Coalition Response
to the Draft Design Report

Auburn Trail Extension Project - PIN 4760.35
 
 
November 17, 2008

Prepared by the
Coalition to Save the Railroad Mills Special Environmental Area



The Coalition to Save the Railroad Mills Special Environmental Area finds the Draft Design Report to be incomplete and inadequate, particularly for the area between the damaged culvert and Railroad Mills Road, the Railroad Mills Special Environmental Area (RRMSEA).

This document clearly shows that the project Sponsor has lacked due diligence in moving the project forward, most seriously in the area of environmental review.  Qualified botanists from the Coalition to Save RRMSEA have identified two additional NYS-threatened plant species that were not found by the Sponsor or its consultants because they did not exercise proper due diligence.  If these species are ignored and the project moves forward, it will cause a significant environmental impact.

Design approval should not be granted at this time.

There are four major areas of concern where the Draft Design Report falls short. 
These areas are outlined below, and discussed in detail in the rest of this document.



1. A Chronology of a Flawed Public Involvement Process 
(View PDF of full Response Below)


The Public Participation Process has been unsuccessful.  The Coalition documents numerous examples of ways the Sponsor, instead of attempting to openly resolve differences and developing an outcome that meets the needs of users and the project goals, has forged ahead towards its own predetermined outcome. Since the beginning, Coalition members expressed concerns about the environmental sensitivity of RRMSEA, impacts from proposed trail widening, and the importance of that area to current users.  The goals of a true public involvement process were not met, despite the inclusion of a Coalition representative on the Advisory Team, and the public outreach efforts. A 3’ alternative was never developed.  The Sponsor has not offered a proposal that is community-valued, one that meets the needs of the users, and protects the environment.


2. Characterization of the Project
(View PDF of full Response Below)

Much of the Draft Design Report is written with an obvious slant to claim that the project meets the criteria of the grant, rather than describing the issues in an unbiased manner.  We provide numerous examples to back up that claim.


3. Social Factors and Social Impacts
(View PDF of full Response Below)

The Sponsor does not adequately address many social issues and impacts.  It does not properly identify the current users, or the substantial use of passive recreational activities the area currently receives. The substantial controversy on environmental grounds, documented in numerous media outlets, public meetings, and letters to the grantors, has not been discussed in the Draft Design Report. The fact that most users either prefer a compromise to a 3’ wide ADA-compliant trail, or would like to see the trail left unchanged, has also not been mentioned in the report.  Many users have gone on record as stating that the proposed widening will make the trail less desirable as a destination for outings and field trips.  The Rochester Butterfly Club has said they would no longer have reason to visit the trail, a regular field trip site, if the proposed trail ‘improvement’ occurs.


4. Environment Analysis and Impacts
(View PDF of full Response Below)

It is the responsibility of the Sponsor to demonstrate that the project will not have significant environmental impact.  The Draft Design Report does not adequately document the existing environmental conditions. The Sponsor has not done any substantive studies, contrary to the recommendations by state agencies.  Due diligence requires that one must know what species are there before making a determination about impact.
The Coalition has done preliminary studies, and has documented two additional “listed species” (NYS-threatened) beyond the one species recognized by the Sponsor.  This finding has been reported to the New York State Heritage Program.  It demonstrates there is substantial risk for significant environmental impact from the project.
The Coalition has provided sufficient documentation for the Town of Victor, as Lead Agency for SEQR to declare a positive declaration.  It has also provided sufficient evidence for FHWA as Lead Agency for NEPA to require an EA/EIS, and not to grant a categorical exclusion with documentation.

Read more about the spectacular diversity of  PLANTS along the Trail.

SelectionFile type iconFile nameDescriptionSizeRevisionTimeUser
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1. A Chronology of a Flawed Public Involvement Process  63k v. 4 Nov 27, 2008, 1:14 PM Auburn RRMSEA
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2. Characterization of the Project  37k v. 4 Nov 27, 2008, 1:15 PM Auburn RRMSEA
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3. Social Factors and Social Impacts  40k v. 4 Nov 27, 2008, 1:15 PM Auburn RRMSEA
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4. Environment Analysis and Impacts  40k v. 3 Nov 27, 2008, 1:15 PM Auburn RRMSEA