Friends of Arana Gulch
Comments on the Proposed Draft EIR
8 August 2005
Susan Harris
City of Santa Cruz
Parks and Recreation Department
323 Church Street
Santa Cruz, CA 95060
Dear Ms. Harris :
The following comments are submitted on behalf of Friends of Arana Gulch.
Our first concern is the name change of the Arana Gulch Greenbelt Master Plan to an Arana Gulch Park Master Plan. By renaming the greenbelt as a "park," Parks & Rec. has dramatically changed the essence of this area, which Measure O stipulated as one of five greenbelts for the City. Somewhere between a March 11, 2003 Public Works Agenda Report and your October 2, 2003 Agenda Report, both for City Council meetings, "greenbelt" became "park." This appears to be the work of Parks & Rec., so it is your obligation to correct your error.
Next, while we do not support the new version of a paved bicycle connection from Broadway to Brommer Street Extension, we have some pertinent comments on the chosen location, as presented at the scoping session:
We are dismayed that the City thinks it shall be able to get this paved roadway and bridge through the Coastal Commission. They have been emphatic about the City finding other bikeway routes as alternatives to developing one on the Environmentally Sensitive Habitat Area of the coastal prairie of Arana Gulch greenbelt (see letters from the Coastal Commission to the City dated 25 Nov. 1998, 11 Jan. 2000, and 13 May 2003).
Restoration Alternative
One alternative was presented at the scoping session, in addition to a No Project alternative that will be analyzed. According to Parks & Rec., an arbitrary limit of three alternatives will be allowed in the EIR. We believe that limiting the alternatives to receive analysis is contrary to the goal of looking at all "reasonable" alternatives, as required by past judicial review of environmental impacts reports. That being said, we have only one alternative to propose. While our alternative does not include either a bridge or paved 8' bicycle connection roadway, it does address all of the components of the Project Description in the Notice of Preparation of the EIR for the Arana Gulch Park (sic) Master Plan: resource management areas, public use guidelines, interpretive trails and the Santa Cruz Tarplant.
If you do limit rigorous analysis of alternatives to three, then we assume the following Restoration Alternative will be the third. It was proposed at the 21 July 2005 scoping session, was supported by others at that meeting, and has been recommended by others during the comment period.
In point of fact, the Restoration Alternative is a real alternative for management, unlike the No Project alternative, which provides for the status quo that allows continued degradation of the coastal prairie meadow habitat of at least one endangered species.
Our Restoration Alternative includes the following:
Potential (cumulative) impacts of development of the 6 acre exclusion must be considered in the EIR, including impacts on the riparian zone of Arana Creek and the coastal prairie meadow habitat. We recommend that, at a minimum, the 6 acres be included as an undeveloped buffer for the greater part of the greenbelt. As an entrance to the natural area, it is a good location for educational signage and interpretive displays, removing such development from the trails themselves and thus maintaining the open space as - open!
We are dismayed that apparently the agencies that have a record of concern regarding a bike roadway through the greenbelt (USFWS, CA Coastal Commission and Fish & Game) were sent the Notice of Preparation of the EIR on 22 June 2005, in the middle of traditional summer vacation time and given only 32 working days to submit comments on such an important development project. One wonders at the reason for such a rush, since Parks & Rec. was given direction to start the Master Plan process by the City Council on 14 October 2003, almost two years ago.
One final note: management of the Arana Gulch Greenbelt will require funds after any alternative is implemented. How much money will be required to properly manage the area? From where will it be derived? How many "on the ground" staff will be needed?
Comments submitted on behalf of Friends of Arana Gulch.
by Jean Brocklebank
1190 7th Avenue
Santa Cruz, CA 95062
[831] 462-4919
Susan Harris
City of Santa Cruz
Parks and Recreation Department
323 Church Street
Santa Cruz, CA 95060
Dear Ms. Harris :
The following comments are submitted on behalf of Friends of Arana Gulch.
Our first concern is the name change of the Arana Gulch Greenbelt Master Plan to an Arana Gulch Park Master Plan. By renaming the greenbelt as a "park," Parks & Rec. has dramatically changed the essence of this area, which Measure O stipulated as one of five greenbelts for the City. Somewhere between a March 11, 2003 Public Works Agenda Report and your October 2, 2003 Agenda Report, both for City Council meetings, "greenbelt" became "park." This appears to be the work of Parks & Rec., so it is your obligation to correct your error.
Next, while we do not support the new version of a paved bicycle connection from Broadway to Brommer Street Extension, we have some pertinent comments on the chosen location, as presented at the scoping session:
- The 8' roadway is shown on the your Proposed Trail System map as running through both the Dredge Yard and Boat Storage areas of the Harbor. Was this an error in map making?
- The EIR consultant stated that there would not be much of a gradient problem from the roadway as it climbs the slope just east of the fenced Harbor area because of the existence of a 4' retaining wall. This is wrong, unless the plan is to come through the Harbor Boat Storage area. The 4' retaining wall runs south/north and ends at the SE corner of the fenced Storage area. Furthermore, there is a rise of 16 feet in about 40' distance to get up to Brommer. This means that the roadway would have to become a ramped roadway at least 260 feet west of the existing eastside fence corner in order to be ADA compliant. If the 8' roadway is to be built behind the HarborÕs fenced areas, it will have to wipe out at least 10' of the 100' setback. And, apparently, become a raised roadway.
- The area north of the existing Harbor fence is all within the 100' setback from Arana Gulch's riparian zone required by the City's LCP Land Use Plan. The Harbor was not allowed to encroach on that 100' setback and was required to complete restoration work, including plantings of native species. Does Parks & Rec. really think that the City is going to allow this development encroachment? And if so, it will be required to create a Resource Management Plan as an LUP amendment within the LCP to be submitted & approved by the Coastal Commission. And this has to be done before the Master Plan that includes development within the 100' setback.
- Additionally, the Hagemann Gulch bridge is located within the riparian zone and would also violate the 100' setback (see above). Our concerns are the same for the proposed Marsh Vista Trail.
We are dismayed that the City thinks it shall be able to get this paved roadway and bridge through the Coastal Commission. They have been emphatic about the City finding other bikeway routes as alternatives to developing one on the Environmentally Sensitive Habitat Area of the coastal prairie of Arana Gulch greenbelt (see letters from the Coastal Commission to the City dated 25 Nov. 1998, 11 Jan. 2000, and 13 May 2003).
Restoration Alternative
One alternative was presented at the scoping session, in addition to a No Project alternative that will be analyzed. According to Parks & Rec., an arbitrary limit of three alternatives will be allowed in the EIR. We believe that limiting the alternatives to receive analysis is contrary to the goal of looking at all "reasonable" alternatives, as required by past judicial review of environmental impacts reports. That being said, we have only one alternative to propose. While our alternative does not include either a bridge or paved 8' bicycle connection roadway, it does address all of the components of the Project Description in the Notice of Preparation of the EIR for the Arana Gulch Park (sic) Master Plan: resource management areas, public use guidelines, interpretive trails and the Santa Cruz Tarplant.
If you do limit rigorous analysis of alternatives to three, then we assume the following Restoration Alternative will be the third. It was proposed at the 21 July 2005 scoping session, was supported by others at that meeting, and has been recommended by others during the comment period.
In point of fact, the Restoration Alternative is a real alternative for management, unlike the No Project alternative, which provides for the status quo that allows continued degradation of the coastal prairie meadow habitat of at least one endangered species.
Our Restoration Alternative includes the following:
- No bridge over Hagemann Gulch. Continued access from Agnes St. and the existing Harbor Road.
- Handicapped access from Agnes Street and along the main meadow path that ends with an interpretive stop turnout, allowing people to see the beauty of the greenbelt, including floral and faunal species (especially raptors on the wing). Limit the width of this multi-use pathway to 4 feet.
- Maintenance of the continuation of a non-paved pathway (available to pedestrians and bicyclists) from the handicapped interpretative turnout to a west turn toward Hagemann Gulch and the Eucalyptus heritage tree.
- Maintenance of the perimeter path way (available to pedestrians and bicyclists) with restoration work to reduce and control erosion.
- Elimination and restoration of the steep path from the Harbor road and signage to require use of either the north (up to Agnes St.) or the south pathways of the perimeter pathway.
- Management for all native floral species of coastal meadow prairie habitats, especially any endangered or threatened species, including but not limited to:
- Santa Cruz Tarplant
- San Francisco popcorn flower
- Point Reyes horkelia
- Maple-leafed checkerbloom
- Gairdner's yampah
- Santa Cruz Tarplant
- Management for all native faunal species of coastal meadow prairie habitats, especially any endangered or threatened species, including but not limited to:
- Double-crested Cormorant
- Merlin
- Sharp-shinned Hawk
- Vaux's Swift
- Yellow Warbler
- Great Blue Heron
- Dusky-footed Woodrat
- Tidewater Goby
- Red-legged Frog
- Southwestern Pond Turtle
- Steelhead trout
- Double-crested Cormorant
- Policing management to disallow camping, litter, graffiti, fireworks and partying.
Potential (cumulative) impacts of development of the 6 acre exclusion must be considered in the EIR, including impacts on the riparian zone of Arana Creek and the coastal prairie meadow habitat. We recommend that, at a minimum, the 6 acres be included as an undeveloped buffer for the greater part of the greenbelt. As an entrance to the natural area, it is a good location for educational signage and interpretive displays, removing such development from the trails themselves and thus maintaining the open space as - open!
We are dismayed that apparently the agencies that have a record of concern regarding a bike roadway through the greenbelt (USFWS, CA Coastal Commission and Fish & Game) were sent the Notice of Preparation of the EIR on 22 June 2005, in the middle of traditional summer vacation time and given only 32 working days to submit comments on such an important development project. One wonders at the reason for such a rush, since Parks & Rec. was given direction to start the Master Plan process by the City Council on 14 October 2003, almost two years ago.
One final note: management of the Arana Gulch Greenbelt will require funds after any alternative is implemented. How much money will be required to properly manage the area? From where will it be derived? How many "on the ground" staff will be needed?
Comments submitted on behalf of Friends of Arana Gulch.
by Jean Brocklebank
1190 7th Avenue
Santa Cruz, CA 95062
[831] 462-4919