CITY COUNCIL: Denise Duffy & Associates, Inc. Errata to RFEIR for Sale of the Flanders Mansion Property

Denise Duffy & Associates, Inc.
PLANNING AND ENVIRONMENTAL CONSULTING
MEMORANDUM
Date: April 23, 2009
To: City of Carmel-by-the-Sea
From: Denise Duffy & Associates, Inc.

To Whom It May Concern:
Please find the attached Errata to the April 2009 Recirculated Final Environmental Impact Report (RFEIR) for the Sale of the Flanders Mansion Property. The attached incorporates revisions to the RFEIR to make corrections and include additional information that was omitted from the RFEIR as follows:

1. Table 2-1 has been corrected to include the text of Mitigation Measure 4.3-2, which was inadvertently left out of the RFEIR. Please note that Mitigation Measure 4.3-2 is still applicable to the proposed project and is included as part of the Mitigation Monitoring and Reporting Program (MMRP). Table 2.1 has also been corrected to include the text related to potential impacts to local traffic. This information was previously included as part of the RDEIR, but was inadvertently left out of the summary table. Other minor revisions and corrections have also been
incorporated as shown on the attached.

2. Revisions have been made to Mitigation Measure 4.3-1 to provide additional detail to ensure the
Preservation Plan is subject to the review and approval of the Historic Resources Board.
Additional detail concerning the timing of this mitigation measure has also been incorporated.
3. Revisions have been made to Mitigation Measure 4.4-1 to provide additional detail to ensure that
potential land use conflicts, such as increased traffic and noise, associated with higher intensity
land uses are avoided.
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ERRATA
REVISIONS TO THE RECIRCULATED FINAL EIR
The following section provides revisions to the text of the Recirculated Final EIR, in amendment form.
The revisions are listed by page number. All additions to the text are presented in underline, and all
deletions are shown in strikeout.
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Page 5-9 of Section 5.0, Table 2-1 is revised as follows:
TABLE 2-1
SUMMARY OF SIGNIFICANT ENVIRONMENTAL IMPACTS AND MITIGATION
Environmental Impact Mitigation Measure Level of Significance
After Mitigation
4.3 Cultural Resources
Sale of the Flanders Mansion and occupancy by
new owners could result in alterations to the
building or site that would diminish the historic
integrity of the resource, changes that would
affect the historic setting of the resource and/or
physically separate it from its surroundings.
4.3-1 The terms of any sale shall be subject to Conditions of Sale requiring recordation
of a deed restriction, which shall run with the land and be binding upon successive
owners, requiring the adherence to a comprehensive Preservation Plan for the
Flanders Mansion consistent with the Secretary’s Standards and the Carmel-bythe-
Sea Municipal Code historic preservation provisions. In general, the
Preservation Plan should shall identify changes to the property that could
reasonably be expected to occur and make recommendations so that the changes
would not disrupt the historic integrity of the resource. The Preservation Plan
shall be prepared by a qualified professional and would provide practical guidance
to the new owners of the Flanders Mansion. Said Preservation Plan shall include:
1) a history of the Flanders Mansion; 2) an assessment of the current condition of
the property (building and grounds) and detailed descriptions of the characterdefining
features; and 3) recommendations following the Secretary’s Standards for
the appropriate treatment of these features. The Preservation Plan shall be
submitted to the City of Carmel-by-the-Sea for review and approval within 12
months of the close of escrow with completion of rehabilitation within 48 months
after City approval. Said plan shall be subject to the review and approval of the
City of Carmel-by-the-Sea Historic Resources Board. Specific standards and
requirements of the plan follow:
A qualified specialist who meets the Secretary of the Interior’s Professional Qualification
Standards should prepare the preservation plan that should shall, at a minimum, include the
following information:
• A detailed history of the Flanders Mansion;
• A discussion of its historical significance (i.e. why the building is listed in the
National Register);
• A comprehensive list of the features of the building that contribute to its
historical significance;
• A detailed description of the current condition of the building and its
integrity relative to the National Register criteria;
• A discussion of the Secretary of the Interior's Standards for the Treatment of
Less-than-significant
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TABLE 2-1
SUMMARY OF SIGNIFICANT ENVIRONMENTAL IMPACTS AND MITIGATION
Environmental Impact Mitigation Measure Level of Significance
After Mitigation
Historic Properties;
• Specific standards and recommendations for the care and treatment of the
Flanders Mansion. These standards in this section of the plan should shall be
based on the identified character-defining features and include relevant
standards outlined by the Secretary of the Interior, and the Secretary’s
guidelines in applying these standards.
It should be noted, that for this project, additional mitigation measures have been
incorporated into the project which require that specific lease terms be implemented or that
Conditions of Sale be recorded with the property that run with the land and mandate that
the structure be maintained in a historic fashion per required standards.
4.3-2 Prior to the sale of the Flanders Mansion, the City of Carmel-by-the-Sea shall
document the Flanders Mansion so that a record of the property as it exists today
is preserved. To accomplish this, the City shall hire a qualified cultural resources
specialist to document the Flanders Mansion (house and grounds) with a
historical narrative and large format photographs in a manner consistent with the
Historic American Buildings Survey (HABS). Copies of the narrative and
photographs shall be distributed to appropriate local repositories (libraries,
planning department) and concerned groups (historical societies, preservation
groups). The preparation of the HABS documentation shall follow standard
National Park Service procedures. There would be three main tasks: gather data;
prepare photographic documentation; and prepare written historic and descriptive
reports. The photographic documentation shall consist of large-format
photography conforming to HABS standards. Photographic documentation shall
include 4-by-5-inch negatives in labeled sleeves, 8-by-10-inch prints mounted on
labeled photo cards, and an index to the photographs. In addition, the
documentation shall include photographic reproduction of any building
blueprints, if available.
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Page 5-10 of Section 5.0, Table 2-1 is revised as follows:
4.4 Land Use
Sale of the Flanders Mansion Property could
result in higher intensity land uses that could be
incompatible with the surrounding Mission
Trail Nature Preserve, Lester Rowntree
Arboretum, and the Hatton Field residential
area.
4.4-1 In order to minimize potential land use conflicts associated with potential future
use of the Flanders Mansion Property, the City of Carmel-by-the-Sea shall require
through conditions of sale, deed restriction, or similar legally-binding mechanism,
that any future use and subsequent sale of the Property be restricted to singlefamily
residential or a low-impact public/quasi-public use those low- intensity
uses that are consistent with the historical use of the property. Future use of the
property that would represent an intensification of use Any future use of the
Flanders Mansion that is inconsistent with the analysis contained in this RDEIR
shall be subject to additional environmental review in accordance with CEQA,
including the provisions of CEQA Guidelines §15162 and §15163, as applicable
and Any intensification of use shall require the preparation of a Traffic Impact
Analysis. , which The traffic analysis shall be provided to the County of Monterey
Public Works Department for review and comment. These restrictions shall run
with the land and shall be legally binding on successor owners/lessees.
Less-than-significant
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Page 5-11 of Section 5.0, Table 2-1 is revised as follows:
4.6 Traffic and Circulation
The sale of the property may result in the loss of
an informal parking area currently used by the
general public to access the Mission Trails
Nature Preserve and the Lester Rowntree
Arboretum. Although not designated as public
parking currently, parking in the lower
driveway area of the Flanders Mansion Property
would be eliminated from public access upon
sale of the property.
4.6-21 In order to ensure that adequate public parking is provided, the City of Carmelby-
the-Sea shall provide additional public parking to facilitate visitor access to
the surrounding Preserve and Arboretum consistent with the policies of the
Mission Trail Nature Preserve Master Plan, prior to the sale of the Flanders
Mansion Property. Prior to the sale of the Flanders Mansion, the City shall
develop a parking plan to provide at least 3 parking spaces along the existing
driveway within the Mission Trail Nature Preserve as demonstrated in Figure 4.6-
2. This site shall be surfaced with appropriate materials such as decomposed
granite, wood chips or similar. Paved surfaces, such as asphalt or similar, shall be
prohibited. Construction of replacement parking shall provide for minimal
disturbance to the natural surroundings and appropriate landscape treatments shall
be provided to minimize views of parking from the Hatton Fields neighborhood.
In the event that grading and/or vegetation-removal activities are required use of
non-impervious materials shall be required. Landscape screening shall also be
provided to minimize visibility from surrounding residences. Native vegetation
screening shall be provided along the area of the parking edge that is within close
proximity to adjacent residences. All disturbed areas shall be replanted with
appropriate native vegetation.
Less-than-significant
The sale of the property may result in future
uses that may cause significant impacts to local
traffic.
4.6-3 See Mitigation Measure 4.4-1. Less-than-significant
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Page 5-18 of Section 5.0, Mitigation Measure 4.4-1 is revised as follows:
4.4-1 In order to minimize potential land use conflicts associated with potential future use of the
Flanders Mansion Property, the City of Carmel-by-the-Sea shall require through conditions of
sale, deed restriction, or similar legally-binding mechanism, that any future use and subsequent
sale of the Property be restricted to single-family residential or a low-impact public/quasi-public
use those low- intensity uses that are consistent with the historical use of the property. Future use
of the property that would represent an intensification of use Any future use of the Flanders
Mansion that is inconsistent with the analysis contained in this RDEIR shall be subject to
additional environmental review in accordance with CEQA, including the provisions of CEQA
Guidelines §15162 and §15163, as applicable and Any intensification of use shall require the
preparation of a Traffic Impact Analysis. , which The traffic analysis shall be provided to the
County of Monterey Public Works Department for review and comment. These restrictions shall
run with the land and shall be legally binding on successor owners/lessees.
Page 5-18 of Section 5.0, Mitigation Measure 4.3-1 is revised as follows:
4.3-1 The terms of any sale shall be subject to Conditions of Sale requiring recordation of a deed
restriction, which shall run with the land and be binding upon successive owners, requiring the
adherence to a comprehensive Preservation Plan for the Flanders Mansion consistent with the
Secretary’s Standards and the Carmel-by-the-Sea Municipal Code historic preservation
provisions. In general, the Preservation Plan should shall identify changes to the property that
could reasonably be expected to occur and make recommendations so that the changes would not
disrupt the historic integrity of the resource. The Preservation Plan shall be prepared by a
qualified professional and would provide practical guidance to the new owners of the Flanders
Mansion. Said Preservation Plan shall include: 1) a history of the Flanders Mansion; 2) an
assessment of the current condition of the property (building and grounds) and detailed
descriptions of the character-defining features; and 3) recommendations following the Secretary’s
Standards for the appropriate treatment of these features. The Preservation Plan shall be
submitted to the City of Carmel-by-the-Sea for review and approval within 12 months of the
close of escrow with completion of rehabilitation within 48 months after City approval. Said plan
shall be subject to the review and approval of the City of Carmel-by-the-Sea Historic Resources
Board. Specific standards and requirements of the plan follow:
A qualified specialist who meets the Secretary of the Interior’s Professional Qualification Standards
should prepare the preservation plan that should shall, at a minimum, include the following information:
• A detailed history of the Flanders Mansion;
• A discussion of its historical significance (i.e. why the building is listed in the National
Register);
• A comprehensive list of the features of the building that contribute to its historical
significance;
• A detailed description of the current condition of the building and its integrity relative to
the National Register criteria;
• A discussion of the Secretary of the Interior's Standards for the Treatment of Historic
Properties;
• Specific standards and recommendations for the care and treatment of the Flanders
Mansion. These standards in this section of the plan should shall be based on the
identified character-defining features and include relevant standards outlined by the
Secretary of the Interior, and the Secretary’s guidelines in applying these standards.
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It should be noted, that for this project, additional mitigation measures have been incorporated into the
project which require that specific lease terms be implemented or that Conditions of Sale be recorded with
the property that run with the land and mandate that the structure be maintained in a historic fashion per
required standards.
Under References, Section 7.0 of the RDEIR, Page 7-1 is revised to include the following references:
Architectural Resources Group, Flanders Mansion Cost Estimate, January 15, 2009
CBRE Consulting, Economic Analysis of the Flanders Mansion Property, February 23, 2009
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SUPPLEMENTAL RESPONSE TO COMMENTS
General Comments: A number of comment letters and commenters at the April 23, 2009 Planning
Commission Hearing identified common concerns or raised similar issues. Generally, these have been
considered and addressed in Section 3.0 Master Response to Comments of the RFEIR. Additional
comments are also identified in this Supplemental Response to Comments document and general
responses provided below.
General Response G1: Additional Response on Alternative Uses
A number of commenters at the Planning Commission hearing directed criticism at the RFEIR because
they felt that the RFEIR did not evaluate an alternative based on various uses for the Project site. Uses
cited included public uses for offices, museum, cultural center, historic foundation center, art center or
other publicly available uses that would allow entrance to the Mansion on a regular basis by members of
the public and thereby increase public enjoyment of the Mansion.
First, the only discretionary action that the City Council is currently considering is whether or not to sell
the Mansion and parcel. The environmental analysis in the RFEIR is more than adequate to enable the
City Council to make an informed decision on this question. The existing environmental analysis presents
an adequate evaluation of the Project’s potential impacts by evaluating reasonably foreseeable impacts of
sale and making assumptions regarding particular impacts to the surrounding property based upon the
divestment in terms of sale of the property. The RFEIR can be used as the document for environmental
review should the City determine to sell the property to another entity who would then use the property
for the various uses contemplated by the commenters.
Because the City is not approving a specific site plan or otherwise committing to allow a specific
development or use on the Project site, the RFEIR’s evaluation of the indirect impacts of sale is adequate
for CEQA purposes. Second, the existing RFEIR already contains sufficient information to consider these
uses as part of the project description and the alternative discussion in Section 6.0 of the RFEIR. Also See
Section 3.0 Master Response to Comments, Master Response 3a, Range of Alternatives and Master
Response 3b, EIR Does not Consider Other Uses Reasonable for the Property under the No Project
Alterative.
General Response G2: Additional Response on Recirculation
Several public comments, including the letters identified as Letter A and I contended that the RDEIR
should be recirculated because significant new information was added to the EIR that deprived the public
of a meaningful opportunity to comment.
The RFEIR incorporates information obtained and produced after the RDEIR was completed, and that it
contains additions, clarification, and modifications. The City Staff and the EIR consultant have reviewed
and considered the information in the Final RFEIR. Neither the Final REIR, nor any of these
modifications, adds significant new information to the RDEIR that would require recirculation of the
RDEIR under CEQA. No information has revealed the existence of (1) a significant new environmental
impact that would result from the project or an adopted mitigation measure; (2) a substantial increase in
the severity of an environmental impact; (3) a feasible project alternative or mitigation measure not
adopted that is considerably different from others analyzed in the RDEIR that would clearly lessen the
significant environmental impacts of the Project; or (4) information that indicates that the public was
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deprived of a meaningful opportunity to review and comment on the RDEIR. Minor changes and
modifications made to the Project description including clarification of the meaning of the objectives and
the project description, and any changes or modifications to the RFEIR after the RDEIR was circulated
for public review and comment do not collectively or individually constitute significant new information
within the meaning of Public Resources Code §21092.1 or CEQA Guidelines §15088.5. This includes
the additional circulation of the economic information provided separately by the City to the public, as
identified in Section 3.0 Master Response to Comments, Master Response 9, Economic Feasibility.
General Response G3: Additional Response on Potential Impacts to Neighborhood, Mission Trails
Nature Preserve and Lester Rowntree Native Plant Garden
A number of comment letters and comments at the Planning Commission hearing stated that the future
sale and/or public use of the Flanders Mansion and property would cause significant traffic, parking or
noise impacts on the surrounding neighborhood. A number of comment letters and comments at the
Planning Commission hearing stated the project would cause significant impacts to the Mission Trail
Nature Preserve and the Lester Rowntree Native Plant Garden. Refer to Section 3.0 Master Response to
Comments, Master Response 4, Single-Family Residential Use Preference and Master Response 5,
Transportation/Traffic regarding impacts to single family residential neighborhood.
Most of the Mission Trail Nature Preserve, including the entire area of the Lester Rowntree Native Plant
Garden, will remain available for public enjoyment and, with the mitigation measures being adopted;
many of the park benefits of the Flanders Mansion property which the public has enjoyed will continue to
be available. Impacts are fully disclosed to the Mission Trails Nature Preserve (MTNP) and the Lester
Rowntree Native Plant Garden. The RDEIR and RFEIR fully disclose these impacts and provide
mitigation measures for them. In response to the comment that the impacts to the Lester Rowntree Native
Plant Garden have not been addressed in the document, the commenter should refer to the discussion of
parkland and the description of the MTNP in the EIR record. The Lester Rowntree Native Plant Garden is
identified as an important component of the MTNP. Impacts to the MTNP, including the Lester Rowntree
Native Plan Garden are evaluated in the RDEIR and mitigation measures are identified. In regard to
specific comments regarding visual impacts to the Lester Rowntree Arboretum, the views from this area
to the Mansion are limited by trees and existing vegetation. As identified in the RFEIR, as the proposed
project will not impact the exterior views of the building, these views will remain intact.
Individual Comments: The following individual comment letters are included at the end of this
document. Letters are coded as A, B, etc and these letter identifiers are shown below, with responses as
indicated.
A1: The commenter contends that the consistency analysis contained in Table 4.4-1 of the RDEIR is
inadequate. As identified in the RDEIR (see page 4.4-7), it is ultimately up to the discretion of the City of
Carmel-by-the-Sea to determine General Plan consistency. CEQA specifically requires that an EIR
evaluate potential conflicts with any land use plan, policy or regulation that was adopted for the purpose
of avoiding or mitigating an environmental impact. The RDEIR identifies that the sale of the Flanders
Mansion would constitute a significant impact due to the permanent loss of parkland and the proposed
project would conflict with several policies intended on avoiding or minimizing impacts to parkland. The
RDEIR correctly identifies that this impact would be potentially significant and unavoidable with the
acknowledgement that only the City can determine General Plan consistency. The analysis in the RDEIR
does not seek to determine General Plan consistency, but rather evaluates the proposed project from the
perspective of potential conflicts with policies intended to avoid an environmental impact.
The comment also contends that the RDEIR erroneously determines that the sale of the project is
consistent with a number of the provisions contained in the General Plan. The comment is factually
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incorrect. The RDEIR clearly states that the project, as mitigated, would be consistent. Again, the analysis
is specific to the project’s potential to conflict with a policy that is adopted to avoid and/or lessen the
extent of an environmental impact. The RDEIR addresses potential project impacts and provides an
evaluation of General Plan consistency of the project. The purpose of the analysis is to identify potential
conflicts with policies intended on avoiding an environmental effect. Mitigation measures proposed in the
RDEIR, as modified in the RFEIR, would avoid and/or reduce potential project affects to a level
considered less-than-significant and therefore would generally be consistent with these measures. . A
determination of consistency with the General Plan is made by the Planning Commission and City
Council as part of the deliberative process for the project; the EIR does not seek to make these
determinations. No further response is required.
A2: The commenter contends that the RFEIR is written to support a pre-selected project. The EIR is
an independent document and is not written in a manner as described by the commenter. The RFEIR
clearly identifies that the proposed project would result in a number of significant and unavoidable
impacts due to the permanent loss of parkland.
B1: Comment acknowledged. No further response necessary.
C1: Comment acknowledged. No further response necessary.
D1: The commenter contends that the RDEIR does not evaluate the possible alternative use of the
mansion as a cultural resource, such as a museum. The RDEIR evaluates a range of uses, including
single-family residential and public/quasi-public use. Please refer to page 3-5 through 3-7 for further
discussion. Also refer to General Response G-1 above
D2: The comment contends that the RDEIR does not address potential uses that may occur as part of
the Flanders Mansion being offered to a public agency as part of the Surplus Land Act. The EIR
Consultant respectively refers the commenter to Section 5.0 Revisions to the Recirculated Draft EIR of
the RFEIR for further discussion. Moreover, future use of the property would be required to comply with
the allowable uses under the site’s existing zoning designation, P-2, and any future conditions of sale. See
General Response G2 above. No further response is necessary.
E1: Comment acknowledged. No further response is necessary.
F1: Comment acknowledged. The comment is referred to decision-makers for further consideration.
No further response is necessary.
G1: Comment acknowledged. The comment is referred to decision-makers for further consideration.
No further response is necessary.
H1: Comment acknowledged. The comments in this letter and comments made by the author at the
Planning Commission hearing of April 23, 2009 are largely consistent with a previous letter received on
the RDEIR. Please refer to the detailed responses to Comment Letter D, contained in Section 4.0
Comments and Responses on the Recirculated DEIR. This comment is also referred to decisionmakers
for further consideration. No further response is necessary.
I1: The comments in this letter and comments made by the author at the Planning Commission
hearing of April 23, 2009 are largely consistent with a previous letter received on the RDEIR. Please refer
to the detailed responses to Comment Letter R, contained in Section 4.0 Comments and Responses on
the Recirculated DEIR. Only specific comments are further addressed in the Supplemental Response to
Comments document, as detailed below.
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The commenter contends that a professional study of the effect of a sale or lease on the Mission Trail
Nature Preserve should be commissioned by the City by an independent park expert. The City is
responsible for the ongoing maintenance and operation of the Mission Trail Nature Preserve and the
Flanders Mansion has been leased to both single-family residential and public/quasi-public uses
intermittently since being acquired by the City. These uses did not significantly affect the ongoing
operation of the Preserve “such that substantial physical deterioration of the facility would occur or be
accelerated.” Mitigation measures have been proposed to ensure that future use of the property would not
result in higher intensity uses occupying the Flanders Mansion (see Mitigation Measure 4.4-1). The
RFEIR has adequately evaluated the potential effects of the proposed project and identified appropriate
mitigation measures that have a direct nexus to project-induced affects. A detailed response to the
comment is contained in Section 4.0 Comments and Responses on the Recirculated DEIR (see
Response R-11 for further discussion).
The comment letter also states that the FREIR and conclusions support the No Project alternative. Per
Section 15126.6(a) of the CEQA Guidelines, an EIR shall describe a range of reasonable alternatives to
the project, or to the location of the project, which would feasibly attain most of the basic objectives of
the project but would avoid or substantially lessen any of the significant impacts of the project. The No
Project alternative would reduce the impacts compared to the proposed project; however, as stated in the
RFEIR it does not effectively meet the project objectives.
The comment letter also states that the FREIR conclusions regarding the significant and unavoidable
impact of the project (sale of the Flanders Mansion) would not be acceptable. Under CEQA, the City
Council must balance the benefits of the project against its unavoidable environmental risks in
determining whether to approve the project. If the benefits of a project outweigh the unavoidable adverse
effects, those effects may be considered “acceptable” (CEQA Guidelines §15093[a]). However, CEQA
requires the City to support, in writing, the specific reasons for considering a project acceptable when
significant impacts are unavoidable. Such reasons must be based on substantial evidence in the EIR or
elsewhere in the administrative record (CEQA Guidelines §15093[b]). The comment is referred to
decision-makers for further consideration. No further response is necessary.
The comment letter also includes a number of comments which were previously submitted on the RDEIR.
A detailed response to these comments can be found in Section 4.0 Comments and Response on the
Recirculated Draft EIR.
J1: Comment acknowledged. The comment is referred to decision-makers for further consideration.
No further response is necessary.
K1: Comment acknowledged. The comments in this letter and comments made by the author at the
Planning Commission hearing of April 23, 2009 are largely consistent with a previous letter received on
the RDEIR. Please refer to the detailed responses to Comment Letter Q, contained in Section 4.0
Comments and Responses on the Recirculated DEIR. The comment is also referred to decisionmakers
for further consideration. No further response is necessary.
L1: Comment acknowledged. The comment is referred to decision-makers for further consideration.
No further response is necessary.
M1: Comment acknowledged. The comment is referred to decision-makers for further consideration.
No further response is necessary.
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N1: The comment raises specific concerns regarding the project objectives associated with the sale of
the Flanders Mansion. A detailed response to the comment is provided in Section 3.0 Master Responses
to Comments, Master Response 1, Definition of Project Objectives and Alternatives and Master
Response 2, Secondary Project Objectives. Please refer to those responses for further discussion.
01: Comment acknowledged. The comments in this letter and comments made by the author at the
Planning Commission hearing of April 23, 2009 are largely consistent with a previous letter received on
the RDEIR. Please refer to the detailed responses to Comment Letter D, contained in Section 4.0
Comments and Responses on the Recirculated DEIR. The comment is referred to decision-makers for
further consideration. No further response is necessary.
P1: Comment acknowledged. The comment is referred to decision-makers for further consideration.
No further response is necessary.
Q1: Comment acknowledged. The comments in this letter and comments made by the author at the
Planning Commission hearing of April 23, 2009 are largely consistent with a previous letter received on
the RDEIR. Please refer to the detailed responses to Comment Letter D, contained in Section 4.0
Comments and Responses on the Recirculated DEIR. The comment is referred to decision-makers for
further consideration. No further response is necessary.
R1: The comment contends that the proposed project conflicts/violates a number of the City’s General
Plan/Coastal Land Use Plan goals, policies and objectives. Please refer to response to Comment C1
above. The comment is referred to decision-makers for further consideration. No further response is
necessary.