Traci Verardo-Torres, vice-president of Government Affairs for the
California State Parks Foundation (CSPF), has generously given us permission to publish these excerpts from the CSPF’s comments on the Draft Environmental Impact Report/Statement (DEIR) for the Fresno-to-Bakersfield section of the California High-Speed Rail.
In her October 11, 2011 letter to Tom Umberg, chair of the California High-Speed Rail Authority board of directors, Verarado-Torres addressed the impact that the High-Speed Rail will have on Colonel Allensworth State Historic Park.
The
California High-Speed Rail Authority has announced that it will not release a Final Environment Impact Report for the Fresno-to-Bakersfield section of the High-Speed Rail as planned in January but will issue a Revised DEIR in the spring of 2012. There will be another official comment period following the release of the revised DEIR.
Stephen Hill, Sr.
Given the cultural and historical importance of Allensworth and the legislative intent to protect the park, CSPF is concerned that the proposed Project will have long lasting, negative impacts to Allensworth. Specifically, the proposed Project will impact the historical character at Allensworth, create barriers to public access and negatively impact the visitors experience at the park. In addition to those concerns, we do not believe the DEIR adequately analyzed all proposed alternatives presented. Our concerns are outlined below.
Degradation of the historical character of Allensworth
Noise
The high speed train operation will result in noise impacts to Allensworth, but the DEIR does not present a clear and comprehensive analysis of the anticipated noise impacts to the park. Of the noise measurement sites, only two were selected just southeast of Allensworth. It is difficult to verify in the DEIR if the locations are sufficient to determine the extent of the noise that will be increased at the park. The noise analysis does not consider the wide use of activities by visitors at the park. Specifically, what impacts will occur to overnight visitors at the campgrounds? Or impacts to day-use visitors that walk through the historical district? What are impacts to the numerous special events that take place throughout the year? These questions are not examined in the DEIR. Further noise analysis and testing is required near visitor utilized areas to understand the impact to Allensworth.
Of the mitigation measures suggested in the DEIR, none sufficiently reduce the impact of noise to Allensworth to less than significant. Installing sound barriers is not proposed at Allensworth, which is inappropriate given the unique park characteristics. If sound barriers were constructed, a new modern feature would be introduced that will lead to degradation of the visual character at Allensworth and are therefore not an applicable mitigation measure.
Visual
Both alternatives studied in the DEIR create significant visual impacts.
The Burlington North Santa Fe Alignment Alternative (“BNSF alternative”) track would be located less than 100 feet from the park, introducing a new contemporary and disruptive feature at Allensworth. This is reinforced by the analysis in the DEIR itself, “24-foot-high OCS system components and wires, right-of-way fencing, and high speed rail trains would introduce distinctly modern industrial elements into the visual foreground that would alter the character of the site and lower visual quality” (DEIR, p. 3.16.61).
The Allensworth bypass alignment would position the park between two rail lines and DEIR concludes would be visible at the park. Unfortunately, the DEIR presents only one visual simulation from Allensworth. Additional simulations at other locations at the park, such as the campground or other historical structures, are required to fully analyze the visual impacts to the park.
Public Access
Park entrance
It is unclear whether the BNSF alternative will require the closure and moving of the entrance. The DEIR notes in the Transportation section, “Twenty three of 25 miles of track would be at grade within Tulare County, on the east side of BSNF Railway right-of-way. Elevated segments are at the Tule River and Alpaugh Railroad spur. Local roads would be maintained, avoided, or realigned except for closures of Angola Drive and Palmer Avenue” (DEIR, p. 3.2-50).
Does the closure of Palmer Avenue mean a new park entrance will be created? This is a significant issue that is not sufficient addressed in the DEIR. In the Appendix 2-B railroad crossing, line No 70, Palmer Road is listed as closing. Under line No 71 for Avenue 24, an above road crossing is proposed. This seems to suggest that access to the park will be provided from a southern access entrance. It is unclear why the potential closure of the current public access and creation of a new entrance to the park is only disclosed in a few areas in the DEIR and appears to be hidden. If the primary entrance to the park is moved, numerous questions emerge:
- Will the new entrance impose any new visual or noise degradation to the park?
- When will the permanent closure occur?
- How will the road closure be implemented?
Changes of public access to Allensworth are critical to understand when evaluating the proposed Project. The DEIR is insufficient and unclear on these points.
Construction
Construction of the BNSF alternative will result in public access disturbances and impediments to Allensworth. As noted above, the park entrance is located at Palmer Avenue, which is part of the land that would be acquired as part of the alternative. If the BNSF alternative is selected, it is critical that public access to Allensworth remains accessible. Without the opportunity to review a draft or final plan for construction, CSPF emphasizes that every possible attempt should be made to minimize the overall impact during construction.
Amtrak
The DEIR concludes that when the project comes to fruition, the current Amtrak line that services Allensworth will be adjusted in response to the completion of the proposed Project. It is not clear from the DEIR if the proposed Project will result in the discontinuance of specific rail stops at Allensworth. Transportation planning should seek to maximize, not eliminate public transportation options to outdoor recreation and culturally significant opportunities, and CSPF urges the continuance of park-specific Amtrak service to Allensworth.
DEIR fails to adequately analyze all the proposed alignments
The DEIR presents three alternative alignments in consideration to Allensworth, but only two are analyzed in the environmental review documents. The utilization of the existing corridor with BNSF, and the Allensworth Bypass that would go east of the park are examined as potential alternative alignments of the proposed Project. Another option suggested, but not analyzed, is to relocate the BNSF railway adjacent to the eastern side of the Allensworth Bypass. There is a lack of a full discussion of this alternative. The DEIR reports this alignment has not been discussed with BNSF, but that does not preclude the need to analyze potential impacts from the proposed alternative if mentioned as a possible alternative alignment in the draft document.
