CEQA EIR Required? Hydrology and Water Quality


a) Violate any water quality standards or waste discharge requirements?

b) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)?



Carmel Highlands Onsite Wastewater Study-min


“I . . . highlight the water and septic issues as there is a body of evidence showing environmental concerns under the current land use provisions and “infer” that the addition of STR’s at the level of occupancy being considered will exacerbate an already existing environmental problem. My evidence is in the County’s own documents like the Carmel Highlands Wastewater Management Plan (http://www.co.monterey.ca.us/home/showdocument?id=14904 ) and the CalAm decision of record not to permit new water connections in the Highlands. These environmental impacts have to be based on the assumption of increased occupancy and infrastructure stress, or at least, temporary occupancy beyond the limit of existing infrastructure capacity. I think that the Hwy 1 / Carmel Valley Road traffic issues could also follow the same rationale.

In the Carmel Highlands, there has always been a fairly high number of non-resident property ownership. It has ranged between 20% – 30% over the years with most of these properties having historically been either very occasionally or seasonally used vacation properties for their owners. Therefore, for most of the year these properties used to sit vacant and did not have substantial impacts on the environment or local infrastructure. These are the very properties that we now see being utilized as illegal vacation rentals – therefore, causing a higher level of use than existed before with the consequent increased level of environmental impacts. . .

The County is using generally accepted HUD Fair Housing Guidelines to inform their two persons per bedroom occupancy standards for the STR ordinance. These are not firm limitations and HUD has decided on many occasions to allow/enforce higher occupancy limits to redress what they determine to be illegal discrimination. One of the few arguments that can be successfully employed to limit occupancy is the lack of basic infrastructure capacity (water, sewer, etc.).

[Editor note: In the Home Stay the owner and his family live there.  Any vacation/short-term renters will be an additional use.  Also the demographic evidence is 3 persons per home avaerage.  Renters would be in addition to that.  It should also be noted that Monterey residents were particularly good at conserving water, especially during the drought.  Tourists from other areas use significantly more water on average.]

The Carmel Highlands community is completely surrounded by Federal, State and local parks plus natural preserve/protected areas including a number of ocean reserves. I’ve put forward additional anecdotal arguments for increased environmental impacts based on reported behaviors of STR tenants and the lack of adequate supervision and enforcement abilities in these sensitive habitat areas in and around the Carmel Highlands. Again, other communities would need to evaluate whether they have similar concerns.. . .  For example, we have observed tenants collecting specimens from tide pools and other onshore/nearshore habitats, climbing down and damaging hazardous and environmentally sensitive cliffs, starting campfires in illegal locations and trespassing onto private property that contain sensitive habitats and cultural artifacts.”