From: Lydia Miller, President
San Joaquin Raptor Rescue Center
Merced, CA 95341
Protect Our Water (POW)
Modesto CA 95350
To: Mr. James Holland January 6, 2006
Merced County Planning Department
2222 M St.
Merced, California 95340 Emailed
Fax: (209) 726-1710
Re: Comments on Draft Environmental Impact Report, Riverside Motorsports Park – General Plan Amendment No. 03005,Zone Change No 03007, State Clearinghouse # 2003071138
Dear Mr. Holland,
We are commenting on the DEIR of the Riverside Motorsports Park.
This project, as meticulously described in detail in the DEIR, does not need the flexibility provided by a special zoning designation. Therefore we object to the development plan zoning designation. This proposed major auto raceway, with great cumulative impacts on the environment of Merced County, should, under no conditions, be permitted to change its plan subject only to the administrative approval of a new, out-of-state director of Development Services.
The DEIR is so narrowly focused on the needs of the project that it fails to even consider the broader impacts the project would have to natural resources, public health and safety and infrastructure needs.
We found it unacceptably confusing that the master plan didn’t coordinate in any obvious way with the DEIR.
Until the county General Plan is properly updated, even to consider the number of possible amendments this project would be asking for is irresponsible land-use planning. Currently, the County is claiming an update in 1995. This is not true; it was amended. An amendment is not a comprehensive update. Since then, a number of other amendments have so warped the General Plan that it is now admitted by all to be a useless policy document.
The County has yet to coordinate responsibly with other jurisdictions on other projects like the Bellevue Corridor and the Atwater/Merced Expressway Project.
Racetracks have a history of failure and this one is competing with several major tracks in nearby counties, including Laguna Seca and Sears Point. Proponents require special zoning that will give them extreme flexibility, despite the apparent level of detail and narrow focus of this DEIR. Under the master plan, changes can simply be made by administrative decision of the director of Development Services. Given these three factors, we must consider the probability that this RMP is a holding pattern, just like a golf course, and that at any time, at the administrative discretion of the director of Development Services, the project can be converted, at taxpayer expense, into commercial development, part of a commercial corridor.
The environmental checklist is so over defined by the needs of the project, as opposed to the needs of the environment, that the proposed mitigations and the lack mitigations fail to reach the standard of a competent DEIR, leaving the public and the resource agencies unable to accurately address this project.
Growth is happening in this area in a haphazard, unplanned way. The impacts from this growth have not been taken into consideration in this DEIR. Mitigation measures in this DEIR defer responsibility to other plans, which, like the regional water plan anticipated for six years, are plans to make plans, for example the Traffic and Circulation Management Plan on page 4-31 of the Master Plan. Mixed in with these plans to make plans, are concrete proposals, such as the creation of a new road, Riverside Drive, without any analysis or alternatives.
This document provides no proof for its claim that there will be no impact to wildlife and habitat from the project.
The document displays a faulty understanding of environmental benefit, for example, on p. 4-2 of the Master Plan.
There is no analysis of the pharmaceutical and solvent content of wastewater proposed to be used in the project.
These documents rely on the infrastructure of the former Castle Air Force Base, yet there is no discussion of this infrastructure or its environmental condition.
We have been consistently involved in this area of the county for a number of years, and have provided the County with numerous public comments on environmental concerns.
We are reserving the right to submit additional information at the time of the public hearing on the FEIR.
In conclusion, we support the no-project alternative because this project fails meet CEQA standards and the county’s current, out-dated general plan.
cc: Interested parties
William Hatch, Badlandsjournal.com