(408) 427-4863

November 25 1998

S. Ted Lopez
City of Santa Cruz
Public Works Department
809 Center Street
Santa Cruz, CA 95060

Subject: SCH #98102080, Broadway-Brommer Street Bicycle/Pedestrian Path Connection, Notice Of Preparation for Environmental Impact Report (EIR)

Dear Mr. Lopez:

Thank you for submitting the Notice of Preparation for an Environmental Impact Report for the Broadway Brommer Bicycle Pedestrian Path. Commission staff strongly supports the provision of non automobile circulation and public access enhancement as specified by Coastal Act Section 30252. At the same time, Commission staff also agrees with the City's conclusion that the significant open space and habitat resources of the Arana Gulch greenbelt as well as the great public interest warrant the more inclusive review of an EIR to assure apropriate levels, type and location of access.

The Initial Study/NOP lists the issue areas that will need to be evaluated for the two routes identified in the EIR. Two broader concerns are the lack of a specific plan for Arana Gulch and the question of whether other alternatives which may be viable and less environmentally damaging have been omitted from consideration.

We suggest that a preferred planning approach would be to prepare the specific plan for the Arana Gulch greenbelt as cited in the City's General Plan Land Use Policy 2.2.7 and include consideration of a Broadway Brommer Bicycle Pedestrian Path. Planning in this context would address the combined impacts of the potential development of a school, playing fields, residences, and the Broadway Brommer Path. Cumulatively these potential developments could affect maintenance of habitat and open space in a manner unanticipated by the bike path alone and. might affect conclusions on the appropriate alignment.

Second is the question of whether the two alternatives to be reviewed are the only possible alternatives for improving east-west travel or whether there are other less environmentally damaging routes. The City has already evaluated several alternatives. For the benefit of an informed public and informed decision making, we would recommend that the EIR provide an historical review of previously considered alternatives to the degree necessary to verify that their impacts are not less environmentally damaging than the two routes proposed. In addition, we would recommend that EIR consider routes that do not impact the Arana Gulch greenbelt such as (a) the Soquel Avenue corridor (including the current experiment) and other possible improvements; (b) better bike lanes and connecting segments on Murray/Eaton; (c) the SPRR railroad right-of-way. Finally, the Commission has received information from the public recommending other alignments not yet considered (to our knowledge) by the City including a Mello Lane to Frederick Street Park bridge.

Almost all possible alternatives would require some level of regulatory review by the Coastal Commission. For example, the two development alternatives to be addressed in the EIR cross a portion of the the Arana Gulch greenbelt which is located in the Commission's original jurisdiction. In addition to the coastal development permit that the City will need to issue for the project in their jurisdiction, the Commission will be responsible for processing a coastal development permit for that part of the development within this original jurisdiction area.. We believe it is in the interest of the City and the Commission for the public's concerns to be addressed as completely as can reasonably be done in the environmental review stage of the process. This approach would facilitate the Commission's review of the City's final decision on the route, as well as the Commission's own permitting process.

Thank you for your consideration. If you have any questions, please call Dan Carl of our staff.

Charles Lester
District Manager

cc:Antero Rivasplata, SCH
Eileen Fogarty, Planning Director
Ken Thomas, Principal Planner

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Last updated 9/13/04