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°
CALIFORNIA
tober 31, 20
STATE PARKS October 31, 2005
FOUNDATION Mehdi Morshed, Executive Director i
The Voice for California High Speed Rail Authority
California’s 925 L Street, Suite 1425
State Parks Sacramento, CA 95814
ai sonnson Joseph Boardman, Administrator
Crarmon Federal Railroad Administration
Penne U.S. Department of Transportation
Say BOSASOS 1120 Vermont Ave., N.W. M/S 20
JOHY HARRINGTON Washington, D.C. 20590
neon Dear Messrs. Morshed and Boardman,
senay FONE

Charman Emons

On behalf of the California State Parks Foundation and our 65,000 members
statewide, I am writing to comment on the final Environmental Impact

2OARD OF TRUSTEES
PAMELA A BASS

HOWARO H BELL Report/Environmental Impact Statement (EIR/EIS) of the California High Speed

Samy noenions Rail Authority (HSRA).

ww EL.OT BROWNLEE

Wan £ CARE JR The California State Parks Foundation is the only statewide non-profit

eee wy membership organization dedicated to protecting, enhancing and advocating for

AUSON EWOT California’s 278 natural, cultural and historic state parks. Through programs

mune SADA that help restore park properties, educate teachers and students about

ee eee environmental resources in parks, built volunteerism and stewardship in our

JOHN HARQNGION state parks, and promote sound public policy, we work to protect countless

eee emston natural, cultural and historical treasures found within our parks, as well as the

EURABEIN A. LAKE 280 miles of coastline, 625 miles of lake and river frontage, 18,000 campsites

ANB. LW "BLL LANE. JR and 3,000 miles of hiking, biking and equestrian trails. On behalf of our

ne members, we are committed to ensuring that state parks continue to provide

tad E Leta recreation, adventure, renewal, and inspiration to all Californians.

FeOBERE € PATTERSON

aoe ale nocmenct se We appreciate the HSRA staff's and board members’ attention to issues relating

ROGER SCHIM to potentially significant impacts on state parks. Specifically, the commitments

crewate. to avoid transecting Henry W. Coe State Park, study additional alternatives to
the Bay Area routes, and the decision to allow further study on the Burbank to

apvisony TausTEEs Union Station corridor, in order to minimize potentially significant impacts to

ee Rio de Los Angeles State Park (formerly known as Taylor Yard) and Los

CAROLYN DEVINNY Angeles State Historic Park (formerly known as Cornfield), address two

ee ea important issues we raised during the comment period on the draft EIR/EIS. As

vaca nape further study and analysis progresses on potential options for a mountain

\WILUAM RANDOLPH HEARST. crossing alignment, however, we urge the Authority to continue its commitment

eee to avoiding Henry W. Coe State Park as well as other state parks in the affected

vai NICHOLS region. With respect to the further study on the Burbank to Union Station

wabanocem sen

tax 8. SMT

veowse, HEADQUARTERS 800 College Ave., P.O. Box 548, Kentfield, CA 94914 TEL 415-258-9975 FAX 415-258-9930

SOUTHERN CALIFORNIA OFFICE 3250 Wiishire Blvd.. Suite 2003, Los Angeles, CA 90010 TEL 213-380-9980 FAX 213-380-9987
Bimcnsree EMAIL Colpark@calparks.o1g WEBSITE www.calparks.org


10/31/2005 16:12 FAX 9163220827 CA HIGH-SPEED RAIL (H003/004

High Speed Rail Authority
Response to Final EIR/EIS
October 31, 2005

corridor, we encourage the HSRA to establish an official Advisory Committee similar to that
proposed for the Bay Area study. This new committee should include community members, ~
local transportation and engineering experts, representatives of the Department of Parks and
Recreation and others to provide community input and transparency in studying that segment.

However, we believe the final EIR/EIS, overall, remains inadequate in its response to potentially -
significant park impacts and inappropriately defers critical analysis for land management, habitat
preservation, cultural and biological resource management and noise and visual impacts to future
project-level analysis. While we appreciate that the final EIR/EIS appears to narrow its focus on
park impacts to five parks specifically identified as within 900 feet of preferred High Speed
Train (HST) alignments, the lack of specificity regarding the issues identified above causes
concerns about the scope of additional park units that may be indirectly impacted by the HST.
This final EIR/EIS establishes the parameters for future analysis and sets a framework for the
work of multiple, segment-specific project EIR/EIS documents. As such, it is imperative that
this final EIR/EIS contain specificity appropriate to avoiding, minimizing or mitigating the
potentially significant impacts of selected and suggested alignments of the proposed HST.
Examples of responses that inadequately respond to our concerns include, but are not limited to,
the following: .

With respect to Response ASO051-1, we respectfully disagree that use of existing rail corridors
for HST operations is not expected to greatly alter the environmental effects of these existing rail:
lines. The parks near or adjacent to rail lines experience use of light rail and low-speed Amtrak,
as well as some freight train use. Addition of HST operations in the vicinity of these existing
services is not simply an adjunct. The speed, velocity, and noise of HST, even at lower than full
speeds, creates potentially significant impacts that do not currently exist with the current rail °
services. Visitors to state parks, even in urban environments, are entitled te an experience that
recreates historic atmospheres, provides a refuge from urban life, and creates a connection with
biological and cultural resources. As such, the addition of HST in areas-where existing rail
corridors are in use near state parks does warrant additional analysis of potentially significant
impacts and avoidance or mitigation strategies. A revised analysis must be prepared to address
these potentially significant impacts for each park near or adjacent to a proposed HST operation.

We disagree with Response ASO051-3, which states that it is premature at this level of design to
develop more specific mitigation measures for potential effects. The alignment proposals in the
final EIR/EIS essentially predetermine the scope of future analysis. By deferring more specific
environmental review, including developing of mitigation measures, to future project-level
design, the final EIR/EIS prevents a full analysis of whether all opportunities for park avoidance
have, in fact, been pursued, and whether mitigation measures would be effective in addressing
inevitable park impacts. We-continue to have strong concerns regarding potentially significant
visual and noise impacts in state parks resulting from HST. The uncertainty regarding mitigation
measures that would be pursued to alleviate those impacts contributes to our position that the
final EIR/EIS is deficient in its response to potentially significant park impacts and fails to


10/31/2005 16:13 FAX 9163220827 CA HIGH-SPEED RAIL oo4/004

High Speed Rail Authority
Response to Final EIR/EIS
October 3}, 2005

document that these impacts will be less than significant with or without mitigation. Again, a
revised analysis must be prepared to address these additional potentially significant impacts.

We are concemed that significant funding is already being considered for additional planning
(Senaté Bill 1024 [California State Senate, 2005]; Safe, Reliable High-Speed Passenger Train
Bond Act [Secretary of State’s Office, prepared for November 2006 election]) at a time when the
final EIR/EIS contains important gaps that prevent a full analysis of the 700-mile HST project. _
At this time, we do not believe that sufficient information has been disclosed that would lead to a
thorough assessment of the proposed project, particularly as it relates to potentially significant
impacts on state parks.

As the HRT process advances, we will be monitoring the various segment considerations and

- will continue to voice our concerns regarding the areas identified above. We urge the HSRA to
develop and make available a process that will resolve the issues identified here prior to formal
initiation of the project-level EIR/EIS work. We look forward to an opportunity to work together
in that regard and appreciate your continued diligence to the stated intention to avoid potentially
significant impacts on park and recreational resources.

Sincerely,

Elizabeth Goldstein

ce: Ruth Coleman, Director, California Department of Parks and Recreation