Thank you for this opportunity to comment on the Notice of Preparation (NOP) issued on May 10, 2012, regarding the Environmental Impact Report (EIR) for the Carnegie State Vehicular Recreation Area General Plan and Tesla Expansion Project in Eastern Alameda County.
Greenbelt Alliance is a membership-based, non-profit public benefit organization that has been active in the San Francisco Bay Area for more than fifty years. We work to make the nine-county Bay Area a better place to live by protecting the region’s greenbelt and promoting the development of livable, walkable, transit-oriented communities in the region through public policy development, advocacy, and education.
The NOP indicates that the intention of the Off-Highway Motor Vehicle Recreation (OHMVR) Division of the California Department of Parks and Recreation (CDPR) is to expand the Carnegie State Vehicular Recreation Area (SVRA) into the Alameda-Tesla acquisition land (“Tesla Park”) to extend off highway vehicle (OHV) activities into these currently untouched 3,478 acres of open space.
Greenbelt Alliance is deeply concerned about the proposed expansion and the potentially significant impacts of this action. We also have concerns about the intended structure of the EIR. If OHMVR proceeds with an EIR for this expansion, the following issues deserve particular attention:
Lack of Need for the Project:
It is unclear why the CDPR is pursuing the conversion of Tesla Park from its current condition as a protected natural area into an area for OHV activities. The State Parks Department 2008 Outdoor Recreation Report clearly identifies non-motorized low impact recreation opportunities as top priorities. In a time of fiscal crisis throughout California and particularly within the CDPR, this expansion appears unnecessary and ill-conceived. The EIR should thoroughly demonstrate why this expansion is needed at this time.
Inadequacy of Program Level Environmental Review:
The proposed acquisition lands contrast greatly with the lands already included in the existing SVRA. Tesla Park does not bear the same semblance and characteristics as the lands of the Carnegie SVRA, which has endured decades of erosion, vegetation damage and other environmental degradation from permitted motorized recreation use under State Parks management. Despite past attempts, Tesla Park has never been successfully approved for
motorized vehicle use, and in its current state remains an untouched haven for many native animal and plant species as well as a critical habitat corridor for diverse wildlife.
As such, it would be inappropriate for the EIR of the General Plan Update to study the potential environmental impacts to these two very disparate sites within the same review. A program EIR is not sufficient for this site-specific decision. A project-level EIR analysis specific to the Tesla Park area must be completed before any decision is made regarding the expansion of off-road vehicle use and impacts into the area.
Impacts on Air Quality:
The Global Warming Solutions Act (AB 32) of 2006 mandates that California reduce its greenhouse gas emissions to 1990 levels by 2020. SB 375 of 2008 provides further policy mandates to reduce vehicle miles traveled. The expansion of the motorized trail system into Tesla Park would conflict greatly with the goals and stipulations of AB 32 and SB 375. Allowing off road vehicle activities into Tesla Park will significantly increase the amount of greenhouse
gas emissions generated in the area, as well as the amount of other pollutants released into the air. Many OHVs are equipped with two-stroke engines that do not burn fuel completely and produce contaminants such as nitrogen oxides, carbon monoxide, ozone, and aldehydes in amounts many times greater than those of modern cars. The EIR should thus include an extensive and thorough study of the emissions that would be generated by OHV use in the site
area and include measures to fully mitigate these impacts.
Keep reading Greenbelt Alliance’s comments on the Environmental Impact Report for the Carnegie State Vehicular Recreation Area General Plan and Telsa Expansion Project: Greenbelt Alliance – Carnegie Scoping Comments (PDF)
