Friday, June 12, 2009

City’s Villas de Carmelo Draft EIR Comment Letter to County

ABSTRACT: On behalf of the City of Carmel-by-the-Sea, Planning & Building Services Manager Sean Conroy submitted a comment letter to the County of Monterey Planning Department on the Villas de Carmelo Draft Environmental Impact Report (DEIR). The letter contains comments regarding Aesthetics, Cultural Resources, Hydrology & Water Quality, Land Use & Planning, Public Services & Recreation, Traffic & Circulation and Alternatives. Interestingly, with regard to Alternatives, Sean Conroy wrote of one alternative which should be evaluated, namely the rezoning of a small parcel containing the historic resource to High Density Residential and leaving the remainder of the site Medium Density Residential as currently zoned. The Villas de Carmelo Draft EIR Comments letter is reproduced in its entirety.

City of Carmel-by-the-Sea
(831) 620-2910 OFFICE
(831) 620-2014 FAX

3 June 2009

County of Monterey Planning Department
C/O Elizabeth Gonzales
168 W. Alisal Street, 2nd Floor
Salinas, CA. 93901

Subject: Villas de Carmelo Draft EIR Comments

Dear Ms. Gonzales:

Thank you for the opportunity to review the Draft EIR for the Villas de Carmelo project. The City supports the rehabilitation of the existing historic buildings on the site, however, there are significant concerns about the impacts of the project on the residents of the City, particularly in the adjacent neighborhoods. I am submitting the attached comments for your review and consideration.

Section 4.1 – Aesthetics
The City concurs with the findings of the EIR that the removal of existing mature vegetation adjacent to Highway 1, and the buildout of the proposed project, is inconsistent with the site’s surroundings bordering a Scenic Highway.

The removal of 213 existing trees, many of which are significant Monterey Pines and Coast Live Oaks is also a significant impact. The Carmel-by-the-Sea City Forester identified at least 156 significant trees on the site in 2007. Mitigation 4.1-1 attempts to address this by requiring a Replanting and Landscaping plan be prepared and approved by the County. This does not adequately address the loss of significant trees, particularly as new landscaping cannot be guaranteed and can take many years to create the canopy that exists currently. A more appropriate mitigation measure would be to require modifications to significantly reduce the number of trees proposed for removal.

The Visual Assessments included in the EIR also seem to overstate the effect that the landscaping will have on the appearance of the proposed project from Highway 1. A more appropriate mitigation would be to require a greater setback along the Highway.

Section 4.5 Cultural Resources
The City concurs with the findings of the EIR that development of the project and the resulting rehabilitation and renovation of the existing structures would cause a substantial, adverse change to a historic structure.

The Draft EIR recommends several mitigation measures that reference the Secretary of the Interior’s Standards for the Treatment of Historic Structures but defers determination of consistency with these standards to a future time. The EIR should include an evaluation of the project, as proposed, with the Secretary’s Standards. It is impossible to determine that all impacts can be mitigated without an analysis of the project using these standards. Below is a list of some of the Secretary’s Standards and potential conflicts with these standards.

2. “The historic character of a property shall be retained and preserved. The removal of historic materials or alternation of features and spaces that characterize a property shall be avoided.”

The character of the property is being drastically altered. The sense of openness, the historic resource’s relationship with its surroundings, and the introduction of several buildings of similar architecture style conflicts with this standard.

3. “Each property shall be recognized as a physical record of its time, place, and use. Changes that create a false sense of historical development, such as adding conjectural features or architectural elements from other buildings, shall not be undertaken.”

While additions and alternations to the historic structure are encouraged to be of similar, yet differentiated in design and materials, proposing several new buildings of similar architectural style creates a false sense of historical development.

6. “Deteriorated historic features shall be repaired rather than replaced. Where the severity of deterioration requires replacement of a distinctive feature, the new feature shall match the old in design, color, texture, and other visual qualities and, where possible, materials. Replacement of missing features shall be substantiated by documentary, physical, and pictorial evidence.”

The project plans propose the removal, relocation and alternation of the fountain, stonewalls, stairways, terracing and stairwells, all of which can be considered character-defining. Page 4.5-26 states that existing safety hazards that are associated with some of these elements would be improved or eliminated. While the City does not disagree, features that require repair and or replacement should be done so in-kind in the same location as currently exist. The project conflicts with this standard.

9. “New additions, exterior alterations, or related new construction shall not destroy historic materials that characterize the property. The new work shall be differentiated from the old and be compatible with the massing, size, scale, and architectural features to protect the historic integrity of the property and its environment.”

As previously stated, additions to the building should be similar in design. However, the new construction proposed should be differentiated to a greater degree from the existing building. The existing historic structure is attributed to two master architects and is an excellent example of the Spanish Eclectic style. To propose several buildings with some similar architectural design features seems to demean the historic resource and the character of the property and conflict with this standard.

Section 4.8 – Hydrology & Water Quality
It would be appropriate to include some discussion of Carmel Bay as an Area of Special Biological Significance (ASBS) in the setting information.

Section 4.9 – Land Use & Planning
The discussion on the regulatory environment should include an indication that the project site is located in the City of Carmel-by-the-Sea’s Sphere of Influence. While the City recently rejected a proposal for annexation, this does not preclude the City from annexing the property in the future. The City’s General Plan polices related to its Sphere of Influence encourage the continuation of existing low intensity development. The proposed project is inconsistent with this policy.

Section 4.12 – Public Services & Recreation
It should be noted that the project site is located in a Very High Fire Hazard Severity Zone as identified by CalFire. A mitigation measure should be included requiring new construction to be consistent with Chapter 7A of the State Building Code.

Section 4.13 – Traffic & Circulation
The City concurs that the project will degrade the Level of Service to an unacceptable level at several locations. The City is particularly concerned with the impacts on Carpenter Street and Valley Way. Does the payment of development fees to TAMC guarantee road improvements in the area of the project? If not, then the payment of fees does not mitigate the actual impacts in the area and additional mitigation measures must be identified.

There is no discussion in the EIR regarding the conditions of the roads themselves. The City is particularly concerned about the impacts the development will have on Valley Way. According to the Carmel City Engineer, Valley Way has no existing base rock, a minimal asphalt surface and shows current signs of numerous potholes in various states of repair. The roadway will likely require patching and about a 2 ½” asphalt concrete overlay due to aging alone. The proposed project will only increase the road deterioration. This should be addressed in the EIR and mitigations identified.

Section 6.0 – alternatives
One alternative that should be evaluated is to rezone a small parcel containing the historic resource to High Density Residential and leaving the remained of the site as currently zoned (Medium Density Residential). This would allow for the adaptive re-use of the historic resource, significantly reduce the number of required tree removals, minimize traffic and other development related impacts, and be more compatible with the surrounding neighborhood.

Thank you for the opportunity to comment on the draft EIR and we look forward to your response to the issues raised. Please let me know if you have any questions.


Sean Conroy
Planning & Building Services Manager

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