by: Friends of Bidwell Park
Re: Comment on Draft Bidwell Park Master Management Plan and Environmental Impact Report
Friends of Bidwell Park is in agreement with the observations about the lack of trail definition in the Horseshoe Lake area, which not only has led to degradation of the area but also causes user conflicts between equestrians and lake/observatory users (i.e. horse manure on the path next to the Observatory). Providing an all-weather trail that bypasses the lake/observatory path will alleviate this problem. We think that the area immediately adjacent to Horseshoe Lake and the Observatory, two of Upper Park's most popular visitor destinations, would benefit from improvements in invasive plant control, signage and possibly parking capacity. Since this area is within the setting of Upper Park, we also want this it to maintain its natural grassland appearance, as much as possible, rather than have the manicured lawns and high-maintenance costs associated with the Bidwell Park Golf Course, One Mile Recreation Area and Five Mile Recreation Area. Based on the 'Concept Plan' which provides the only detail about project, it appears that a drastic makeover of the Horseshoe Lake area is being proposed.
Since the Horseshoe Lake project area was not specifically delineated by a map, for purposes of these comments, we are assuming that it is the area bounded by Parking lot B on the west, Upper Park Road on the south, Monkey Face on the east and the unnamed trail that's on the southern edge of the north rim.
Appendix F pages F-1 through F-5
1. As described on page 2-2, the water level in Horseshoe Lake varies a great deal seasonally. In the dry season, extra water is pumped in from a golf course well to maintain a minimum level. In the rainy season, water percolates down from the hillside to the north and fills the lake to its maximum capacity. When it's reached capacity, an overflow culvert moves excess water across the road and ultimately into Big Chico Creek.
Related to this seasonal fluctuation in water level, would implementation of this plan keep the lake at a specific level year-round? If it would, how much water would need to be pumped in to maintain this level versus how much is pumped in now to maintain a minimum level? Who would pay for pumping this water and how much would the pumping cost? If there would still be fluctuations in the water level, where would the paths and plantings be sited in order to avoid being flooded in winter? Please define the current seasonal fluctuation in size with maps showing the maximum and minimum lake size as well as the size of the lake in the proposed project.
2. Would the perimeter trail be ADA accessible? Which trails or portions of trails within the project area would be ADA accessible?
3. Any time that infrastructure (trails, trash cans, benches, etc.) or landscaping is added to the park, there are increased maintenance costs. Who will pay for the additional maintenance costs associated with these improvements?
4. Exactly how would the B and C parking lots be expanded? Please provide a map showing the current footprints of the parking lots and the footprints of the expanded lots. Have you consulted a soil scientist or hydrologist to determine how expanding these lots might affect the seasonal drainages in these areas?
5. Has the city ever had a successful Upper Park revegetation project that involved planting in areas that weren't directly adjacent to a creek? How many failed revegetation projects have there been in Upper Park? Who would be responsible for the watering needed to keep these plants alive for the first few years?
6. In the third paragraph is the sentence "Access to Monkey Face has been consolidated at the northeast corner of the Lake." Do you mean by this statement that all of the unofficial trails that lead to Monkey Face from parking lot #E will be closed and revegetated and that access will be only via the Maidu Trail as the map on page F3 and Exhibit E3.2.1.2 implies? If so, as experienced trail maintenance volunteers in the park, we believe this is extremely unlikely to be successful. No matter how many signs and fences you install, many hikers will not be willing to use a trail that does not appear to lead to their destination (namely, Monkey Face). Please provide details about the routing of this trail to Monkey Face. Also provide details about what you plan to do at the top of Monkey Face to prevent hikers from taking a shortcut back down to the parking lots.
Also, it will be very difficult to do any revegetation of the many trails that now scar the Monkey Face area because there is almost no topsoil there, there's no way to water any plants that put in, and there's little existing vegetation to provide shade for new plants that will get the hot afternoon sun. Please describe the restoration plan for this area.
7. Please show the Observatory's outdoor seating area in any future maps.
8. In 2002, several of us spent quite a few hours picking up fishing line, hooks and sinkers during the time period when the water level in the lake was drawn down in order to build the fishing pier. Many trees and shrubs near the lake had fishing line tangled in them. Your plan shows a significant number of new trees being planted by the lake. How do you plan to educate the public that they shouldn't cast a line near an obstacle and that they should retrieve their tangled line instead of just abandoning it?
9. Have you consulted a soil scientist regarding the location of the proposed trail from the north edge of Parking Lot B to Lot C? If it is in the same location as the current unofficial trail, in the western part of this trail, it goes through the low point in the meadow and has several small vernal pools immediately adjacent to the trail. How much of this area is a wetland in the winter?
10. Part of the trail that is next to Upper Park Road from the entrance to Parking Lot B, which intersects the trail described in 9 appears to be an existing unofficial trail at its western end and a new trail at the eastern end. What's the length of the new section? If the eastern portion is located where it appears to be from the map, it will be in an area that's very wet in winter.
11. Since 4 ADA parking spaces will be created at Parking Lot B, presumably there will be ADA access to new facilities there (restroom, picnic area) that are also ADA accessible? Please explain what trail surfaces will be used to make these facilities accessible, i.e. concrete, crushed gravel.
12. The Concept Plan map is inaccurate in its portrayal of the Blue Oak Trail location. Does this mean that the Blue Oak Trail will be moved or that an additional trail will be built to join the Middle and Upper Trail? It's difficult to tell from this map or from the map in Appendix E, Exhibit 2 exactly which trails are being kept, which are being closed and which are being moved. On future maps, please include this information by differentiating between official and unofficial trails and use the map of existing trails as the basis for the map, rather than an artist's rendering of where trails might be.
13. How many feet of new trails would be created if this plan was implemented? How many feet of existing unofficial trails would be closed and revegetated?
14. In the general area of Parking lot B, there is currently only one tree. The concept plan shows numerous trees. Have you consulted a soil scientist to determine why there aren't more trees there now and whether this is a suitable location for trees to thrive?
15. The Neg Dec for the Observatory originally had a requirement for landscaping, but this was removed in the final draft of the Mitigated Neg Dec. Since this requirement was apparently considered too onerous or impractical to implement, what conditions have changed in the general area to make this area suitable for landscaping? Have specialists (e.g. soil scientist, ecologist) been consulted as to the feasibility of planting trees in this area?
16. Where are the traffic studies that indicate a need for parking lot expansions? Besides the Hooked on Fishing, Not on Drugs day and a few Observatory celestial events, how often would these parking lots fill to capacity? For these major events, no amount of on-site parking would be adequate. If the Observatory management has requested an expansion and provided documentation regarding the need for additional parking on a regular basis, that would constitute a reasonable basis for considering expansion. Otherwise, where's the need?
Impacts AES-1b: Alteration of Scenic Vistas with implementation of Park Improvements Project (page E4-8)
We believe that to alter the natural setting of Horseshoe Lake as drastically as appears to be proposed will significantly impact the ecological and aesthetic resources of the area. These impacts will be compounded if the proposed landscaping is not successful and the park ends up with a permanently disturbed-failed planting area. Just consider the dismal failure of mitigation at the Municipal Golf Course just across the road on deeper and more easily planted soils. Virtually none of the blue oaks planted as part of that mitigation have survived and a second oak tree planting also failed. It's now just a patch of weeds.
Regarding implementation of mitigations for Bidwell Park, the City of Chico does not have a good track record. The failed mitigation efforts at the adjacent municipal golf course and failure on the City's behalf to uphold viewshed mitigations for the Canyon Oaks development are both testimony to their "cut-and-run" impact-mitigation ethic. Even within this project area, a minor required mitigation was never implemented. The portable toilet at the Observatory parking lot was supposed to be surrounded by a wooden fence as one of the mitigations when the Observatory was built (and it may have again included as a mitigation when the outdoor seating area was added). There is still no screening fence around this portable toilet. Likewise, the first blue oak planting at Parking lot E failed and was replanted a few months ago. Will there be a third and fourth planting if these trees don't thrive?
There are not trees around Horseshoe Lake currently because the thin soil and lack of hydrology preclude their natural establishment and growth. What will be different as part of the City's proposed actions? Will there be an irrigation system installed? If so where will the water come from? If not, how is it expected to support a plant community that currently cannot be naturally maintained?
How will the city ensure that these plans will succeed considering natural site potential and past failures nearby? And, if things don't establish as planned, what will be the monitoring protocol, monitoring frequency, monitoring timeline, thresholds of success and required remedial measures? Where is the assurance; or at least the definition of process that should assure us of follow-through, monitoring and remediation obligations?
Impact Bio-1c: Adverse Effects of the Trails Plan and Horseshoe Lake Area Concept Plan (page E4-55) and Impact Bio-6 Fragmentation of Wildlife Habitat (page E4-84)
The proposed Monkey Face trail as a branch to the east from the first switchback of the Maidu Trail (as shown in Exhibit E3.2.1.2) is in an area of dense, native vegetation (including several listed plant species), crosses numerous seasonal drainages, and currently provides undisturbed habitat for many wildlife species (including a coyote den). When this proposed trail routing was discussed years ago at trail planning public meetings, there was almost universal condemnation of the proposed route by the members of the public who participated in this series of meetings. Not only would it open up a previously undisturbed area of the park to impacts but it would be very difficult to maintain due to the amount of vegetation along the proposed route. Friends of Bidwell Park strongly opposes the development of a new trail in this area. T here are several much more suitable locations for a trail that would access Monkey Face from the east via Upper Trail, where there have already been significant impacts to the vegetation and soil. Also, as mentioned in item 6 of the MMP comments, an easterly routing would be much more likely to be used by hikers since it would appear to provide more direct access to the top of Monkey Face.
Impact Bio-3e Adverse Effects of Park Improvement Projects on Northern Volcanic Mudflow Vernal Pools (page E4-80)
There are several vernal pools in the meadow area between Parking Lot B and C, where trail construction is proposed. The EIR fails to provide a map of Middle Park's vernal pools or discuss the possible impacts to vernal pool special species from the construction of several trails in this area.