A brief update on the Meeting of the Off Highway Motor Vehicle Recreation (OHMVR) Commission, taking place at Tracy City Hall, regarding planned expansion project into the Tesla area, as proposed by Carnegie State Vehicular Recreation Area (SVRA):

On Friday, February 5th, 2016, many local organizations and members of the public stood up with EBCNPS at the OHMVR Commission Meeting. We spoke out on the Carnegie SVRA General Plan and proposed expansion into the Tesla area. Passion was high at this event, the last opportunity for public comment on this project. Sticker badges of “I Own Carnegie” contrasted with “Save Tesla Park” around the room. Most importantly, a majority of speakers remained adamantly opposed, and submitted succinct opposition comments into public record.

Please read EBCNPS’ submitted comments from the Commission Meeting, stating that this Proposed Final Environmental Impact Report (EIR) lacks appropriate consideration of important evidence previously submitted in full. The true effects of the General Plan and Final EIR on botanical resources continue to be misjudged, to the point of failing to satisfy California Environmental Quality Act (CEQA) requirements. We asserted, yet again, that these Proposed Final EIR  and General Plan documents should not be certified or approved.

As Conservation Analyst, I represented EBCNPS at this meeting. I spoke to summarize important points from our submitted comment letter. We attached our Corral Hollow Botanical Priority Protection Areas (BPPA) map with description, and a Special- Status Species and Habitat Occurrences on Tesla Expansion Area map, which specifically illustrates a talking point on curly blue grass grassland, a rare natural community. This grassland is recognized by California Department of Fish and Wildlife (CDFW) and depicted as up to 175 acres in size on the special- status map. It is unclear why the coarse vegetation mapping used for their impact analysis overlooks these and other botanical and cultural resources.

In fact, we recommended that the Tesla area is so very significant as to merit a “sensitive area” recognition as defined by Public Resources Code, to serve as permanent mitigation for ongoing impacts of OHV use at the existing Carnegie SVRA. I also reinforced in comments that EBCNPS thinks Tesla should be permanently preserved with no OHV use.

As you analyze these documents for yourself, please keep in mind that delaying the planning of smaller projects as part of a program- level planning process is an over- generalized approach in this case, inadequately accounting for the summary impact of small projects on the whole Tesla area. Where there could be significant impacts to resources requiring legal protection, appropriate steps to analyze those impacts must be taken, and definitely were not taken by this Proposed Final EIR. Any small project would undeniably effect the whole. Steps to ensure complete analysis is performed before action would be taken on the expansion plan are also not outlined. The only impact deemed significant and unavoidable by this Proposed Final EIR is that on air quality, which is not supported by the evidence we and many other groups submitted. We are thrilled that so many others agreed with us.

Reporting on this event included The Independent’s article summary of the “sharp criticism” for the Tesla expansion plan, and, an article on how to understand the fuel tax allocation source of funding for the purchase of Tesla property by Carnegie SVRA in the 1990s.

Small victory that the OHMVR Commission did not vote on the General Plan and Proposed Final EIR at this meeting! What can we do now? Within 6 months, the Commission will decide whether to approve the General Plan and EIR. Hopefully, they will take extensive time to consider the resources needing protection on the Tesla property. Please continue to show your support by keeping your ears open about Tesla topics.

If you have the time, read through the FEIR, comments, or appendices. Many groups also made important opposition points backed by valid evidence.

We will await the Commission’s decision, and report back to you.

Karen Whitestone