The Human Impacts of the Project

The draft EA falls far short of meeting NEPA requirements to address human impacts.  
Some of these include:

1. Inadequate assessment  of the trail users.  Who are the current users?  What is the need for the project?

The draft EA does not quantify the substantial numbers of people who use the trail, consider how the trail is currently used and has been used, or address the impacts upon these users if the recommended alternative were adopted.  

On the Auburn Trail Extension it is pedestrians, not cyclists,  that have been the primary user group.  Because of its exceptional biodiversity and accessibility, the trail has been used by walkers and nature lovers for many years.  

The draft EA does not provide evidence of  proper consideration of the historical and current recreational uses of the trail.   The project’s proposed plans for a stonedust bikeway met early resistance and generated great public controversy in large part because of the proposal’s anticipated human impacts.   The draft EA does not adequately consider the fierce outcry from many users, and the groups that have represented those users.  

By not carefully assessing its human impacts, the draft EA has not meet its stated objectives of being “ inviting and accommodating to all users, ” “increase overall mobility, accessibility, and  safety”, and “attract people from outside the Town to visit Victor.” 

The draft EA does not provide justification of the human need for the project.   As an example of numerous assertions that have no basis in fact, the Draft EA claims that the project will tie into the Town of Pittsford’s plan to improve the Auburn Trail as part of a regional system.  The Town of Pittsford has no such recommendation in its Comprehensive Plan.  Rather than being part of a regionwide system, as the planners state, the project ends in a parking lot at a corner of Powder Mills Park.  It has been called a trail to nowhere. 

Inaccurate statements as these undermine the credibility of the entire draft EA, and mislead the public.

The draft EA does not adequately consider the human impacts of the project.  It does not meet its stated objectives relating to human impacts. 

2. What is the current and projected future use of the trail when it is completed? 

The Draft EA provides no surveys or counts of current users, nor does it give any reasonable estimates of future users.  No numbers at all are provided.   There are conflicting projections of future use.

Should a federal project move forward without any actual data on current use and reasonable future projections?  In parts of the draft EA it is claimed that low use is expected, while  in the funding application it claimed it would become an important transportation connector, with substantial use, including many commuters.  While this was fanciful grantsmanship intended to secure funding, we ask, which is it?  Is high use projected?  Or low use?  Will it be used for commuting?  From where?  To where? Whatever use is projected, it should be based on proper data, not someone’s wish of what sounds good to meet guidelines.

3. The draft EA does not adequately address the social groups that would be harmed or excluded by the project. 

The draft EA claims (IV-6) that no identified social groups would be significantly benefited or harmed.  It claims that “no adverse impacts on elderly..would result from the project. The project will have a positive effect on it would be designed and built to ADA standards, thereby increasing safety and accessibility for people with restricted physical capacities.”

The Draft EA provides no documentation for this claim.  It appears to be an unfounded opinion of the planners.  The claim of no impact ignores hundreds of comments by people which state that there will be adverse effects on them as individuals, and as members of groups.  Several users have commented that they are handicapped and preferred the trail as it currently is, or prefer the Coalition recommended option.  The draft EA did not include or address those comments. 

The statements about social groups in the Draft EA  reflect a bias that permeates the entire document.  

The draft EA does not give accurate and honest consideration of the issues, as required by NEPA.  It should have accurately represented the concerns of users and the public by giving due consideration to the comments and feedback submitted, which due diligence requires.    Instead the draft EA presents the planners uninformed opinion as factual, and then uses it to justify its preferred alternative.  It is contrary to the requirements of CEQ.

The Elderly is a Group that Will be Harmed.

Many trail users are elderly.  Burroughs Audubon Nature Club is a case in point.  Its sanctuary borders the project, and its members have spoken regularly to preserve the special area that they use for their educational and recreational activities.  The great majority of its membership are seniors.  BANC members and other seniors have stated the trail is accessible for them now, and would continue to be accessible per ADA, were it widened to 3’.  

Many of these users have visited the area for years because of the opportunities it gives them for one of their hobbies - nature recreation.  It might be photography, birding, butterfly watching, or a peaceful stroll along the scenic trail.  Many have commented that the existing linear meadow offers unusual opportunities for an experience that has been described as “nature up close.”   They have expressed numerous concerns about environmental impacts as well as their ability to continue safely using the trail if it were widened to a 15 mph bikeway.    

None of the expressed concerns are considered in the draft EA.  The draft EA does not address the issue of safety of elderly users, who often cannot move quickly out of the way of fast-traveling cyclists. 

On April 19, 2010 an elderly woman in Renton, Washington, was killed on a shared use trail,  hit by a passing cyclist.  Elderly Renton woman hit by bike rider on Cedar River Trail identified - Renton Reporter.  What considerations are in place to assure that this doesn’t happen to the many seniors that use this path?  None are discussed in the draft EA.

The draft EA does not consider the consequences, even unintended ones, of its proposal.  By designing a trail where elderly users feel unsafe, or one that destroys the very environment that attracts them to it, the unintended consequence is likely to be that these users will stop visiting.    Many users have sent comments that this is true for them.  Federal funding may not be used in any discriminatory or exclusionary manner.  This concern must be addressed in the EA.

4. The Draft EA does not consider conflicts between user groups.

The draft EA neglects to address real conflicts that exist between user groups.  Rather than honestly addressing these conflicts, the Town instead makes unsupportable claims.  In the brochure that was mailed to all Victor residents in advance of  the April 2010 Public Hearing, it claimed that the project will “bring people together, improve safety for all users, enhance attractiveness of Victor”, etc.  A pretty PR piece - but not true.
FHWA has acknowledged that user group conflicts need to be addressed.  In Chapter 14. Shared Use Path Design - FHWA: “All pedestrians are affected by sudden changes in the environment and by other trail users, such as bicyclists, who travel at high speeds. However, the conflicts on shared-use paths are especially significant for people who cannot react quickly to hazards, such as some people with mobility impairments.”   FHWA recommends addressing these conflicts in various ways, including the suggestion that, “bicyclists and pedestrians should have different lanes or pathways.”

The draft EA provides no such accommodation. Why? 

Perhaps it is because the railroad berm, at 10 - 12’ wide for much of its length,  is simply too narrow to support speeding cyclists and pedestrians.   A 1’ shoulder is likely too narrow for someone to safely move out of the way of a speeding cyclist.  

But there are other options to accommodate “different lanes or pathways.”   An on-road alternative to direct experienced (not novice) cyclists around the sensitive environmental area should be reconsidered.   

An unintended consequence of the proposed trail design is that it will become, de facto, a bikeway which excludes the very users who have used it recreationally for many years.  FHWA states in the document linked above, “For most shared-use paths, bicyclists are the primary user group.”   Although that may be true for “most shared use paths,” it is not true on the Auburn Trail Extension where the primary user group on the existing trail are pedestrians.  The draft EA should be designed with that fact in mind, rather than designing for bicyclists as the primary user group.

Even the AASHTO Guide (p. 58) states the following in a discussion of sidewalks, but the concepts are applicable to the trail: “Conflicts are common between pedestrians traveling at low speeds (exiting stores, parked cars, etc.) and bicyclists.  Walkers, (and) joggers, …can, and often do, change their speed and direction almost instantaneously, leaving bicyclists insufficient reaction time to avoid collisions.” ...“Similarly, pedestrians often have difficulty predicting the direction an oncoming bicyclist will take.”

We ask the planners to picture the heavy recreational use that the trail gets from nature lovers, birders, butterfly club members.  Recent Birding field trips have had over 30 people in attendance,  Butterfly Club outings over 20, and Burroughs Audubon outings have counted over 30 attendees.  Imagine these large groups - or small groups - or individuals when a single, or several high-speed cyclists come by.  How does the design accommodate both groups safely?  The proposed alternative does not.

The Planners have not considered the numbers of current users, their demographics, and why they visit the trail.  Instead they have designed a bike path that is simply not safe if the existing uses and users continue to use the trail as they have.  It is particularly unsafe for the many elderly users, many of whom cannot move quickly out of the way of fast-moving cyclists.

5. The Draft EA does not give due consideration of concerns about USER DISPLACEMENT - those users who will no longer be able to use the trail as they have been accustomed to.

In addition to the elderly the draft EA has ignored concerns of other groups and individuals that will be harmed by the project.  

The Rochester Butterfly Club regularly uses the area for field trips, and has stated that it will no longer do so if the proposed alternative is completed.   The proposed alternative destroys the  the habitat for the butterflies which draws the club members to the trail.  

Hundreds of other users have also explained, in thoughtful comments that were not considered in the draft EA, that they, too, would not be able to use the trail in the manner that they have for years.  Their concerns regarding the human impacts of  the project have not been addressed. 

The users include The Coalition to Save the Railroad Mills Special Environmental Area, a group representing over 5000 local members of Burroughs Audubon Nature Club, Rochester Birding Association, Rochester Butterfly Club, Rochester Regional Group of the Sierra Club, and Genesee Valley Audubon Society.  Individuals have also identified themselves as members of other groups who use the trail for recreational purposes: Rochester Area Mycological Association, Retired Teachers Organization, Osher Lifelong Learning at RIT,  Monroe Community College Biology Department, Oven Door Runners, Rochester Bicycle Club. 

If the intent is to exclude present users from using the trail as they have used it for years, the project will have succeeded.  If the intent, however, is to allow for multiple, shared uses of this recreational trail, the project fails as written.

NEPA makes clear that an EA will not be used to rationalize or justify decisions already made.  However,  by not recognizing and accurately reporting how the trail is used,  and by whom, and the impacts on those users, the draft EA is slanting the information to justify its predetermined decision.  The Administrative Record provides ample evidence that,  from the project’s inception,  the planners envisioned a wide stonedust bike path, and have never considered that this recreational trail could be designed differently, in a manner that could accommodate all users, present and future.

If the proposals advocated in the draft EA are implemented, it will have a profound human impact.  As it will be unsafe for the elderly and others who use it for nature recreation.  The project will, in the end,  exclude hundreds, if not thousands, or trail users, while benefiting a much smaller subgroup of cyclists.   It cannot meet its stated project objectives.  The draft EA must address this. 


The draft EA does not adequately address the human impacts in this project, as a NEPA document requires.  There are many omissions, mischaracterizations throughout the document.  

Accurate information on the human impacts must be obtained, and properly analyzed in order for the human impacts to be accurately assessed.  Planner bias and preconceptions must be set aside in order to do this properly. 

By not properly addressing the human impacts of the project,  draft EA cannot meet those project objectives that relate to human impacts.  The alternative proposed in this draft EA does not 1) make the trail inviting and accommodating for all users;  2) increase overall mobility and safety, or 3) attract people from outside the Town to visit. 

An accurate assessment of the project’s human impacts  is necessary before a fair determination of its impacts can be made.  

To do this will require significant and substantial revision of this draft EA.  Given the environmental and public controversy surrounding this project, the public should have an opportunity to comment on this substantially revised document.   A full and fair consideration of human impacts should influence the proper consideration of alternatives, which will need to be reassessed with the new information. Thus, the revised draft Environmental Assessment should be reissued as a draft for public comment, rather than as a Final EA.  Alternately,  an EIS should be prepared.