Dr Hogans PEIR Analysis
Dr. Michael Hogan provided the County with a detailed reply to their PEIR report. His full reply can be read here.
Dr. Hogan (an environmental / soils–watershed scientist associated with the Save Tarpy Flats effort) argues that the PEIR cannot treat Tarpy Flats as a viable RHNA opportunity site because the draft does not adequately analyze site-specific constraints. The County itself has said environmental effects of including and rezoning Site 52 would be studied in this PEIR.
- Site 52 sits in a High Fire Hazard Severity Zone next to the airport, Highway 68, vernal pools, and a wildlife corridor. Hogan’s comment treats those as known, site-specific constraints, not issues that can be deferred to a later project EIR—especially with a Builder’s Remedy application already on the land.
- Wildfire and evacuation.
The letter relies on the group’s commissioned work: a KLD wildfire evacuation estimates and a April 22, 2026 wildfire threat analysis by Mr. Hillman. Those studies say existing neighborhoods already face long evacuation times through the Olmsted / Highway 68 choke point, and hundreds of new units would multiply vehicles in a high-hazard zone with limited water for firefighting. - Water, sewer, and soils/watershed function.
The PEIR does not show a real, available water and sewer supply for high-density housing on undeveloped marine-terrace grassland, and that grading and hardscape would impair infiltration, erosion control, and downstream water quality. - Biology and wetlands.
Dr. Hogan points out that Tarpy Flats is a remnant highland grassland / marine terrace with vernal pools and listed or sensitive species (including Yadon’s piperia and other CNPS/CNDDB occurrences). Development would fragment the corridor between Fort Ord National Monument and Jacks Peak. That is presented as a significant, inadequately mitigated PEIR impact. - Traffic and airport interface.
The comment echoes the group’s figure of 5,000+ extra daily trips on Highway 68 (already LOS F) and conflict with airport access at Olmsted Road. - Site inadequacy
The letter’s policy ask is to remove or not rely on Site 52 for RHNA capacity because the PEIR does not demonstrate realistic development capacity, AFFH suitability, or feasible mitigation. Save Tarpy Flats has consistently said the County can meet RHNA on other sites.
Dr. Michael Hogan provided the County with a detailed reply to their PEIR report. His full reply can be read here.
Dr. Hogan (an environmental / soils–watershed scientist associated with the Save Tarpy Flats effort) argues that the PEIR cannot treat Tarpy Flats as a viable RHNA opportunity site because the draft does not adequately analyze site-specific constraints. The County itself has said environmental effects of including and rezoning Site 52 would be studied in this PEIR.
- Site 52 sits in a High Fire Hazard Severity Zone next to the airport, Highway 68, vernal pools, and a wildlife corridor. Hogan’s comment treats those as known, site-specific constraints, not issues that can be deferred to a later project EIR—especially with a Builder’s Remedy application already on the land.
- Wildfire and evacuation.
The letter relies on the group’s commissioned work: a KLD wildfire evacuation estimates and a April 22, 2026 wildfire threat analysis by Mr. Hillman. Those studies say existing neighborhoods already face long evacuation times through the Olmsted / Highway 68 choke point, and hundreds of new units would multiply vehicles in a high-hazard zone with limited water for firefighting. - Water, sewer, and soils/watershed function.
The PEIR does not show a real, available water and sewer supply for high-density housing on undeveloped marine-terrace grassland, and that grading and hardscape would impair infiltration, erosion control, and downstream water quality. - Biology and wetlands.
Dr. Hogan points out that Tarpy Flats is a remnant highland grassland / marine terrace with vernal pools and listed or sensitive species (including Yadon’s piperia and other CNPS/CNDDB occurrences). Development would fragment the corridor between Fort Ord National Monument and Jacks Peak. That is presented as a significant, inadequately mitigated PEIR impact. - Traffic and airport interface.
The comment echoes the group’s figure of 5,000+ extra daily trips on Highway 68 (already LOS F) and conflict with airport access at Olmsted Road. - Site inadequacy
The letter’s policy ask is to remove or not rely on Site 52 for RHNA capacity because the PEIR does not demonstrate realistic development capacity, AFFH suitability, or feasible mitigation. Save Tarpy Flats has consistently said the County can meet RHNA on other sites.
Dr. Michael Hogan provided the County with a detailed reply to their PEIR report. His full reply can be read here.
Dr. Hogan (an environmental / soils–watershed scientist associated with the Save Tarpy Flats effort) argues that the PEIR cannot treat Tarpy Flats as a viable RHNA opportunity site because the draft does not adequately analyze site-specific constraints. The County itself has said environmental effects of including and rezoning Site 52 would be studied in this PEIR.
- Site 52 sits in a High Fire Hazard Severity Zone next to the airport, Highway 68, vernal pools, and a wildlife corridor. Hogan’s comment treats those as known, site-specific constraints, not issues that can be deferred to a later project EIR—especially with a Builder’s Remedy application already on the land.
- Wildfire and evacuation.
The letter relies on the group’s commissioned work: a KLD wildfire evacuation estimates and a April 22, 2026 wildfire threat analysis by Mr. Hillman. Those studies say existing neighborhoods already face long evacuation times through the Olmsted / Highway 68 choke point, and hundreds of new units would multiply vehicles in a high-hazard zone with limited water for firefighting. - Water, sewer, and soils/watershed function.
The PEIR does not show a real, available water and sewer supply for high-density housing on undeveloped marine-terrace grassland, and that grading and hardscape would impair infiltration, erosion control, and downstream water quality. - Biology and wetlands.
Dr. Hogan points out that Tarpy Flats is a remnant highland grassland / marine terrace with vernal pools and listed or sensitive species (including Yadon’s piperia and other CNPS/CNDDB occurrences). Development would fragment the corridor between Fort Ord National Monument and Jacks Peak. That is presented as a significant, inadequately mitigated PEIR impact. - Traffic and airport interface.
The comment echoes the group’s figure of 5,000+ extra daily trips on Highway 68 (already LOS F) and conflict with airport access at Olmsted Road. - Site inadequacy
The letter’s policy ask is to remove or not rely on Site 52 for RHNA capacity because the PEIR does not demonstrate realistic development capacity, AFFH suitability, or feasible mitigation. Save Tarpy Flats has consistently said the County can meet RHNA on other sites.