LWVMP and LWVSV

September 7, 2008
Todd Muck
TAMC
55-B Plaza Circle
Salinas, CA 93901

Subject: Mitigated Negative Declaration (MND) For Carmel Hill and River Class I Bicycle Trail Project

Dear Mr. Muck:

The League of Women Voters of the Monterey Peninsula has reviewed the MND for the Carmel Hill and River Bicycle Trail. The project is a 1.7 mile, 12-foot wide bicycle trail between the Crossroads and Canyon Drive, a cul-de-sac, withan undercrossing at Carmel Valley Road. We have the following comments:

  1. Page 1. The MND notes the Biological Assessment is currently undergoing final changes to comply with recent "regulatory input". As of September 4, the document was not posted on the TAMC website. The comment period for review of the MND should be extended to enable public review of an updated Biological Assessment.
  2. Page 55. The MND concludes, "For these reasons, the impact of diesel exhaust from this construction project is anticipated to contribute negligibly to an increased cancer risk for each individual sensitive receptor and would be considered less-than-significant". This conclusion is based on a qualitative rather than a quantitatively analysis. Further, the analysis fails to address acrolein, a toxic air contaminant resulting from the combustion of diesel exhaust. Since there are residences within 1/4 mile of proposed construction activity and acrolein adversely affects those with respiratory problems including asthma, a quantitative risk assessment of diesel exhaust emissions and acrolein should be undertaken
  3. Page 56. The MND concludes, "It is anticipated that the project meets the suitability criteria for the U.S. Fish and Wildlife Service Programmatic Biological Opinion (2003)". The document indicates that all mitigation measures outlined by the U.S. Fish and Wildlife Service shall be implemented. Without identification of these mitigation measures, it is not possible for the Lead Agency to determine if they are feasible and if an MND is the appropriate environmental document. The MND should be recirculated once the mitigation measures have been identified.
  4. Page 58. Protection of Smith's blue butterfly depends on unidentified mitigation measures. See item 3 above.
  5. Page 58. The MND states that a qualified biologist shall prepare and implement a Wetland and Riparian Restoration and Monitoring Plan which will identify needed mitigation measures. Once again, without identification of needed mitigation measures, the MND is incomplete and should be revised and recirculated once the information is available
  6. Pages 67 and 68. The MND finds the project includes new impervious surfaces totaling 2.6 acres and storm water will sheet flow from the paved surfaces to nearby unpaved areas where it will percolate or flow into the creek or storm culvert and the trail would result in an increase in the amount of surface runoff during storm events. Policy 3.1.1.2 of the Carmel Valley Master Plan includes a provision "... for slow release of runoff water so that runoff rates after development do not exceed rates prevailing before development...". The project is inconsistent with this policy. Were project alternatives or mitigation measures considered that would reduce impervious surfaces such as a narrower bicycle path?
  7. Page 75 and 76. The MND indicates the project would reduce traffic along Highway 1" by providing a more accessible alternative transportation option (bicycle and pedestrian)." Table 8 provides estimates of bicycle and pedestrian trip generation of up to 100 trips during Sunday mid-day peakes. These estimates were based on pedestrian and bicycle counts at six locations along the Monterey Bay Coastal Trail (p. 12, Appendix K). All of the locations were segments of a connected trail system. The proposed project stops at Carmel Hill without any northern connectivity. Given the lack of connectivity, the assumption that the trail would provide an alternative transportation option is very highly questionable. Further, the short length of the trail would limit its appeal to recreational bicycle users. The trip estimates appear too high and should be revised based on data of comparable trail systems.

Thank you for the opportunity to review and comment on the document.

Sincerely,
     Janet Brennan, President