Thursday, May 21, 2015

Red Card: Eject the Twain DEIR's Rec Spaces Analysis

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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