| 1. Project Description |
The project description as presented in the Notice Of Preparation (NOP) dated 4/27/98 from the San Mateo County Planning and Building Division describes the project as:
| "Construction of thirty-five single-family detached residential lots and homes on individual lots with full suburban infrastructure of roads, storm drains, water, sewer, electricity, gas and communications." |
It is also noted that in the Request For Proposal (RFP) on this EIR that the County issued on 12/15/97, it states on page 2:
| "It is the intention of the owners that a 15-acre portion of the project site parcel located west and a 16-acre portion located east of the project site would remain undeveloped." |
In addition, the Initial Study from EIP Associates, included as Exhibit A of the NOP, refers to the following as part of their project description:
| "It is also the intent of the owners/applicants that a 15 acre parcel located west of the project site (oceanfront parcel as shown on Figure 3), and the 16 acre parcel located east of the project site remain undeveloped. These 15 and 16 acre parcels are also owned by the owners/applicants, and are proposed by the owners/applicants for dedication as permanent open space." |
The description continues to note that the project is not consistent with the General Plan, current zoning, or LCP buildout planning, and as so would require:
It has also been noted by community members that the plan is contrary to LCP Policy 1.5 (a) & (b) which reads:
1.5 Land Uses and Development Densities in Urban Areas a. Incorporate the adopted Montara-Moss Beach-El Granada Community Plan into the land use plan for the Mid-Coast, but amend it where necessary to meet Local Coastal Plan objectives. b. Permit in urban areas land uses designated on the Land Use Plan Maps and conditional uses at densities specified in tables 1.2 and 1.3. |
These policies essentially adopt the "Community Park/Public Recreation" designation for the subject property, and allow the low density level consistent with RM/CZ lands.
We should also consider the history of this particular project proposal: It was the result of negotiation in the "El Granada Waterfront Task Force" process that resulted in the owners/applicants bringing this project to the county. The Task Force was supported and partially funded by the county government, had active participation from the County Planning department, and designated representatives from the MidCoast Community Council and the Harbor District. The dedication of the two parcels mentioned above was integral to the agreed-upon proposal for the 35 housing units.
Concern has been expressed at the public scoping sessions and the work meetings for this document as to the mechanisms and/or guarantees concerning the dedication of the two parcels for open space. Is the dedication contingent on approval of the housing proposal? Would they be dedicated anyway? In what form and to what receiving agency?
In light of this history and these descriptions and unanswered questions, and the unprecedented changes to the General Plan, zoning, and LCP buildout numbers, the EIR should include, as part of the project description, consideration of the two other parcels (the "West Parcel" area between Highway 1 and the Ocean and the "Hammerhead" parcel east of the proposed housing development) in various potential arrangements of private or public ownership depending on the alternatives studied. It is important that these lands be included in the overall project consideration for reasons described above and in the sections to follow; and that they be looked at in more than cursory manner for regarding all areas of potential impacts.
| 1.1. Need for More Detailed Project-Specific Information |
A complete project description is essential for defining impacts and possible mitigation. Projects impacts such as Land Use compatibility, geology, fiscal, infrastructure, traffic, water & air, visual, biological, construction, etc. cannot be fully assessed with the project definitions and plans currently provided.
As these would be important for consideration of even a single unit project, it is all the more essential here, where an entirely new, unplanned-for neighborhood and re-designation of large, undeveloped parcels are being proposed within an existing community plan structure. At best, an estimation of possible impacts and mitigations could be assembled, but project specific issues critical to the surrounding communities could not be properly addressed. Many factors of construction, design and intent need to be clarified before this process could be completed, including but not limited to:
a. Subdivision details: Lot sizes, street width, utility layout and implementation, grading, landscaping, pavement materials (streets and sidewalks, if any), connection and intersection with existing infrastructure, traffic flow (both internal and access and egress to surrounding areas), parking (on-street, garaged, driveways, etc.), recreation areas (playlots, parks, rec. centers, etc.), project perimeter designs (gates, fences, berms; landscape and construction elements that integrate or separate the project from the surrounding community), projected utility usage beyond housing units (street lighting, public area water usage, etc.), utility installation (underground? poles?), overall project parameters such as use or alteration of existing topography and natural habitat, and overall project orientation (integrated neighborhood, gated community, etc.) including orientation to what surrounds it: Highway and ocean to the West, El Granada to the East, Miramar to the South and the school to the North.
b. House design/construction and proposed PUD guidelines: lot coverage, sq. footage, setbacks, heights, design standards, size of decks, utility interface, foundation design, construction types (materials restrictions, prefab, mobile homes, ?) variance and variety in design, parking requirements, garages, driveways, storage units, landscaping, etc.
c. Clarification of the proposed open space donations: The implications and details of the dedication of the West Parcel and the Hammerhead to public open space need to be fully defined - are they tied to the project, or are they entirely separate? Are they outright donations or easements? The aspects of the change of use of these parcels will need to be considered in each of the sections regarding housing, visitor-serving facilities, public access, maintenance and operation, receivership, and other community impacts (traffic, infrastructure, housing numbers, etc..)
| 1.2 Consideration of Other Planning Processes |
It would also be important that this project be considered in the light of other ongoing planning and evaluation process within the MidCoast area, so that planners and EIR consultants on this and other projects are fully aware of plans that might affect each other. This would include, but are not limited to:
a. City of Half Moon Bay Land Use revision process, and efforts to consider down-zoning to implement a better jobs/housing balance and implement C/CAG Transportation Plan policy.
b. Fiscal Analysis - MidCoast Incorporation/Annexation Study (see Appendix D)
c. Airport Master Plan Revision (flight patterns and sound envelopes that could affect proposed housing)
d. ABAG Coastal Corridor Planning Project
e. C/CAG Traffic Congestion Management Studies (see Appendix C)
f. Caltrans proposed Highway 1 improvement work.
g. CCWD water distribution upgrade project (which runs right through this residential parcel)
h. Other large building projects with significant impacts, including but not limited to:
1. Moss Beach Highlands project (for high density housing about 4 miles north of this site)
2. Proposed Shorebird Hotel and approved Harbor Village project at Pillar Point Harbor.
3. Two proposed hotels and approx. 200 new homes in Half Moon Bay along Highway 1 between this site and Rte. 92 intersection.
At the present time, we have only been provided with a preliminary project plan - See Appendix A, A-1 - and so will have to base our comments and observations on that. We request that the County and EIP forward any and all further project details to the MCC P&Z Committee as soon as they become available.
We have been assured, and expect to see in the Draft EIR, that in cases where sufficient details for review have not been provided that EIP will adopt a "worst-case" scenario for evaluation.