TRAC. March 2, Mayor Gayle McLaughlin and City Councilors City of Richmond P.O. Box 4046 Richmond, CA 94804

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1 TRAC Trails for Richmond Action Committee 73 Belvedere Avenue Richmond, CA Phone/Fax March 2, 2011 Mayor Gayle McLaughlin and City Councilors City of Richmond P.O. Box 4046 Richmond, CA Dear Mayor McLaughlin and City Councilors: With regard to the FEIR for Point Molate Mixed-Use Tribal Destination Resort and Casino Project, the Trails for Richmond Action Committee requests that the City Council clarify and strengthen Transportation Demand Management Mitigation Measure (MM) 3-20 i. on page 5-16 as follows: Prior to the beginning of construction of the Proposed Project, the Tribe shall place in escrow its fair share contribution representing 97 per cent of the cost for designing, permitting and building the planned San Francisco Bay Trail connection between the southern property boundary at Point Molate Beach and the bus stop at Castro Street and Tewksbury Avenue. As detailed in Attachment A, the FEIR s mitigation measures for reducing traffic and criteria pollutant emissions from motor vehicles assume that there will be a bicycle and pedestrian connection between the project site and the community, e.g. the Tribe is required to provide and fully fund: showers and lockers for employees bicycling or walking to work; ample covered bicycle parking at commercial areas and parks; and secure. weather protected bicycle parking for employees. However, there are no pedestrian or safe bicycling connections between the southern project boundary at Point Molate Beach and the bus stop at Castro St. and Tewksbury Ave. for both AC and Golden Gate transit companies. It is impossible to walk between City of Richmond residential areas and Point Molate. Bicyclists must ride on side of the freeway, which is very hazardous as demonstrated when a motorist veered out of the vehicle lane on I-580 killing one bicyclist and severely paralyzing another. FEIR Response I4-3 dismisses this dangerous situation with the callous comment that... the current configuration is not ideal. MM 3-18 g. for criteria air pollutants states (emphasis added) The Proposed Project would be located within one-half mile of an existing/planned Class I or Class II bike lane and promises that a one per cent reduction in criteria pollutants would occur with the implementation of this mitigation measure apparently even in the absence of a completed Bay Trail connection with the community.

2 Vague and unenforceable MItigation Measures in the FEIR attempt to paper over this situation with nebulous conditions such as (emphasis added): MM 3-17 e. The Tribe shall provide and fully fund sidewalks and/or paths, connected to adjacent land uses, transit stops, and/or community-wide network. MM 3-17 h. The Tribe shall provide and fully fund safe, attractive pedestrian access from project to transit stops and adjacent developments. MM 3-20 i. The Tribe shall assist in funding the improvements necessary to connect the Bay Trail south of I-580 to the proposed segment north of the freeway. Clear, enforceable mitigation measures are needed to ensure that there will be a Bay Trail connection with the community at the time that the project begins operation in order to implement required Air Quality mitigation measures, as well as to help mitigate Cumulative Significant and Unavoidable Transportation impacts on nearby roads and intersections. This Bay Trail connection comprises the following two sections: 1. South of I-580 from the combined Golden Gate and AC Transit bus stop at Castro Street and Tewksbury Avenue to the existing trail under the Richmond/San Rafael Bridge and 2. from the north side of the trail under the bridge along the shoreline to the southern border of the project site at Point Molate Beach. Construction of these trail sections is feasible once funding is provided. Chevron has committed to provide easements across its property for construction and operation of both trail segments. The City of Richmond has retained Questa Engineering to prepare construction documents for closure of the first Bay Trail gap south of I-580 connecting with the existing trail under the Richmond/San Rafael Bridge, and East Bay Regional Park District (EBRPD) is working with Chevron to define the easement for the Bay Trail north from the I-580 corridor to Point Molate Beach in accordance with EBRPD s Master Plan. Based upon the Attachment B recent Engineer s Cost Estimate and escalation of costs in ABAG s September 2005 San Francisco Bay Trail Gap Analysis Study, the estimated costs of design, permitting and construction are as follows: Castro & Tewksbury to trail under bridge $19.2 million Trail under bridge to Pt. Molate Beach 1.5 Total $20.7 million The City of Richmond and EBRPD desire to design, build and operate these Bay Trail sections. The City has funds dedicated to the Bay Trail as a result of a utility tax settlement with Chevron, and EBRPD Measures CC and WW earmark funds for the Point San Pablo Peninsula, including extending the Bay Trail from I-580 to Point Molate Beach. However, these available public funds are insufficient to close the Bay Trail gaps between Point Molate and the community. Therefore, the Point Molate project should provide funding to design, permit and construct these Bay Trail segments based on its proportion of total trips to/from the Point San Pablo Peninsula. As detailed in Attachment C, the Point Molate Casino project would account for over 97% of vehicle trips in the year Hence, the project s fair share is at least 97% of the costs, i.e. about $20 million, to provide the pedestrian and safe bicyclist access required by Air Quality and Transportation impact mitigation measures. The mitigation measure recommended in the first paragraph of this letter is a clear and enforceable means for ensuring a fair share contribution that will allow the City of Richmond and EBRPD to complete the Bay Trail linkage between Point Molate and the community. Page 2

3 Requiring fair share funding to close the Bay Gap with the community is similar to other off site measures such as the widening of Western Drive, Air Quality MM-3-19 and Traffic MM 7-13, 14 & 15 for improvements of nearby off site roadways and intersections. The feasible mitigation measure in the first paragraph of this letter also should be incorporated in the FEIR to mitigate the Significant and Unavoidable Cumulative Transportation Impacts on nearby roads and intersections. Otherwise, it would not be possible to adopt the Findings and Statement of Overriding Considerations required to approve a project despite its Significant environmental effects (State CEQA Guidelines Sections ). This mitigation applies to Environmental Impacts , 12 & 15 for Alternative A and equivalent impacts for Alternatives B, B1, C and D. Thank you very much for considering TRAC s comments and recommendation. Sincerely, Bruce Beyaert, TRAC Chair cc: Bill Lindsay Richard MItchell Randy Riddle Lina Velasco Page 3

4 Attachment A Air Quality & Transportation Mitigation Measures in the FEIR Assume Safe Pedestrian and Bicycle Connections with the Community (emphasis added) MM 3-17 e. The Tribe shall provide and fully fund sidewalks and/or paths, connected to adjacent land uses, transit stops, and/or community-wide network. MM 3-17 f. The Tribe shall provide and fully fund showers and lockers for employees bicycling or walking to work. MM 3-17 g. The Tribe shall provide and fully fund adequate and secure shortterm bicycle parking for retail customers and other non-commute trips. MM 3-17 h. The Tribe shall provide and fully fund safe, attractive pedestrian access from project to transit stops and adjacent developments. MM 3-17 i. The Tribe shall provide and fully fund secure. weather protected bicycle parking for employees. MM 3-18 g. The Proposed Project would be located within one-half mile of an existing/planned Class I or Class II bike lane. A one per cent reduction in criteria pollutants would occur with the implementation of this mitigation measure. MM 3-20 e. The Tribe shall provide ample covered bicycle parking at commercial areas and parks. MM 3-20 g. The Tribe shall consider bicycle and pedestrian circulation in the design of intersections and and turning movements, and... MM 3-20 i. The Tribe shall assist in funding the improvements necessary to connect the Bay Trail south of I-580 to the proposed segment north of the freeway. Page 4

5 Page 5 Attachment B Engineer s Cost Estimate by Questa Engineers Bay Trail Connecting Castro St. & Tewksbury Ave. to Trail under Richmond/San Rafael Bridge

6 Attachment C Basis for 97% of Vehicle Trips Resulting from Project Baseline Trips without Point Molate Development: The February 2002 FEIR/FEIS For The Disposition of and Reuse of Naval Fuel Depot Point Molate stated that the existing traffic count at Point Molate Main Gate is 503 trips/day with 377 trips/day at the northern end of property (Table 3.9-7). It is noteworthy that about 2% of these trips were by bicycle even in the absence of a safe, convenient bicycle connection with the community. Based on Figures E.4-1 and E.4-6, trips to/from sites on the Point San Pablo Peninsula north of Point Molate are projected to increase to about 525 trips/day by 2020 without development on the Point Molate property. Trips with Mixed Use Development Project: According to Table 5-5 in Appendix S, Alternative A of the Mixed Use Casino project would generate 16,912 vehicle trips on weekdays and 22,400 on Saturdays excluding the Entertainment Center. This means that Alternative A s casino and hotel operations alone would add about 18,500 weekly average daily trips to/from Point Molate to the year 2020 baseline of 525/day for sites north of Point Molate for a total of 19,025 average daily trips from I-580 to Point Molate. Hence, Alternative A would contribute 97.2% of the projected daily trips on the Point San Pablo Peninsula in 2020 (18,500/19,025). An event filing the 3,000-seat entertainment center to 85% capacity would generate an additional 1,594 vehicle trips (Appendix S, Sec. 8.1). Page 6