluated in this Draft EIR and the comparative environmental effects of each. The alternatives considered in this analysis are as follows:

􀂃 No Project
􀂃 Alternative Land Use- Visitor Serving Development
􀂃 Existing Zoning Project Alternative
􀂃 Applicant’s Modified Design Project Alternative
􀂃 Reduced Density Project Alternative
􀂃 Increased Percentage of Low and Moderate Income Units Project Alternative

The alternatives chosen for this analysis, beyond those mandated by CEQA, were developed to avoid or substantially reduce the significant impacts of the project.

6.4.1 No Project

Summary
Although the No Project Alternative that would opt to leave the project site undeveloped and would avoid the extent of the environmental impacts of the proposed project, this alternative would fail to meet any of the project objectives, including the adaptive reuse of a historic structure. Rehabilitation of the project site for use as a convalescent hospital would involve minor environmental impacts; however, would reintroduce vehicle trips and water usage that have been essentially dormant since the closing of the convalescent hospital. Further, this option of the No Project Alternative would fail to meet the applicant’s project objectives to develop a residential community on the project site which would include affordable housing.

6.4.2 Alternative Land Use – Visitor Serving Development

Summary
A visitor-serving commercial development on the project site would be inconsistent with planning documents. Residential development, such as the proposed project, is generally considered a preferred land use for an area surrounded by residential properties or an infill site. It is assumed that the Visitor Serving Alternative would provide similar square footage of development as compared to the proposed project.

Under the Visitor Serving Alternative, the primary project objectives of the project would not be met. This alternative would conflict with the applicant’s project objectives to develop a residential community on the project site which would include affordable housing.

6.4.3 Existing Zoning Project

Summary

The Existing Zoning Alternative would lessen the overall impacts of the development by reducing the area of development and reducing the residential units from 46 units to 7 units allowed under the existing land use plan. This Alternative would avoid the proposed project’s significant unavoidable impact upon a scenic resource.

Under the Existing Zoning Alternative, the primary objectives of the proposed project would not be met. This Alternative would conflict with the Applicant’s project objectives to develop a larger residential community on the site, including affordable housing, and could also conflict with the goal of rehabilitation of the existing historic buildings on the site.

6.4.4 Applicant’s Modified Design Project

Summary
This Alternative would avoid the project’s significant impact upon a scenic resource by removing two large buildings of the proposed project’s design from within the public viewshed of Highway 1. This project may also reduce impacts to hydrology and water quality depending on design. Impacts related to traffic and demands on public services would be equal when compared to the proposed project. Due to its similar development intensity, this Alternative would otherwise result in environmental impacts comparable to the proposed project. This Alternative would be consistent with the Applicant’s objectives to rehabilitate and preserve a historic building, establish the residential community and provide market rate, affordable and work force housing stock, as well as meet the objective of reuse of vacated buildings on a site with infill development.

6.4.5 Reduced Density Project

Description
This Alternative consists of reducing the number of units on the project site in order to avoid or lessen the majority of the proposed project’s impacts. The Reduced Project Alternative consists of reducing the project to a residential multi-family development of 37 units. As a component of the Reduced Project Alternative, 26 units would be designated as market rate units, 3 units would be designated as affordable to Moderate-income units, 3 units would be designated as Low-income units, and 3 units would be designated as Very Low-income units, per Monterey County’s Inclusionary Housing Ordinance.

This Alternative: 1) reduces four of the units in the area proposed for Units 1-8 along Highway 1, 2) reconfigures the site plan in order to provide a landscape berm along Highway 1 as well as parking and landscaping in the area of the project site where proposed Units 1-8 are currently located, and 3) eliminates three units in the area of Units 24-28 in order to address neighborhood concerns regarding viewshed along Valley Way, as well as Unit 23 and Unit 32 in order to further reduce the impacts from density of development and construction on areas exceeding 30% slope.

Impacts
Aesthetics. This Alternative would avoid the project’s significant unavoidable impact to a scenic resource by lessening development within the majority of the area of the Highway l corridor viewshed. This Alternative also includes less overall development, which would in turn reduce the visual effects of the project. Implementation of this Alternative would result in retention of more trees on the project site and offer the opportunity for increased set back and landscaping on the project site’s border with Highway 1. The effects from new light and glare sources would be less than under the proposed project particularly on the east side of the project site where the existing eight units of low-income housing are currently located in project site plans (Units 1-8). The impacts of this Alternative on aesthetics would be less than those of the proposed project.

Air Quality. Based on URBEMIS modeling conducted for this Alternative, the Reduced Project Alternative would result a slight reduction of impacts from the generation of emissions from the creation of 37 residential units in comparison to the 46 units of the proposed project. Construction emissions will be reduced from those estimated for the proposed project given the reduction of 9 units and the correlated reduction of grading activities and construction. The Reduced Project Alternative would result in reduced mobile source emissions including PM10, ozone precursors, and GHGs due to the reduced vehicle trip generation. Implementation of mitigation measures recommended for the proposed project would also reduce the level of air quality impacts associated with this alternative. Under both scenarios, air quality impacts would be less-than-significant.

Biological Resources. This Alternative would reduce the proposed project’s impacts to biological resources, including trees, because of its reduced footprint. Under the Reduced Project Alternative, the development footprint would be reduced to allow the construction of 37 residential units compared to the 46 units described for the proposed project. As such, the biological impacts identified under the proposed project would be reduced. Depending on design, impacts associated with tree removal and effects to sensitive species would be reduced. Mitigation measures recommended for the proposed project would also reduce the biological impacts associated with this alternative to a less-than-significant level. The impacts of the Reduced Project Alternative to biological resources would be less than those of the proposed project.

Cultural Resources. Because of its reduced grading, this Alternative could reduce potential impacts to undiscovered cultural resources. The impacts of the Reduced Project Alternative to cultural resources would be less than those of the proposed project in the area of archaeological impacts. In relation to the historical buildings on the site, the impacts under this alternative could be similar if this alternative also includes full rehabilitation of the existing historic buildings through the development of the site.

Geology/Soils. Under the Reduced Project Alternative, development would be decreased, which would decrease overall grading on the site by reducing the size of the overall development. Short-term construction impacts associated with the potential for erosion, accelerated runoff, and sedimentation are expected to be less than those anticipated for the proposed project given that the project area that would be affected by grading activities during construction would be decreased. Additionally, this project alternative would remove Unit 32 from the original site plan, which would greatly reduce the percentage of site development on areas exceeding 30% slope. Implementation of mitigation recommended for the proposed project would also reduce the levels of impacts associated with this alternative. The site would be subject to the same soil, geologic, and seismic hazards for both the proposed project and this alternative. Under the Reduced Project Alternative, impacts associated with seismicity and soil stability would likewise be similar to the proposed project. With mitigation and reduction of development on areas exceeding 30% slope, impacts related to geology and soils under this alternative would be less than those of the proposed project.

Hazards and Hazardous Materials. Demolition activities associated with construction of the Reduced Project Alternative would be slightly reduced in comparison to the proposed project. However, there is still the possibility of potential impacts associated with undiscovered contamination, risks to underground utilities, hazardous materials involvement, asbestos and lead-based paint exposure, and the demolition of buildings. Implementation of mitigation recommended for the proposed project would also reduce the levels of impacts associated with this alternative. The impacts related to hazardous materials from the Reduced Project Alternative may be somewhat less than those of the proposed project.

Hydrology/Water Quality. This Alternative would reduce impervious surfaces compared to the proposed project. Short-term construction impacts to water quality associated with the potential for erosion and sediment discharge into the storm drainage system would be less than the proposed project. This Alternative would be required to provide onsite drainage facilities and implement BMPs to avoid significant water quality impacts. The hydrology and water quality impacts of this alternative would be somewhat less than those of the proposed project.

Land Use. This Alternative would not be consistent with County and Coastal land use planning documents and land use designations to provide medium density residential on the site at MDR/2. This Alternative is considered more consistent with specific policies in the Coastal Plan for the site, although less development is included than envisioned by the project objectives and the project would remain inconsistent with the type of development surrounding the project site. Ultimate consistency with policies would be dependent upon future residence design and layout.

Noise. Construction noise impacts from this Alternative would be reduced in accordance with the decrease in site development and traffic generated by the project and due to the increased area from residences located immediately adjacent to the northwest portion of the project site and construction activities. During project operations, traffic noise impacts along nearby streets would be reduced from the generation of fewer vehicle trips. This would reduce the cumulative noise effects of the project. This Alternative would presumably slightly reduce the construction schedule, lessening impacts to the sensitive receptors of the residential community adjacent to the site. The noise impacts of the Reduced Project Alternative would be less than those of the proposed project.

Public Services & Utilities. This Alternative would reduce the overall demand on services and utilities by decreasing the amount of development on the project site from 46 units to 37 units. The water demand of this Alternative is estimated to be 5.697 AF/Y (5.55 AFY for the 37 units + 0.147 AFY for the gym) based upon MPWMD residential water use factors. This estimated demand is 1.17 AFY/Y less than that of the proposed project. This Alternative would reduce the demand on police and fire services, parks, water, sanitary sewer, and solid waste disposal services, as well as energy. The public services and utilities impacts of the Reduced Project Alternative would therefore be less than those of the proposed project.

Traffic. The Reduced Project Alternative is expected to reduce the 269 total daily trips estimated for the proposed project by up to twenty percent. This would reduce traffic impacts at some of the studied intersections and roadway sections, but will not avoid traffic impacts reported for the proposed project on the intersections and roadway segments analyzed. This is also true for the regional cumulative impacts. For both the proposed project and this Alternative, local traffic impacts would be mitigable to less-thansignificant levels. The traffic impacts of the Reduced Project Alternative would be less than those of the proposed project.

Summary
The Reduced Project Alternative would lessen the overall impacts of the development by reducing the area of development and reducing the residential units from 46 units to 37 units. This Alternative would still require a land use plan amendment. The Reduced Density Alternative would avoid the project’s significant unavoidable impact on a scenic resource as project development within the Highway 1 corridor viewshed would be reduced. Under the Reduced Project Alternative, some but not all of the project objectives of the proposed project would be met. This Alternative would conflict with the Applicant’s project objectives to develop a larger residential community on the site. This Alternative would be consistent with the Applicant’s objectives to rehabilitate and preserve a historic building, establish the residential community and provide market rate, affordable, and work force housing stock, as well as meet the objective of reuse of vacated buildings on a site with infill development.

6.4.6 Increased Percentage of Low and Moderate Income Units

Summary

Due to its similar development intensity, this Alternative would otherwise result in environmental impacts equal to the proposed project for the impacts cited. The increase in affordable housing provided under this Alternative is the only difference in terms of project components and impacts when compared to the proposed project.

This Alternative would be consistent with the Applicant’s objectives to rehabilitate and preserve a historic building, establish the residential community, and reuse the vacated buildings on a site with infill development. However, this Alternative would not fully meet the applicant’s objectives of provision of market rate housing in the residential housing mix requested by the proposed project.

6.5 ENVIRONMENTALLY SUPERIOR ALTERNATIVE

CEQA requires that an environmentally superior alternative to the proposed project be specified, if one is identified. In general, the environmentally superior alternative is supposed to minimize adverse impacts to the project site and surrounding environment while achieving the basic objectives of the project. The No Project/No Development alternative could be considered the environmentally superior alternative because all adverse impacts associated with project construction and operation would be avoided. However, CEQA Guidelines section 15126.6(e)(2) states: “If the environmentally superior alternative is the “no project” alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives.

Based on the analysis in the alternatives discussion, several design changes could reduce the environmental impacts of the project as proposed.

The Alternative Land Use – Visitor Serving Development Alternative would involve the construction of a hotel facility on the project site. This Alternative would have similar impacts as the proposed project in all areas aside from its significant increase to traffic in the project site’s vicinity. This Alternative would also be inconsistent with the surrounding land use of the project site and would not meet a primary project objective of the establishment of a residential community on the project site.

The Existing Zoning Alternative consists of developing the project site with residential uses as proposed, but under the existing zoning for the site of MDR/2. This Alternative would avoid the unmitigable impact of the proposed project to a scenic resource. However, this Alternative would not be capable of meeting the majority of the project objectives, including a principal project objective of the adaptive re-use of a historic building and the establishment of a residential
community on the project site.

The Modified Design alternative would avoid the significant unavoidable impact associated with the development of buildings within the Highway 1 scenic corridor that would adversely impact this scenic resource. This design alternative would otherwise result in impacts similar to the project as proposed and would meet the applicant’s project objectives of the adaptive re-use of a historic building and to develop a residential community on the project site.

The Reduced Project Alternative would not only avoid the unmitigable impact upon a scenic resource by reducing construction within the Highway 1 viewshed but would also reduce impacts in most other areas by decreasing the development density and building footprint on the project site.

The Increased Percentage of Low and Moderate Income Units Alternative would increase the amount of low and moderate income units amongst the residential units proposed for construction on the project site; however, would otherwise result in the same impacts as the proposed project.

A comparison of the impacts of each alternative relative to the proposed project is presented in Table 6.4-1. Among the alternatives aside from the No Project/No Development Alternative, the Reduced Project alternative would represent the environmentally superior alternative, since it avoids or reduces many of the project’s impacts associated with more intense development on the site. The Reduced Project alternative would allow the proposed project to meet its objectives, while insuring that adverse environmental impacts are reduced to the extent feasible. This alternative would reduce impacts in other impact areas in accordance with the decrease in development. Therefore, after the analysis of potential alternatives to the proposed project, the environmentally superior alternative is considered to be the Reduced Project Alternative.

ADDENDUM:
DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE VILLAS DE CARMELO PROJECT
CARMEL, CALIFORNIA
VOLUME I: DRAFT EIR

DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE VILLAS DE CARMELO PROJECT
CARMEL, CALIFORNIA
VOLUME II: APPENDICES

NOTICE OF AVAILABILITY
DRAFT ENVIRONMENTAL IMPACT REPORT (DEIR)
VILLAS DE CARMELO

CARMEL AREA LAND USE PLAN
LOCAL COASTAL PROGRAM
CERTIFIED APRIL 14, 1983
MONTEREY COUNTY, CALIFORNIA