by: Friends of Bidwell Park
Re: Comment on Draft Bidwell Park Master Management Plan and Environmental Impact Report (DEIR)
1) Since the report discusses the potential impacts to "Visual Character" shouldn't "Visual Character" be defined in the report, as are scenic vistas, scenic roads and night sky? This is a serious oversight, since it is the natural beauty of Bidwell Park that makes this park stand head-and-shoulders above every other municipal park in California. Surely, "Visual Character" was a primary impetus leading Annie Bidwell to give the land as a park to the City of Chico. For example, in a Chico Daily Record Editorial, July 1, 1905 a quote states that "Mrs. Bidwell's one idea, to preserve this beautiful natural park for the benefit it will work to humanity, believing that such grand scenery, embodying as it does valley and mountains, creek and canyon, trees and vines, cannot but tend to make people more appreciative of nature and therefore better men and woman."
With this sentiment as the genesis of Bidwell Park being donated as public land, a more detailed discussion and analysis of the "visual character" of Bidwell Park is expected, especially since we also believe the aesthetic setting is being significantly compromised by the bootleg disc golf course, the "proposed" projects, and most importantly, by the proposed experimental mitigation measures (e.g., artificial barriers around oak tree trunks, constructed rock barriers, imported mulch, concrete slabs, dying oaks, inevitable multiple parallel trampled trails, raw soil, etc.).
It is difficult to see how the inevitable ongoing impacts and proposed experimental mitigation measures could ever be perceived as "visually compatible" with the natural setting of Upper Park. Perhaps Chico's teachers, artists, photographers, naturalists, biologists, historians, hikers, bikers and others should be queried on their opinions of "Visual Character" as it applies to the bootleg and proposed disc golf course site, and especially, the proposed experimental mitigation measures. Please provide a more accurate and realistic definition of the aesthetic resources (visual and auditory) and impacts to them.
2) This section needs to mention that the proposed Disc golf/trailhead area is a unique site and with the canyon rim accessed there, represents the most spectacular scenery in the entire city of Chico. This is particularly relevant if one considers public access. There is no other site in all of Bidwell Park that combines such grand scenery with such a high degree of public accessibility. People have described the proposed (bootleg) disc golf course site as "Chico's Yosemite". The EIR completely misses this point.
3) Although the DEIR claim that the projects (arguably; see 1 above) may not alter the "scenic vista" as described in the DEIR, they certainly have altered the scene since the bootleg course has started, and will continue (if approved) to degrade the place. How can this be argued? We have watched it happen. Many people have expressed their concern (which is documented extensively in the public record).
4) We strongly disagree with your assessment that the Disc Golf /Trailhead Plan will enhance the visual character of the area. Please describe how the following do not constitute significant negative visual and aesthetic impacts:
a) Pouring over 35 (4' by 12' by 6") concrete pads (32 cubic yards of concrete) built on an otherwise natural geological surface,
b) Placing barriers around the trunks of over 100 oak trees [unfortunately and contrary to what is hoped for, this will not mitigate for the most serious disc-related impacts to the canopy foliage (see arborist report)],
c) Unmitigated ongoing canopy damage and likely death of over 100 centuries-old oak trees (see "b" above),
d) Creating unnatural lines of boulders placed along several thousand feet of trails,
e) Placing several thousand cubic feet of mulch, perhaps annually and indefinitely into the future (replacing native vegetation, fostering establishment and growth of invasive species, e.g., Yellow Star Thistle, and contributing to nutrient enrichment and degradation of water runoff quality),
d) Installing dozens of trash cans and benches, and
e) Paving over the historic Humboldt Road.
5) This particular site is the most unique in the park with regard to viewshed, vista and public accessibility. The aesthetic visual resources here are unparalleled elsewhere in Upper Park, except for those able and willing to trek to the north rim, and even there, the viewshed/vista is not comparable to the oak woodlands, wildflower displays and canyon visible from the south rim at this particular location.
6) Although the DEIR refers to the Disc Golf/Trailhead Area Plan, it never really defines what the project is. We can not determine if the City is proposing 1 course or 2 courses. Are they 12 holes per course or 18? Or is it one with 36 holes?
7) It appears from the conceptual disc golf maps that the City is proposing to build several miles of new trails on the site. These trails are indicated as going through mapped wetlands and Butte County Checkerbloom sub-populations. The DEIR never discusses the proposed trail details (how many miles of new trails are there, where will they go, what resources are impacted from the new trails, what are the construction specifications, how is the city going to mitigate impacts associated with these new trails?). If the term "Trailhead Project" is used in the title, why not describe and analyze them?
8) Shouldn't all new trails be analyzed in the "Trail Plan"?
9) Butte County Checkerbloom (Sidalcea robusta)
As with all other CNPS List 1B species, Butte County Checkerbloom is a candidate for State and or Federal Listing on petition, and is required to be completely accounted and mitigated for during planning and implementation of all proposed projects. The Butte County Checkerbloom plants at the bootleg disc-golf site are actually part of a larger single occurrence that is currently being impacted by multiple contiguous projects, each being analyzed in isolation. The Canyon Oaks Developments, the Trails Plan, and the Disc Golf Course are all impacting the same CNDDB Occurrence (population?). There is no comprehensive analysis of direct, indirect or cumulative effects, nor is there a workable conservation/management/mitigation strategy for this CNDDB Occurrence/population. Is this another example of piecemeal planning (in violation of CEQA) on behalf of the City?
10) White Stem Clarkia (Clarkia gracilis ssp. albicaulis) is also known from the south side of Upper Park and would be impacted by both the trail plan and Disc Golf/Trailhead Plan. Please describe how the plan avoids and minimizes these potential impacts
11) Please describe how the proposed trunk barriers will protect the trees from ongoing damage and eventual death. Anyone who has played or has watched the sport knows that the discs are not only hitting the trunk but also and more importantly, the multiple of limbs and seasonal growing tips throughout the tree canopy. In fact, in some cases, all the limbs on the fairway side are virtually denuded of foliage in just the last few years. While the barriers might protect the toughest and most durable part of the trees (the trunk), the most ecologically sensitive and important part of the trees (growing tips and terminal branches) will remain entirely unprotected and will continue to be impacted. While the mitigation effort is appreciated, it is next to insignificant with regard to being ecologically effective. The arborist reports that these Blue Oaks can only take this abuse for so long. The blue oak mitigation measures are nearly meaningless from the ecological standpoint; how will protecting the most durable part of the tree (trunks) mitigate impacts to the most sensitive parts (canopy and roots)? There are recognized oak tree experts that should be brought into this discussion.
12) Since the DEIR never describes what material or design will be used for the barriers, it is impossible to determine if a) they will be effective, b) they won't be ugly and therefore have aesthetic impacts on the visual character of this scenic area (see comments above), c) won't negatively impact nesting and foraging birds.
13) Please discuss more clearly the details of implementing the proposed mitigation measures to address impacts to the soil (compaction and erosion) as well as the potential negative environmental effects of the proposed mitigation for soil compaction/erosion (isolated concrete pads and tons of mulch added in perpetuity).
14) What are the total feet (miles) of trails associated with the Disc Golf course (please account for the inevitable parallel routes)?
15) How many feet of boulders will need to be installed to delineate the fairways? What will keep people within these "boulder-lined paths" when they retrieve their inevitabley errant disks?
16) Where will these boulders come from? If they are from the site, what impacts will this cause? If from another site, where?
17) How will the boulders be placed? Will the City use tractors or other motorized vehicles to transport and place them? Will access routes need to be constructed/rehabilitated? Will there be soil/hydrology/season readiness criteria?
18) Since the vast majority of discs do not land within the fairway, how will the areas outside the "boulder-lined delineated fairways" be protected from impacts? This is a serious point of contention since the nature of disturbances relating to disc golf are by default completely different from all other forms of recreation. Hikers and bikers almost always stay on a single trail, and with exception to exceptionally rare and serious accidents, they do not impact oak tree trunks, and never, ever do they impact oak canopies. There has never been a recreation-related disturbance regime equating to what we see from disc golf. Even cattle only hit a site temporarily and move on once forage is taken advantage of. On these Tuscan Volcanic surfaces, livestock leave 10 out of 12 months for the site to rejuvenate. Carrying capacity of the limited forage and grazing behavior precludes further impacts. Contrary to what a few vocal disc golf proponents claim, there is no historic or existing land use with similar ecological impacts.
19) What is the precedent of using imported mulch as mitigation for impacts to soil compaction/erosion in Blue Oak Woodlands/Savannah and Volcanic Annual Grassland elsewhere in California? Is there any precedent, or is this purely experimental?
20) Please quantify the amount of mulch needed to protect the soil, how will its condition be monitored; what thresholds are established for reapplication? How frequently will it be reapplied? How will effectiveness be monitored/determined?
21) How will the mulch be certified "weed free"?
22) Where exactly will the mulch be needed? There already is extensive erosion/compaction around the tees, around the benches, around the tone poles and throughout the fairways.
23) How will this mulch be installed? Will motorized vehicles be used?
24) How will ongoing mulching and monitoring be funded?
25) What are potential impacts from the experimental mulch application to native biodiversity and water quality? This artificial tonnage represents a significant nutrient-pollutant loading on the site. This will foster the establishment and growth of non-native invasive species, including but not limited to Yellow Star Thistle, Wall Barley, Prickly Lettuce, and Medusahead grass. On these volcanic soils, the greatest native plant diversity is associated with the thinnest and least productive of soils. The greatest invasive weed cover is associated with deeper, more nutrient-rich soils. Addition of this mulch in perpetuity represents a major source of nutrient enrichment (pollution) that will significantly alter the floristic composition, and the "Nutrient Tea" from runoff will inevitably wind up in Big Chico Creek. How will this unnatural, unprecedented and significant nutrient loading affect the volcanic grassland vegetation and ecology of the uplands and the aquatic community of Big Chico Creek through decades/centuries?
26) How will application of mulch in-perpetuity affect the impressive biodiversity of "thin-soil- adapted" plant species that comprise the brilliant native floral displays?
27) How will application of mulch in-perpetuity affect the well-being of "thin-soil-adapted" rare plant species (e.g., Bidwell's Knotweed, Butte County Checkerbloom)? This mulch application and mulch decomposition through the decades has great potential to completely alter the ecology of the site, both for terrestrial and downslope aquatic systems.
28) What are the fire hazards of all this mulch? There are already thousands of cigarette butts on the site, so it's fairly obvious that the City is incapable of enforcing the established May- November "no smoking rules" for the now unauthorized use at this location. Will accumulated mulch represent an unnatural fire hazard?
29) Since the soils are so shallow, aren't the root zones for the Blue Oak trees much larger than the drip line? Authorities on oak tree ecology report that the rooting zone can be as much as 3- times the areas of the canopy drip-line.
30) All of the proposed mitigation measures for soil and Blue Oaks described in the EIR are highly experimental, questionable in effectiveness, ecologically/aesthetically degrading, and represent significant impacts in themselves, yet there are no mentions of these predictable problems and potential uncertainties.
31) Why should we assume that placement of concrete pads will force disc golfers to voluntarily confine themselves to them? It seems absurd to assume that placement of concrete pads at "throwing locations" will result in people voluntarily restricting themselves to use them exclusively. Is it realistic to expect disc golfers to be crowding themselves together on these pads while one person after another throws, then they all walk single file on a single trail to the next concrete pad? More likely, there will be permanent concrete pads built, which will be surrounded by a halo of the same significant soil disturbances we already see at the throwing sites now, and a complex network of multiple parallel trails will remain/develop to connect the concrete pads and tone-poles. Why should we assume different? Will the placement of boulders along a single route between concrete pads keep disc golfers from leaving the "single pad-trail-route" to retrieve errant discs?
32) What will be the source of the Mulch? Sometimes commercially available mulch is made from things like shredded Christmas Trees, forest waste, landscaping waste, scrap wood materials, etc., and in itself is biologically toxic, at least until it's completely decomposed. What will be the quality control criteria of the mulch applied to this natural ecologically sensitive soil-plant ecosystem?
33) There is a once-beautiful and unique seep-wetland complex on the rocky outcrop towards the south end of the course. This has been severely degraded over the last few years. Hansen's Spikemoss (a slow-growing and long-lived species) was once lush and thick. It has been almost entirely replaced by barren rock, and much of the thin soil held by the spikemoss and virtually all of the geophyte species once there are now gone. This site continues to degrade. You do not mention permanent degradation already underway and ongoing under the "bootleg" setting (again a problem with inappropriately defined "existing conditions").
34) What are the direct, indirect and cumulative impacts to these unique or otherwise sensitive natural resources (Vernal Pool, Wildflower Fields, Blue Oak Woodland and Savannah, Rare Plant Populations, Sensitive Soils, Aquatic Ecosystems) that are already happening and which will continue under the "E5.2.5.3-No-Project Alternative"? The natural setting cannot continue to endure the abuse without further significant degradation/impacts.
35) Direct, indirect and cumulative impacts of all project alternatives need to be completely described in detail as they relate to all potentially sensitive natural resources so an informed decision can be made.
36) Why are the citizens of Chico forced to consider a 36-hole Golf course, when almost all other disc golf courses in the western U.S. are 18 holes? Hopefully the 36-hole proposal has more to do with analysis/demonstrated needs than a designer's personal vision/ego. Two 18-hole courses are still a single 36-hole project in this analysis. Anything else is an attempt to piecemeal the projects in violation of CEQA.
37) Will the course be handicapped accessible?
38) As an intensive recreation development, is the facility required by law to be handicapped accessible? If so how will the parking area, the bathroom, the trails and the entire course comply, if it is to be considered as a publicly funded intensive recreation development?
39) Where is the economic analysis of the proposed disc golf courses? Implementation of the proposed project will be expensive enough, but in the long term it will require a significant and as yet undetermined long-term investment of public resources. What will be the cost of this course after construction. If in 10 years, gasoline will be $6.00+ a gallon (as it is reasonable to assume) what will be the cumulative costs of maintenance and use? This consideration of long-term sustainability alone is a serious economic factor that is totally unaddressed. Where is the economic analysis? Perhaps a course at lower elevation and one accessible by pedestrians and bicyclists in- town would be a better alternative from purely an economic standpoint.
40) Where are the proposed alternatives? Friends of Bidwell Park and others have suggested a number of alternative sites situated nearer to downtown Chico that would be accessible to all people of all ages and transportation capabilities, and in the long run would be eminently sustainable in comparison. Why are there no sustainable alternative sites proposed? There is no cost-benefit analysis that measures short-term and long-term expenses relative to location. One argument against locating the site closer to the town of Chico and at lower elevation has been the cost of land, but if the true costs are considered over a few decades, an initially more expensive land purchase closer to town will be offset by long-term lower costs of maintenance and lower costs for commute relative to the current bootleg-proposed site. This seems to be a very pragmatic argument in favor of constructing a disc golf course closer to downtown where all people of all age groups can more readily benefit from the sport, in perpetuity. This is a simple cost-benefit- sustainability analysis…where is it?
41) How will 32 cubic yards of concrete (4'x12'x 0.5'x 36 pads) be brought onto the site for construction of the throw-pads? Will the concrete pads need to be rebar-reinforced? Thirty-two yards of concrete (at 4,000lb per yard) amounts to about 128,000 lbs. (64 tons). At about one hundred 60lb dry-sacks required per 1.85 cubic yard of concrete, 1,730 sixty-lb sacks (~60 tons) will be required for transportation. At ~6 gallons of mix water per sack and 1,730 sacks required, there will be 10,380 gallons of mix water needed (86,673 lbs of water). A significant additional amount of water will be needed for cleanup. So, we are led to believe that disc golf volunteers will bring in at least 43+ tons of water and 60 tons of concrete (103+ tons) by hand? Disc golf proponents claim that they will transport and mix by hand…is this realistic? If not done by volunteers and by hand, then by whom and at what cost? There are also temperature minima and maxima for concrete setting (37-90 degrees F), so there is a seasonal window for this as well, which is not specified. Over what period of time will this volunteer construction take place? Are there any cement masons among the disc golf volunteers? Or, again is this another example of wishful thinking?
42) When the concrete is brought in by hand, how will it be mixed, where will the mix-water come from, where will waste concrete and wash water be disposed of, and where will the delivery equipment and finishing tools be cleaned? All of these construction related activities have great potential to permanently degrade the ecologically sensitive site. Who will inspect the concrete- finishing for quality control? Will the volunteer-constructed concrete be of the same quality workmanship as the volunteer-constructed benches?
43) Concrete pads are not a good idea for too many reasons. Most importantly, there will be no impetus for users to confine themselves to them and soil impacts in the halo around them will be at least as severe as they are without concrete pads. And, as the site continues to degrade and ancient oak tree "obstacles" die (see comments pertaining to inadequate oak tree protection), the permanent pads will likely be abandoned as players adjust for more "challenging" throw- spots/fairways.
44) These concrete pads, along with the in-perpetuity-applied mulch, ineffective oak tree- trunk cages, and trailside boulder-lines are not realistic mitigation measures; it is wishful thinking. In fact, it is easy to see that these mitigation measures in themselves represent significant aesthetic and ecological impacts with little provable benefit.
45) The proposed mitigation measures are potentially at least as aesthetically intrusive and ecologically degrading as the unmitigated bootleg-disc golf course-use, only more permanent.
46) These proposed measures convey a false sense of accountability (all of these measures are highly experimental), and as the EIR is written, there are no monitoring requirements, monitoring/reporting schedules, success criteria, nor remedial requirements.
47) This is a very poorly defined project with inadequate/experimental/damaging mitigation, an open end, and no long-term accountability.
48) Will the now-illegal course(s) be closed until construction is complete? If not, then why not?
49) How many benches will be installed? What are the potential impacts (erosion/compaction)? The existing illegally installed benches all have bare soil, broken glass and hundreds of cigarette butts around them, so it seems logical to assume that the new bench areas will have the same impacts. Will these heavily impacted areas require mulch too?
50) The DEIR fails to discuss the direct, indirect and cumulative impacts to the historic Humboldt Road. Including the portions that are impacted from the courses itself (not just the portion being paved over for the parking area).
51) Will there be trash cans installed on the course(s)? If so, how many and where will they be installed? How often will there be trash service to the site and how will this be funded?
52) How often will the toilets be serviced and how will this be funded?
53) Will there be drinking fountains?
54) Doesn't CEQA require complete analysis of alternatives, including previous proposed alternative sites? Since the City is proposing a Disc Golf course in Hooker Oak Recreation Area in Bidwell Park, shouldn't this be analyzed as a project too (or as an alternative)? Won't this be piece- mealing projects if it is not included?
56) Will there be local tournaments? If so, how often would they occur? How many people will be using the course then? What are the potential impacts? What additional mitigation will be required?
57) Will there be regional tournaments? If so, how often would they occur? How many people will be using the course then? What are the potential impacts? What additional mitigation will be required?
58) Will there be state tournaments? If so, how often would they occur? How many people will be using the course then? What are the potential impacts? What additional mitigation will be required?
59) Will there be national tournaments? If so, how often would they occur? How many people will be using the course then? What are the potential impacts? What additional mitigation will be required?
60) What are the impacts to wildlife from Disc Golf activity? There is no mention of how the continuous damage to the oak trees affects nesting birds and foraging birds directly, indirectly and cumulatively. Nor is there discussion of how the players may impact wildlife (i.e. noise disturbance).
61) Shouldn't there be a discussion of impacts to species using the cliffs for habitat? Since several holes on the proposed long course are adjacent to cliffs, discs routinely land over the sides requiring golfers to climb down to retrieve them. This has impacts on nesting birds and bats (including special-status species). The DEIR should discuss how the course design avoids, minimizes and mitigates for these impacts.
62) If a golfer falls off a cliff retrieving a disc (as they have in the past), will the City pay for the rescue?