Let's look at the Twain DEIR Recreation 'impact
analysis' in Subchapter 3P.
The DEIR states on page 3P-5, under Paragraph 3P-4:
Less than Significant Impact
The proposed
project would not increase the use of existing neighborhood and regional parks
or
other recreational
facilities that would cause or accelerate substantial deterioration of the
facilities.
And,
the DEIR concludes on Page 3P-7:
3P.5 CUMULATIVE IMPACTS
The
proposed project would not result in significant impacts to recreation.
Therefore, there would
be no
cumulative impacts.
By
conflating field space acreage with other rec spaces, including asphalt space
occasionally doubling as parking space, the DEIR deliberately avoids analysis
of the removal of one half of the existing sports field utilized by community
youth sports under the Civic Center Act at Mark Twain Middle School.
Users
will be forced to seek other space in a domino effect, thereby increasing use
of other field space in the area. The DEIR fails to investigate impacts of this loss because
it omits any study of existing area ball fields’ permit availability for team
practice/game play. The
DEIR somehow assumes any additional burden upon other facilities will somehow
be absorbed to the level of less than significant impact.
Area
fields’ physical condition and maintenance cycle with regard to the ability to
handle more hours of play was not assessed.
Nor
was the potential availability of adequate permits.
Ask any youth teams sports parent--permits for consecutive practice dates/times/games are notoriously difficult to obtain at local public rec facilities.
Schools;
state parks; and neighboring municipalities all have different threshold
policies on field permits for groups—particularly groups which draw membership
from outside the municipality--and it cannot be assumed those other
jurisdictions’ fields would have available permits, or that they would absorb
more users without physical impacts such as increased wear and tear; traffic;
and noise.
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