Monterey County Planning Commission, and

General Plan Update Team

Monday, October 7, 2002

Since Monterey County was formed, some 150 years ago, it has failed to solve or even alleviate, many serious problems including --

• Traffic Jams and Delays
• Water Availability without environmental harm
• Species extirpation and extinction
• Forest habitat loss
• Affordable Housing
• Parking
• Sewage
• Pesticide and Fertilizer's toxic harm to humans, plants and animals
• Noise & Light pollution, and the biggest problem of all --
• Population Growth

SPECIES IN PERIL -

We share Monterey County with hundreds of animals and plant species. Forty nine animals 19 trees and plants are imperiled to the point of needing official protection by Federal and State laws because Monterey County has failed to adequately protect them.

These species have fortunately survived the years-long, arduous process of receiving official listing under Federal and State Endangered Species Acts, Fully Protected laws and Special Status species lists.

Yet, these 68 species are merely the officially recognized ones. Experts know of many more local species needing official protection and know there are other species we will never know of before we cause them to go extinct - gone forever.

We may eventually clean up our pollution and find new water sources - but when an animal goes extinct - it is gone from our planet, gone our solar system, gone from our galaxy - forever.

Dozens of animal species are crying out for our help. Is anyone listening?
 
 

WATER -

We are painfully out of water in the Salinas Valley, Monterey Peninsula and North County. Our Peninsula is laboring under an officially declared Water Supply Emergency and is simultaneously imperiling two vital aquatic species (steelhead & the red-legged frog)!

Let us suggest that contrary to those who demand unfettered exploitation of natural phenomena and are unconcerned with imposing on their neighbors - the Wild West is gone.

• ENOUGH!

Our community systems are broken because we overzoned and underregulated and under-prohibited dozens of such dangerous and harmful activities.

Right to Greed vs. Right to Healthy Environment

Those who made, and make, money from unsustainable activities, such as development and resource exploitation, don't want to stop. They refuse to recognize that our community rights, the rights of the rest of us to a healthy environment, far exceeds any businessman's right to profit.

Directly contrary to the bleats of the development crowd who claim the General Plan Update is a "No-Growth" plan it is a HUGE GROWTH Plan. It requires accommodating some 100,000 to 150,000 new people, housing them in at least 10,000 NEW buildings (ignoring converting existing unused housing), building new and wider roads and freeways (Expressways).

Growth is Not Inevitable.

When considering the astounding number and depth of constraints on natural resources and how growth always costs more than it pays, Monterey County should be examining how to stop growth not how to blindly encourage growth.

Range of Solutions

We want to participate in the honest evaluation of two alternatives

1. A General Plan constrained by water, traffic and other existing infrastructure limits.

2. A General Plan constrained by sustainable use of resources sometimes called "Carrying Capacity" or "Steady State."

EIR - Far Too Soon

We have not yet commented upon the Draft EIR because -

1) the GPU is described on page 1 as "a "first draft." (Italics theirs). Because analysis of this project is so time-consuming we will wait until the GPU is re-written and the revised Draft EIR is provided, and

2) The DEIR is so massively deficient in its recognition of potentially significant environmental impacts (including growth, traffic, water supply and pollution, pesticides, and soils), alternatives and mitigations.

As the advisor you hired, Clem Schute, put it "You're wise to pay close attention to the legal adequacy of the [EIR]."

PROTECT ENVIRONMENTAL HEALTH & ELIMINATE MANMADE HAZARDS

Objective 14 needs the phrase "eliminate wherever possible" so it reads "... and eliminate wherever possible manmade hazards (hazardous materials, noise, aircraft)." because we can control man-made hazards, while we cannot control natural hazards such as earthquakes.

Objective 14 should also protect non-human health such as wild habitats. We suggest adding the phrase "and general environmental health" so the phrase reads "Protect public health and safety and general environmental health by ..."

Objective 14 should now read "Protect public health and safety and general environmental health by minimizing risks related to natural hazards (seismic/geologic, fires, flooding, erosion) and eliminate wherever possible manmade hazards (hazardous materials, noise, aircraft)."

ANIMALS NEED PROTECTION TOO

The Environmental Element has the beginnings of protection for plants in Goal ER-3, but no similar Goal or section for animal protection.

• Please include a Goal and section that provides protection for wildlife.

• Please provide a Public Works program that -

FORESTS NEED PROTECTION

Page 7 "Forests" need to be specifically included just as wetlands, sensitive plant communities and riparian areas are.

SOILS NEED PROTECTION TOO

Soils are alive. In very cubic inch of soil live some 1000-1200 species of micro-organisms.

• Please include a Goal and section for soil protection.

Policy ER-2.1 chops off further protection for not merely endangered and threatened species - but all animals and plants which may be listed in the future.

Question - After a Habitat Conservation Plan (HCP) is prepared and approved under Policy ER-2.1 for a specific parcel of land, and as long as the landowner is complying with the plan and implementing agreement, under what circumstances, if any, may a landowner be required to provide any additional protection on their land -

* for covered species which experience a significant new decline towards extinction?

Answer - NONE. No further protection.

* for a species newly designated as threatened or endangered under the federal or state Endangered Species Acts, living on that HCP covered land?

Answer - NONE. No further protection.

If this policy was in place when the 1982 General Plan was adopted the Steelhead and the Red-legged frog would receive no further protection when they were listed just 5 years ago!

• Please remove the last part of the policy starting with the words "while relieving..."

• Please provide a scientifically based process for adding County imperiled species to a County list so they are recognized before they become threatened or endangered.

Wildlife corridors are highly important to retaining and restoring biodiversity. "Missing Linkages" (November 2000) prepared in concert with the USGS and California State Parks documents the loss and further threats to wildlife corridors in Monterey County. The largest threats are urbanization, agriculture, roads vineyards, invasive species, water diversions and watercourse flow regime alterations.

• Please provide protection for wildlife corridors from urbanization, agriculture, roads vineyards, invasive species, water diversions and watercourse flow regime alterations.

Living matter has weight, which is called "biomass."

The General Plan does not currently recognize loss of biomass. Policy ER-3.4 explicitly allows the loss of biomass through mitigation which pretends that a few ounces in seedlings fully offsets the loss of tons of trees. Leaving this Policy as it stands will increase CEQA environmental impacts and could trigger additional EIR work.

• Please provide a goal which specifically recognizes and avoids biomass loss.

• Please provide Mitigation for cutting native trees which provides funds for purchasing nearby Native Monterey pine forest habitat.

• Please provide Mitigation for loss of sensitive habitats which provides funds for purchasing that same native habitat type in nearby locations.

A forester or arborist rarely has any Biology training.

A biologist is only trained to examine one species at a time.

An Ecologist is trained in the health, sustainability and interdependence of all the animals, plants and other biota in an area. Even the Pebble Beach Company representative acknowledged the importance of ecologists in comments on May 1, 2002.

• Please improve all references for biota experts by replacing biologist (for example ER-2.c ,ER-2.4), forester and Arborist to "Ecologist."

Missing from the Scenic Viewsheds map are Los Laureles Grade, Robinson Canyon Road, the Old Coast Road, Plaskett Road, and the Coast Ridge Road.

• Please include those missing roads and analyze the viewsheds from those roads.

• Please Remove Golf Courses from Open Space definition.
• Please Define Open Space as areas with free public access.

TRAFFIC & ROADS

• You Can't Pave Your Way Out of Congestion

• Closing Roads or Lanes Can Reduce Congestion!

"When Road Capacity Shrinks, So can Traffic." Auto-Free Times, Winter 1996-1997

PLANNING

"Eight Myths of Traditional Traffic Planning" CART, Brisbane Australia, 1989

"Determining Generated Traffic External Costs." Litman, Victoria Transport Policy Institute, March 1997

ROADS GENERATE TRAFFIC

"Do new Highways Generate Traffic?" U.C. Berkeley Transportation Research Center

"New roads may create more traffic." Monterey Herald, Dec 26, 1998

• "Relationship between Expansion and Congestion in Metropolitan Areas" Texas Transportation Institute and STTP, Nov 1998 (A study of 70 cities over 15 years showing no matter how many roads or how much money is spent - congestion increases.)

"Road to Ruin" Martin, Discover Magazine, May 1992 (Braess' Paradox)

ROAD IMPACTS

"Road Building Leads to Extinction" Soule, M. Auto-Free Times, Winter 1996-1997

"Review of Ecological Effects of Roads on Terrestrial and Aquatic Communities", Trombulak et al., Feb 2000, Conservation Biology

Federal Court decision "Highways create demand for travel..." 962 F. Supp 1037 (N.D. Ill 1997)

• Please remove the Expressways (Espinosa etc.) from the General Plan.

• Please remove Rio Road extension at the mouth of Carmel Valley for the same reasons.

• Please remove the LOS (Level of Service) change from C to D.

• Please include a map of roads currently experiencing gridlock.

• Please only allow buildings AFTER the infrastructure is in place.
• Please support the Traffic-shed concept.
• We strongly support walking trail corridors over private property, especially along ridgelines and along rivers.

• We strongly support the Draft General Plan where it leaves Highway 1 as a two-lane only road between Castroville and Santa Cruz County Line.

• We strongly oppose expanding Highway 68 to four lanes.

• We strongly oppose building any new four lane roads to the Monterey Peninsula.

We find this element helpful in some regards, but respectfully request it be expanded to recognize these Health & Safety issues.

NOISE ELEMENT

The General Plan does not adequately recognize loud short-term Noise Impacts.

Both methods used, "CNEL" (Community Noise Level Equivalent) and "Ldn" (Sound (L)evel (d)ay & (n)ight), only recognize long duration increases in noise.

• CNEL and Ldn simply do not recognize short-term loud and even harmful noises including gun-shots, car horns, aircraft landing and take-offs, lawn mower use, leaf blowers or even dog barking.

I think we can agree the livability of the two areas is dramatically different. Yet, the CNEL and Ldn for both days will be the same. The two days will be indistinguishable even by an expert.

• Please use and provide a Countywide Contour Map of Maximum Noise Levels. The map will make it clear even to a non-technical people where areas have noise problems.

There are existing Noises that can and should be reduced including garbage trucks, traffic, aircraft, trains, use of generators in rural areas, leaf blowers (which are highly restricted in Carmel & Pacific Grove), mining, marine acoustic experiments, marine shipping cavitation (up to 190 dBA), automobile racetracks, ball parks, outdoor shooting ranges, chainsaws and chippers, construction equipment and vehicles, and persistent dog barking.

• Please provide Policy, Goals and Actions to reduce existing noises to ambient sound levels so that complaints are eliminated.

• Please prohibit subdivisions and building in areas where noise barriers could be needed.

Goal HS-2 should "Eliminate" - not merely "reduce" the potential for damage to structures and danger to life caused by flooding. Floodplains are for agriculture.

• There should be no further development on the Carmel Valley floodplain or other floodplains.

• In Monterey County some 428 cases of human pesticide poisoning were reported to public officials during a six year period into the early 1990s. Fifty (50!) cases of human pesticide poisoning were reported in Monterey County in 1996.

What this does not show is the number of pesticide poisonings that is never reported because victims and even doctors are not trained to recognize the myriad symptoms from the toxic cocktail of pesticides sprayed into the air of Monterey County every year.

PESTICIDES UNINTENDED and UNAVOIDABLE IMPACTS

• Pesticides by definition, intent and design are deadly to humans and animals.
• They are intended and designed to kill animal and plant life.
• Almost all pesticides kill unintended victims.
• Some pesticides have multi-generational impacts - your exposure could harm your grandchildren.
• In the words of the US-EPA "Pesticides are not 'safe.' They are produced and used specifically because they are toxic to something."

"As many as 67,000 cases of human pesticide poisoning occur worldwide each year, some of which are fatal." Environmental Science; Morgan, Moran & Weirsma; W.C. Brown Pub. 1993, p 178 "Somewhere between 400,000 and 2 million people suffer from acute pesticide poisoning every year: between 10,000 and 40,000 of them die." World Wildlife Fund, 1990

COUNTY PESTICIDE USE

While we acknowledge the importance of preserving the Salinas Valley Flood Plain for agricultural land for food, we are very seriously concerned about the amount and toxicity of pesticides and fertilizers used.

• Agriculture can be, and is, conducted at a profit without pesticides.
• Agriculture can be, and is conducted, at a profit by halving the amount of (very expensive) pesticides used.

We find the use of pesticides on golf courses simply unacceptable because of their deadly known and unknown impacts.

• San Francisco's Presidio Golf Course is managed entirely without pesticides.
• Map of Monterey County Pesticide Use

Since the 1940s the amount of pesticides used has skyrocketed yet the percent of agriculture products lost to pests has stayed about the same - 25% to 35%.

The Rising Tide of Toxins: Pesticide Use in California by James Liebman Global Pesticide Campaigner, Volume 7, Number 3, September 1997. Pesticide Action Network North America, San Francisco, CA states "The largest percentage increase in reported pesticide use (in California Counties) during this period took place in Monterey County, which saw an increase from 7 million to almost 13 million pounds, representing an 85% increase."

This 10 - 13 million pounds of County Pesticide per year does not include -

• Inert ingredients and impurities in pesticides - which can amount to 99 percent of the product. The total amount of pesticides applied is easily 20 million pounds and possibly much more. Impurities can constitute up to 15 percent of the pesticide product or more and be even deadlier and more persistent pesticides.
• Home pesticide use which can include deadly pesticides banned from industrial use
• School pesticide use.
• Cal-Trans pesticide use along roadsides.
• Forest Service pesticide use which includes spraying diesel fuel on forests!
• It should include Golf Course pesticide use, which is typically a thousand pounds per course per year in Monterey County, but there is zero accountability in the system (literally no one verifies the products and amounts used) and the use of these deadly chemicals can easily go unreported.

Monterey County Health Department admits they have NOT tested the watercourses adjacent to golf courses including the Carmel River or any stream in Pebble Beach for each pesticide.

• Please provide a Goal, Section and Action testing the watercourses adjacent to golf courses including the Carmel River and all streams in Pebble Beach for each pesticide used in that watershed.
• Please provide a Goal, Section and Action requiring Monterey County Health Department to keep a list of pesticides used on golf courses built before 1997 and to track liquid and solid poison use of less than 100 pounds.

There are about 630 different "active ingredients" in pesticides worldwide. In real-world use, these main ingredients are combined with other chemicals (some are called "inert ingredients") to make several thousand toxic formulations -- but the basic active ingredients number about 630. In 1992 4.5 Billion pounds of pesticides were used in the U.S. which is about 18 pounds per person.

Approximately 1,050 of the secret ingredients are considered "inerts of unknown toxicity." EPA does not require testing to determine their toxicity. "EPA has found approximately 40 "inert ingredients" to be of toxicological concern after testing them and has determined that approximately 65 others are potentially toxic." "More than two thousand inert ingredients are used in pesticides however, and most of them have not been tested by EPA or evaluated for toxicity." NCAMP v. EPA 941 F.Supp 197, 198 (1996)

Approximately 40 of the "inert" ingredients are known to cause cancer, nerve damage, other chronic effects, or adverse reproductive effects. These "inerts" include asbestos, carbon tetrachloride (banned as an active pesticide ingredient), and trichloroethylene. In 1987, EPA indicated these inerts must be listed on the pesticide label, but there is no evidence that EPA enforces this policy. All the other 1,400 or so inert ingredients do not have to be listed on pesticide labels.

Approximately 65 of the secret ingredients are classified "potentially toxic inerts/high priority for testing" because their chemical structure or existing data suggest toxicity. These "inerts" include xylene, cresols, and methyl bromide (a highly toxic fumigant and neurotoxin).

• Please provide a Goal, Section and Action increasing the meaningful documentation on the use of all pesticides. (please see Appendix A)
• Please provide a Goal, Section and Action on the use of all pesticides - analyzing and avoiding or fully mitigating the complete deadly health impacts on humans and wildlife in Monterey County.

• Monterey County industry generated 572 tons of pesticide waste in 1986 and was projected to generate 540 tons in 2000. Monterey County Hazardous Waste management Plan 1989 p 5

Monterey County industry generated 139 tons of PCBs and Dioxins in 1986 and was projected to generate 148 tons in 2000. Monterey County Hazardous Waste management Plan 1989 p 5-22

CHLORINE

Swimming pool chlorine dumped as runoff into streams and storm drains is not uncommon. It can harm the Sea Otter Refuge, Areas of Biological Significance (ABS) and the Monterey Bay National Marine Sanctuary (MBNMS).

CATTLE DIPPING

Many Ranches in Monterey County performed "Cattle Dipping" prior to the 1960's in which cows were led through a trench filled with DDT and Toxaphene. These areas are now hazardous waste sites. Markham Ranch is one example.

DDT - ITS BACK

Moss Landing Harbor has the highest concentrations of DDT in its harbor bottom of anywhere in California. The Pajaro River bordering Monterey and Santa Cruz Counties also has high levels of DDT.

• Please provide a Goal, Section and Action recognizing the uses of hazardous materials, map their current and former (and still deadly) uses and prepare a plan to fully avoid, mitigate and genuinely clean up their harmful impacts on humans and wildlife.

We solidly support the Air District's concern about Diesel exhaust as a toxic and cancer causing.

• Please provide a program to monitor and reduce air toxic hot spots so we can eliminate them.

Light Pollution

Light pollution has two facets - sky glare which impacts astronomical observations and light pollution which impacts neighbors.

The county and private parties can save money by using less polluting light fixtures with smaller wattage bulbs.

1) Conduct a survey of major existing light and glare pollution sources in the County,

2) Adopt measurable light pollution reduction goals and policies including -

1. Substantially and continually reduce light pollution from existing major and cumulative sources.

3) Monitor the situation and adapt as necessary to continually decrease overall light pollution.

STOP LIGHTS and SOUND WALLS

Forbid Stoplights in the Monterey Peninsula, Carmel Valley and Big Sur Area.

Forbid Sound walls (like near Toro Village) in the Monterey Peninsula, Carmel Valley and Big Sur Area.

Pebble Beach

• Remove shoreline access restrictions (e.g. Point Joe, Cypress Point) as it never received Coastal Commission approval.
• Prohibit Stop Lights

• Remove coastal access prohibition of Big Sur's night time parking prohibition as it never received Coastal Commission approval.
• Prohibit Stop Lights

COUNTY IMPROVEMENT PROCESS

There is an explicit procedure (forms to fill out, explicit decisions by decision makers and appeal procedures) for developing the county, but no parallel process for protecting the County's natural phenomena or improving public participation.

• Please include a process for protecting the County's natural phenomena and improving public participation.

• Please provide a schedule where as soon as the General Plan is adopted - one General Plan Element is revised each year in the future so the Plan stays relatively up to date.

p 3 Biological Diversity is well stated.

p 18 Noise is well stated.

p 18 Overdraft is well stated.

p 25 Walkable Community is well stated.

Mistyped?

p 5 In Clustered Development "placed"

p 5 In Coastal Act "balanced"

Clarification Needed

p 3 In Biological community - some communities are not dominated by a single species. You could add the word "sometimes" to make it more accurate.

p 4 Carrying Capacity is generally well stated. We request you remove the third concept (buildout) as it is not a carrying capacity and is already properly placed at the top of p 4. These two concepts are important to distinguish and should not be confused. Also under concept 1, please change the word "change" to "harm."

p 15 LOS "F" please add "Gridlock - Typically a delay of 60 seconds or more."

p 16 In Long Term Water Supply please add " quantity and" to quality.

p 17 In Nitrate Cont. please add "surface and" to "groundwater."

p 19 In Rare and Endangered please add "California Native Plant Society and United Nations Food and Agriculture." as they are recognized experts in this area.

p 20 Ridgeline Development - please remove the word "common" as it is ambiguous.

p 21 In Smart Growth - please remove "and protects open space" as there is no legal definition, or agreed upon concept that open space will be permanently or ever be protected associated with growth. If you leave this in we suggest you add the words "protects an equal amount of open space as public for at least 250 years."

p 1 In Acceptable Risk - please change "deemed" to "deemed by an identified source."

p 7 In Conservation please add "extraction, erosion or loss."

p 7 In Cumulative Impact please add "Also means different types of impacts added with sometimes unexpected results."

Please Remove

p 23 Please remove "Sustainable Development" - Because it is a self contradictory phrase as development cannot continue indefinitely. No matter how slow growth occurs at some point it must consume all land. (See Herald editorials March 15, 1998 and March 26, 2000 also at www.1hope.org/smart-no.htm)

Acoustic Clarifications

p 7 In dB range of "0 to 140." Please rewrite as Decibels have no inherent upper limit. In Monterey County jets, gunfire and explosives regularly exceed 140 dB.

p 5 CNEL (and p 7) The term "average" in misleading. There are at least 8 types of averages, or measures of central tendency. Each can have a wildly different result. CNEL is an extraordinary combination of 3 measures of central tendency which can hide significant noise.

As described in our letter of June 3 "CNEL and Ldn simply do not recognize short-term loud and even harmful noises including gun-shots, car horns, aircraft landing and take-offs, lawn mower use, leaf blowers or even dog barking."

We again request you add "Maximum Noise level" to the terms used.

Please add "Maximum Noise Level: The loudest reoccurring noise in an area in dBA."

Definitions Needed but Missing

Please add "Biomass: The total weight or mass of living organisms."

Please add "Downzoning: Reduction of zoning density so fewer structures are allowed.

Please add "Ecosystem"

Please add "Ecologist: An Ecologist considers the health of interdependence of all the biota and natural cycles in an ecosystem while a Biologist only studies one species at a time.

Please add "Edge effect: The degradation of a natural environment proportional to its nearness to human activity and structures. A road introduces noise, light, air and water pollution. Generally the closer to a road the greater the pollution.

Please add "Events" (e.g. Laguna Seca races, Golf Tournaments)

Please add "Forest: A natural area dominated by native trees supporting native soils and wildlife."

Please add "Light Pollution: Unwanted man-made light interfering with astronomical observations or aesthetic enjoyment of dark areas or those illuminated with natural light."

Please add "Public Interest: Benefiting the general public, a large class of persons or the natural world."

Please add "Take of Endangered Species: To harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct."

With all due respect,

David Dilworth, Executive Director
 
 

Appendix A

We urge needed additions to the standard Pesticide Reporting form used by Monterey County.

PROBLEM:

In spite of the Pesticide Reporting forms now used at the Counties and in spite of the (somewhat obscure) public availability of the related information - No one, including DPR, the US-EPA, Calif Fish and Game, public interest researchers, applicators themselves or the decision makers can easily determine:

1) the exact chemicals (active and "inert") in products to be applied (CAS numbers),

2) the toxicity levels of the active (and "inactive") chemicals to human life, to fish or to birds or other wildlife (LD50, LC50, Carcinogenic, Tetrogrenic and Bioaccumulative effects etc.)

3) The persistence of the active and "inert" ingredients in the environment (soils, water and food chains).

According to pesticide experts at the US-EPA, the California Department of Pesticde Regulation and the California Department of Fish and Game - "There is no single place where you can look up all that information."

Let me repeat that:

Finding this information should NOT be the multi-week exercise, which I have experienced, for those interested in determining the public and environmental health hazards of materials used in California.

SOLUTION:

So to significantly more adequately protect human health, public safety, wildlife and the environment we seriously request that you please add to the existing Pesticide Reporting form -

1) Lines requiring disclosure of the active chemicals in each product.

2) Lines requiring disclosure of the "inert" chemicals in each product which have any known toxic effects - whether on humans, wildlife or fauna.

3) For each of the lines added from 1 and 2 - require the EPA's CAS (Chemical Abstract Service) number for each of the active and inert chemicals.

4) For each of the lines added from 1 and 2 - require the LD50 and the LC50 numbers (toxicity levels) and whether the chemical is listed under Proposition 65 (Chemicals KNOWN to the State to be carcinogens etc.).

5) For each of the lines added from 1 and 2 - require the half life data to provide a rough guide for how long the chemical could persist in the environment.

When Applicators are required to fill in this additional information it will not only make the Pesticide Reporting significantly more meaningful - it will make the applicators significantly more personally aware or refreshed of the real hazards of the highly dangerous materials they are using.

We realize that until Manufacturers provide this information on product labels, Counties will have to have the reference books or internet access available at the counter.

We find the added disclosure for those directly involved in the permit process and to those who are interested in public health - far outweighs the small inconvenience in time to those filling out the forms and the extra County staff time needed to educate and assist those filling out the forms. w long the chemical could persist in the environment.

When Applicators are required to fill in this additional information it will not only make the Pesticide Reporting significantly more meaningful - it will make the applicators significantly more personally aware or refreshed of the real hazards of the highly dangerous materials they are using.

We realize that until Manufacturers provide this information on product labels, Counties will have to have the reference books or internet access available at the counter.

We find the added disclosure for those directly involved in the permit process and to those who are interested in public health - far outweighs the small inconvenience in time to those filling out the forms and the extra County staff time needed to educate and assist those filling out the forms.