CVA Comment on the Draft Environmental Impact Report (DEIR)
for the Mid-Valley Shopping Center Project
The Carmel Valley Association has reviewed the DEIR for the proposed project and has the following comments:
The DEIR finds the project would result in a significant and unavoidable impact:
“Therefore, approval of the project as proposed would result in a significant and unavoidable impact on an historical resource. The alternatives presented in this EIR will be considered by the County Planning Commission, or Board of Supervisors on appeal, in order to consider how to mitigate, if possible, the significant and unavoidable impacts of the proposed project.” (DEIR, p. 5-19)
The DEIR finds that Alternative 2: Design Modifications to Proposed Exterior Alterations in Compliance with the Secretary of the Interior’s Standards would not result in significant impacts on historical resources and would mitigate project impacts:
“Implementation of the design modifications above would ensure the proposed project would be consistent with the Secretary of the Interior’s Standards and would not result in significant impacts associated with historical resources. Submittal of revised plans reflecting these modifications will require review and approval by a qualified architectural historian selected by the County to ensure consistency with the Secretary of the Interior’s Standards.” (DEIR, p. 10-8)
When mitigation measures or alternatives are identified to reduce impacts to less than significant, CEQA requires their adoption. A fundamental mandate of CEQA is that “public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of the project” (PRC Sections 21002, 21081).
The DEIR affirms that the property is eligible for listing on Federal, California and Monterey County historic registers (DEIR, p. 5-16). The significant elements of the Mid-Valley Shopping Center’s architecture are well documented, and its architect, Olof Dahlstrand, is acknowledged as a master with his body of work described in the appendix to the DEIR, Painter Preservation’s Historic Resource Evaluation.
The DEIR’s Alternative 2 meets project objectives by offering a framework for the developer to make repairs and improvements to the Mid-Valley Shopping Center while respecting its key architectural elements. By following this framework, new modifications to the property would avert environmental impacts, offensive alterations already made by the developer would be removed, and the changes would be consistent with the Secretary of the Interior’s standards for historic resources.
The DEIR finds the project inconsistent with the following policies in the 2010 Monterey County General Plan: PS 12-12; PS 12-13 and PS 12-17. It also finds the project inconsistent with the Carmel Valley Master Plan Policy CV-3.13 and potentially inconsistent with Chapter 18.25 of the Monterey County Historic Preservation Ordinance. The DEIR should be revised to find that the project would have a significant impact on the environment, based on these findings.
A copy of the EIR and appendices is available at the Carmel Valley Public Library and at this site:
The EIR draft is open for comment until January 10, 2022. With the EIR in final form, the project is expected to be referred to the County’s Historic Resources Review Board for consideration in February.
