March 12, 2009
City of Ventura
501 Poli St
Ventura, CA 93001
RE: Embassy Suites Hotel/T J Mian & Associates Mitigated Negative Declaration # 2278
The Surfrider Foundation has reviewed the MND for the proposed development. The project proposes a new four-story hotel to fill the vacant 2.74-acre parcel at the corner of Figueroa and Harbor Blvd. in Ventura.
We are concerned that the MND does not adequately address impacts on coastal resources due to climate change.
Although there is considerable uncertainty regarding the impacts of Climate Change, the State of California has passed AB 32, the Global Warming Solutions Act of 2006 that recognizes the threat of climate change. On March 11, 2009, the Pacific Institute released a report commissioned by the State that addresses potential impacts to the coast of California due to sea level rise as a result of climate change. Using a very conservative 1.4m increase in sea level elevation over the coming century, the study estimates that the cost of building new or upgrading existing coastal structures is estimated to be at least $14 billion (in year 2000 dollars), with an additional $1.4 billion per year in maintenance costs. The UN has predicted even greater and faster sea level rise, so this impact could me much greater.
Permitting such a large development directly on the coast will increase the future need for taxpayer subsidies to protect this property. We suggest that, if this project is approved, a mitigation bank be established to provide funding for coastal maintenance. Tax revenues or a separate coastal mitigation fee should be established for all new commercial development within the future inundation zones of the California coast. Alternatively, the project should be bonded to provide funds for its removal, should that become necessary in the future.
While we recognize the need for re-vitalization of the local economy, we want to ensure that the true cost of coastal development is not passed on to future generations.
A public hearing on this project is scheduled for 6 PM on March 17, at the City Council Chambers at City Hall.
MND-2278 may be downloaded from the city's website here
City Council will be approving the land swap and MND on April 20