Comments on the Draft Master Plan for Arana Gulch
and the Draft EIR for the Proposed Project included in the Master Plan
Submitted by Michael Lewis & Jean Brocklebank, on behalf of Friends of Arana Gulch to the City Council and Parks & Recreation Dept. at the March 28, 2006 public hearing
Natural History of Arana Gulch
We begin by making note of our sincere appreciation of the incredibly well researched and presented natural history of the greenbelt. It is beautifully crafted and exceptionally thorough and Parks and Recreation staff can be proud of their work in this regard.
Master Plan Process
We read in the introduction of the Draft Arana Gulch Master Plan that the "the intent of this Master Plan is to establish a vision and goals that will shape the future of Arana Gulch as a unique open space within the City of Santa Cruz." However, these words of intent ring hollow because "a vision and goals" were never developed, not even at the only Public Scoping Session of last year. Instead, at that Scoping session, the public was told that a paved bicycle route and its bridge over Hagemann Creek would be included in the Master Plan.
The purpose of a Master Planning process is to analyze the resources of the area under study and develop goals and objectives for its use based on public input. The proposed Arana Gulch Draft Master plan has substituted a project for a process. Instead of the Master Planning process, the City has produced a project (the Broadway-Brommer Bicycle/Pedestrian Path Connection) around which the entire Master Plan has been developed. Project, not process.
In a letter dated January 11, 2000, from the California Coastal Commission the City's Dept. of Public Works was advised of the proper planning process for the Arana Gulch greenbelt, as directed by the City's own Local Coastal Program (LCP). The "preferred planning approach would be to prepare a specific management plan" for the greenbelt" prior to consideration of a Broadway-Brommer Bicycle Pedestrian Project."
Friends of Arana Gulch has been asking for this proper planning process for Arana Gulch for years. Once again, this latest incarnation of the paved Broadway-Brommer Bicycle route through an environmentally sensitive habitat area is an obvious attempt at slipping a preconceived project under the door of the Master Planning process.
Why Two Documents?
If the City had followed both its LCP planning directive and the advise of the CA Coastal Commission, we would not now be reviewing two separate documents and the City would not have had to spend so much of its limited funds to produce twice the documentation needed for a Master Plan for Arana Gulch.
Be that as it may, we now have two flawed documents. One is the Draft Master Plan with flaws in its basic approach and which created a project instead of a process and the other is the Draft EIR, which is duplicitous, factually inaccurate, internally inconsistent and self-contradictory.
A Bridge Over Troubled Water
The most glaring misrepresentation of both documents is their statement that there is no longer a bridge over Arana Creek in the proposed project. This is simply not true. The project includes a ramped bridge over Arana Creek. The DEIR states (p. 3-17): "Where the trail rises in the floodplain/floodway area, a small steel bridge span would be designed to achieve the change in grade." In point of fact, there is no way to bring the paved bike roadway up to Brommer St. without crossing Arana Creek.
Even if the bridge crosses the creek mostly over the existing culverts of the Harbor, it still crosses the creek and it is still a bridge per the DEIR.
Legally Feasible Alternatives
Only the Proposed Project and Alternative 2 are identified as providing money that can be used for a Tarplant Adaptive Management Plan. The other alternatives claim "uncertain" funding status for management for the tarplant. Therefore, the City is proposing alternatives which will violate the Endangered Species Act. Furthermore, these alternatives do not meet the "feasibility" test according to CEQA, which stipulates that when an alternative does not comply with "other plans or regulatory limitations," it is not a feasible alternative.
The City is required, by law, to manage for the tarplant. It must provide such management even if there is No Project. It may not consider an "uncertain" funding project.
Interim Management Plan
On page 8 of the Master Plan document we read that many of the "unauthorized pathways are located in the southern grassland and tarplant areas, and, though the City has made efforts to close these pathways and restore the habitat, management actions have been somewhat limited under the Arana Gulch Interim Management Plan." Attached are two pictures that show the so-called management actions. Two bits of plastic fencing, put in place and never again reinforced, can hardly be called serious management.
On page 46 we read that "the Arana Gulch Interim Management Plan limits existing maintenance responsibilities to annual fuel break and trail mowing, emptying trash containers, and clean-up of refuse and illegal campsites."
However, we find, in the City's Creeks & Wetlands Management Plan document a different statement about the Arana Gulch IMP. It specifically allows for "resource protection, including management of the Santa Cruz Tarplant." No limitations are identified that would establish green plastic fencing, left in disarray, as the only management actions allowed.
Environmentally Sensitive Habitat Areas
"The site is considered an environmentally sensitive habitat area (ESHA) by the Coastal Commission (under Coastal Act Section 30240) and as such is required to have resource-dependent uses. The proposed interpretive trails that are identified in the Arana Gulch Master Plan are resource-dependent and would allow a diversity of visitors to the project area. With development of the proposed multi-use and pedestrian trails, the resources of Arana Gulch could be viewed and experienced by visitors on foot, in wheelchairs, and on bicycles." (DEIR, Page 4.2-38)
The only part of the proposed paved bike route system that could be considered a "resource dependent use" are the interpretive signs. Interpretive signs do not require an ADA compliant, paved trail system that connects adjacent communities, one to another or to any other destination, via bridges over Hagemann Gulch and Arana Creek.
ESHA development restrictions specify that "Environmentally sensitive habitat areas shall be protected against any significant disruption of habitat values." The Draft EIR states, "Construction of trails through these areas would result in permanent loss of tarplant habitat within the width of the trail; additional habitat for 1 to 2 feet outside the trail footprint could also be disturbed if pedestrians and bicyclists do not stay strictly within the trail width." "Loss of tarplant habitat would be relatively greater with the multi-use trails (Canyon Trail, Arana Meadow Trail, and Creek View Trail) because these trails would be 8 feet wide, as compared to the pedestrian-only trails which would be 18 to 24 inches wide. To the extent that these trails cannot be routed to avoid the tarplant habitat (see Mitigation Measure BIO-5, below), this would be an impact that cannot be fully mitigated."
With regard to proposed mitigation measures, the Draft EIR states, "The combination of the above measures would reduce this impact, but the impact would remain significant and unavoidable because it cannot be fully ensured that all tarplant habitat would be protected. (Significant Unmitigated)"
Therefore, the paved, ADA compliant bicycle/pedestrian/wheelchair roadways cannot be considered "resource dependent uses" in the ESHA area, and furthermore will not be permitted by the California Coastal Commission and the California Department of Fish and Game because of the significant unmitigatable impacts to the resource on which the ESHA is based.
Trail Widths
There is probably no part of any of the proposed 8' wide paved "trails" that is truly only 8 feet wide. Figure 3-8 of the Master Plan shows four sections that, including their shoulders or cut and fill slopes and all are greater than 8 feet. They range from 9' 4" to 15' and include a more than 13 foot wide route.
Confusion Reigns
Prior to the April 14th comment deadline, we hope that we shall be able to make sense of several incomplete and confusing aspects of the documents. For instance:
We want this place preserved and protected, not developed.
Friends of Arana Gulch | webmaster
home
Last updated 4/1/06
Natural History of Arana Gulch
We begin by making note of our sincere appreciation of the incredibly well researched and presented natural history of the greenbelt. It is beautifully crafted and exceptionally thorough and Parks and Recreation staff can be proud of their work in this regard.
Master Plan Process
We read in the introduction of the Draft Arana Gulch Master Plan that the "the intent of this Master Plan is to establish a vision and goals that will shape the future of Arana Gulch as a unique open space within the City of Santa Cruz." However, these words of intent ring hollow because "a vision and goals" were never developed, not even at the only Public Scoping Session of last year. Instead, at that Scoping session, the public was told that a paved bicycle route and its bridge over Hagemann Creek would be included in the Master Plan.
The purpose of a Master Planning process is to analyze the resources of the area under study and develop goals and objectives for its use based on public input. The proposed Arana Gulch Draft Master plan has substituted a project for a process. Instead of the Master Planning process, the City has produced a project (the Broadway-Brommer Bicycle/Pedestrian Path Connection) around which the entire Master Plan has been developed. Project, not process.
In a letter dated January 11, 2000, from the California Coastal Commission the City's Dept. of Public Works was advised of the proper planning process for the Arana Gulch greenbelt, as directed by the City's own Local Coastal Program (LCP). The "preferred planning approach would be to prepare a specific management plan" for the greenbelt" prior to consideration of a Broadway-Brommer Bicycle Pedestrian Project."
Friends of Arana Gulch has been asking for this proper planning process for Arana Gulch for years. Once again, this latest incarnation of the paved Broadway-Brommer Bicycle route through an environmentally sensitive habitat area is an obvious attempt at slipping a preconceived project under the door of the Master Planning process.
Why Two Documents?
If the City had followed both its LCP planning directive and the advise of the CA Coastal Commission, we would not now be reviewing two separate documents and the City would not have had to spend so much of its limited funds to produce twice the documentation needed for a Master Plan for Arana Gulch.
Be that as it may, we now have two flawed documents. One is the Draft Master Plan with flaws in its basic approach and which created a project instead of a process and the other is the Draft EIR, which is duplicitous, factually inaccurate, internally inconsistent and self-contradictory.
A Bridge Over Troubled Water
The most glaring misrepresentation of both documents is their statement that there is no longer a bridge over Arana Creek in the proposed project. This is simply not true. The project includes a ramped bridge over Arana Creek. The DEIR states (p. 3-17): "Where the trail rises in the floodplain/floodway area, a small steel bridge span would be designed to achieve the change in grade." In point of fact, there is no way to bring the paved bike roadway up to Brommer St. without crossing Arana Creek.
Even if the bridge crosses the creek mostly over the existing culverts of the Harbor, it still crosses the creek and it is still a bridge per the DEIR.
Legally Feasible Alternatives
Only the Proposed Project and Alternative 2 are identified as providing money that can be used for a Tarplant Adaptive Management Plan. The other alternatives claim "uncertain" funding status for management for the tarplant. Therefore, the City is proposing alternatives which will violate the Endangered Species Act. Furthermore, these alternatives do not meet the "feasibility" test according to CEQA, which stipulates that when an alternative does not comply with "other plans or regulatory limitations," it is not a feasible alternative.
The City is required, by law, to manage for the tarplant. It must provide such management even if there is No Project. It may not consider an "uncertain" funding project.
Interim Management Plan
On page 8 of the Master Plan document we read that many of the "unauthorized pathways are located in the southern grassland and tarplant areas, and, though the City has made efforts to close these pathways and restore the habitat, management actions have been somewhat limited under the Arana Gulch Interim Management Plan." Attached are two pictures that show the so-called management actions. Two bits of plastic fencing, put in place and never again reinforced, can hardly be called serious management.
On page 46 we read that "the Arana Gulch Interim Management Plan limits existing maintenance responsibilities to annual fuel break and trail mowing, emptying trash containers, and clean-up of refuse and illegal campsites."
However, we find, in the City's Creeks & Wetlands Management Plan document a different statement about the Arana Gulch IMP. It specifically allows for "resource protection, including management of the Santa Cruz Tarplant." No limitations are identified that would establish green plastic fencing, left in disarray, as the only management actions allowed.
Environmentally Sensitive Habitat Areas
"The site is considered an environmentally sensitive habitat area (ESHA) by the Coastal Commission (under Coastal Act Section 30240) and as such is required to have resource-dependent uses. The proposed interpretive trails that are identified in the Arana Gulch Master Plan are resource-dependent and would allow a diversity of visitors to the project area. With development of the proposed multi-use and pedestrian trails, the resources of Arana Gulch could be viewed and experienced by visitors on foot, in wheelchairs, and on bicycles." (DEIR, Page 4.2-38)
The only part of the proposed paved bike route system that could be considered a "resource dependent use" are the interpretive signs. Interpretive signs do not require an ADA compliant, paved trail system that connects adjacent communities, one to another or to any other destination, via bridges over Hagemann Gulch and Arana Creek.
ESHA development restrictions specify that "Environmentally sensitive habitat areas shall be protected against any significant disruption of habitat values." The Draft EIR states, "Construction of trails through these areas would result in permanent loss of tarplant habitat within the width of the trail; additional habitat for 1 to 2 feet outside the trail footprint could also be disturbed if pedestrians and bicyclists do not stay strictly within the trail width." "Loss of tarplant habitat would be relatively greater with the multi-use trails (Canyon Trail, Arana Meadow Trail, and Creek View Trail) because these trails would be 8 feet wide, as compared to the pedestrian-only trails which would be 18 to 24 inches wide. To the extent that these trails cannot be routed to avoid the tarplant habitat (see Mitigation Measure BIO-5, below), this would be an impact that cannot be fully mitigated."
With regard to proposed mitigation measures, the Draft EIR states, "The combination of the above measures would reduce this impact, but the impact would remain significant and unavoidable because it cannot be fully ensured that all tarplant habitat would be protected. (Significant Unmitigated)"
Therefore, the paved, ADA compliant bicycle/pedestrian/wheelchair roadways cannot be considered "resource dependent uses" in the ESHA area, and furthermore will not be permitted by the California Coastal Commission and the California Department of Fish and Game because of the significant unmitigatable impacts to the resource on which the ESHA is based.
Trail Widths
There is probably no part of any of the proposed 8' wide paved "trails" that is truly only 8 feet wide. Figure 3-8 of the Master Plan shows four sections that, including their shoulders or cut and fill slopes and all are greater than 8 feet. They range from 9' 4" to 15' and include a more than 13 foot wide route.
Confusion Reigns
Prior to the April 14th comment deadline, we hope that we shall be able to make sense of several incomplete and confusing aspects of the documents. For instance:
- Appendix A of the Master Plan on the City web site is missing several pages.
- It is clear that the part of the Proposed Project on Port District Property has received scant attention to detail and therefore true environmental impacts cannot be known or evaluated. Additionally there is no discussion of hazards created by high-speed downhill bicycle traffic in both directions.
- The applicability of the riparian 100 foot setback required by the CA Coastal Act, the City's LCP and the Citywide Creeks and Wetlands Management plan is not clearly addressed and is confusing as it is stated in the DEIR. We can't make sense of it. Does it apply or doesn't it?
We want this place preserved and protected, not developed.
Friends of Arana Gulch | webmaster
home
Last updated 4/1/06