5. App A Organization Comment Letters – Part 12.pdfcarnegiegeneralplan.s3.amazonaws.com/documents/FEIR_09/5. App A... · feir o18-8\rcont. feir o18-9. feir o18-10. feir o18-11.

Organization Comments on the Preliminary General Plan and Draft FEIR—Part 12

1

________________________________________________________________________________ ________ 2155 Third Street

Livermore, CA 94550

HAND DELIVERED TO OHMVR COMMISSION 2/5/16 AND EMAILED

February 5, 2016

OHMVR Commission

Christopher Conlin, Deputy Director

Dan Canfield, Planning Manager

California State Parks

Off Highway Motor Vehicle Recreation Division

1725 23rd Street, Suite 200

Sacramento, CA 95816

[email protected]

[email protected]

RE: Carnegie State Vehicular Recreation Area Draft Final EIR General Plan

Dear State Parks OHMVR Commission and Staff:

This letter is written on behalf of the Livermore Heritage Guild, the local historical society for the

Livermore Valley. Our mission is to preserve our community’s rich history.

We have opposed the Off-Highway Motor Vehicle Recreation Division’s plan to open the Alameda-Tesla

expansion area to Off-Highway Vehicle (OHV) because the plan would damage the irreplaceable cultural,

natural, agricultural and scenic resources that comprise the Tesla landscape. Unfortunately, the Draft Final

Environmental Impact Report (“DFEIR”) responses did not resolve those issues.

Livermore Heritage Guild (LHG) submitted detailed comments on the Preliminary General Plan (“PGP”)

and Draft Environmental Impact Report (“DEIR”) that were prepared for the Carnegie State Vehicular

Recreation Area (“CSVRA”). Our comment letter was incorporated into the DFEIR as letter 021

responded to on pages 7-93 to 7-94. Most of the responses were restatements of the justification for the

“broad Program EIR” structure. Based on our review of the DFEIR, our position remains that the

description of the existing conditions and resources, definition of the project, analysis of the impacts and

establishment of concrete mitigation that reduces or eliminates impacts are inadequate. Planned OHV

recreation is incompatible with the level of protection required for the exceptional historic and cultural

resources that are part of Tesla.

We recognize that the Draft FEIR/GP removes the entrance facilities on the west end of Tesla nearest

Livermore, however, the vague Limited Recreation Area (LRA) designation still allows OHV trails to

traverse the area as determined by CSVRA to be necessary “to serve their intended purpose.” Other

than not allowing structures, the LRA designation is vague and unenforceable. Intensive OHV use and

facilities are allowed directly next to LRAs and sensitive cultural and natural resources, causing direct

2

and indirect impacts as demonstrated at Carnegie SVRA. We believe such cultural resources including

the full interpretive zone of the visual and sound field must be fully protected with no interference and

influence from damaging OHV use. As such non-OHV use options for the entire Tesla expansion area

should be considered as they are able to meet most project objectives and reduce impacts.

We also remain concerned about the failure of the Draft FEIR to document the Tesla Mining and Historic

District and impacts from the proposed Project Plan. The FEIR does not address why the application for

National Registry of Historic Place recognition, approved by the State Office of Historic Preservation on

December 7, 2012, has still not been submitted by OHMVR to the National Park Service. The FEIR is

deliberate in stating that OHMVR does not believe it is subject to the National Preservation Act “at this

time.” The implications of this statement are troubling as we would expect units within the same State

Parks Department to apply the same highest standard of resource protection.

In our DEIR comments we provided a copy of “Tesla – Interpreting an Invisible Landscape.” The

monograph helps explain why the entire Tesla expansion area should be preserved. The Tesla expansion

area is an expansive historic site; it is a land of Indigenous peoples; it is a place of rich biodiversity. All

of these factors come together to make the Tesla Expansion Area landscape extraordinary and

irreplaceable, a place to be preserved for future generations.

We request that the OHMVR Commission NOT certify and approve the Proposed General Plan or the

Final EIR for Carnegie SVRA. The Tesla expansion area is not appropriate for OHV use. The expansion

area should be designated as a sensitive area as provided in the Public Resources Code or through other

viable preservation alternatives, as permanent mitigation with no OHV use for the ongoing impacts of

OHV use at the existing Carnegie SVRA.

We ask that the OHMVR Division work with local agencies and the community to ensure that the Tesla

park land is permanently preserved with no OHV use.

Sincerely,

Will Bolton

Will Bolton, President, Chair

Tesla Preservation Project

Livermore Heritage Guild