1. NMFS, USFWS and Cal DFG, together with all the environmental groups and some individuals, all stated they believed the project had growth-inducing impacts. Only County staff seem to think otherwise.
2. Staff stated at the Planning Commission hearing that future growth will require future environmental review. That is irrelevant and too late – the concern is that this lot line adjustment and road extension, widening, and paving will make future growth more likely. CEQA requires analysis of growth inducing impacts now, when the actions that make future growth more likely to occur.
3. Staff also stated that induced growth comes from oversized infrastructure, but the road is at the bare minimum size. This has two flaws: first, the currently-sized road presumably could bear additional traffic (staff never says how much), and having extended and widened the road will make it easier to simply widen it in the future. Second, the lot reconfigurations will facilitate development, independent of the road. The applicant has openly claimed the line adjustments are for estate-planning purposes, in other words allowing the parcels to split into separate ownership, greatly facilitating development of individual parcels.
4. The refusal of the landowners to allow the Native American group access to look for culturally-significant sites, including burial grounds, or even to meet with the group off-site, suggests that the best interest of the county in preserving the sites will not be protected. A number of Planning Commissioners expressed their concern about this issue. Representatives of the Amah-Mutsun group told me they were also concerned about growth-inducing impacts, so this is another reason for rejecting the project.
5. Staff analysis recommended approval of the project solely on the basis that it did not violate County policies (in their opinion), but this does not examine whether approval would be in the best interest of the County. There should be a pro-and-con analysis over whether the County is better off with this project.
6. A similar pro-and-con analysis should accompany a discussion of the alternatives to the project. The staff report wholly failed to discuss alternatives, virtually all of which are environmentally superior to the proposed project.
7. Failure to consider cumulative impacts from impervious surfaces and greenhouse gas emissions is a problem in this and other County environmental documents. Staff should be asked to report on whether a programmatic analysis of these issues is appropriate.
8. If approval goes forward, a project condition should be that only people with business on the property should be allowed access (e.g., landowners on