Sudbury Citizens For Responsible Land Stewardship www.sudburylandstewardship.org PO Box 743 Sudbury, MA 01776
PRESERVE SUDBURY

Statement to Sudbury Community Preservation Committee

Regarding Rail Trail CPA Requests

December 6, 2006

Dear Community Preservation Committee:

In regard to the funding request for a wildlife study, the feasibility report acknowledges the sensitive location of the rail bed when it states how important it is for users to be confined to the trail and how difficult that confinement will be to control and enforce. The report also goes on to suggest that a trail, if built, may need to be closed during breeding seasons. The rail bed is one of only a limited number of acknowledged wildlife corridors still in existence in Sudbury. It is a corridor that connects with conservation lands, Great Meadows Wildlife Refuge, passes near vernal pools, traverses designated areas for Priority Habitat of Rare Species and Estimated Habitats of Rare Wildlife. A section of the rail bed has also been determined to be a regionally important area for biodiversity. There is a growing body of studies that have been compiled by the US government stating that non-motorized trails that were once considered non-consumptive are now being viewed in a different light. There is growing evidence in the field of conservation biology that these trails are indeed consumptive and have both long term and wide ranging impacts on wildlife that inhabit the surrounding area of a trail. For all these and other site specific reasons that for the sake of time I won't go into, an independent, in depth wildlife and wildlife impact study needs to be carried out for the benefit of the Town. What is disturbing with this funding request is that it is unknown what the study will cover and it is not specified that this study should be done by a biologist independent of some large firm that will be doing the 25% design. In-depth and independent are crucial words here. Will the eventual RFP be more on the lines of what the RTAC recommended be included in a wildlife study or will it turn out to be what is recommended in a 25% design? The 25% design only requires an environmental coordination checklist identifying potential environmental impacts. It is disturbing that the Conservation Commission has so far been virtually excluded from this process and it is even more disturbing that at its November 9th meeting the Selectmen and Town Manager decided to have a legal determination to see if the Town could avoid abiding by the Town's bylaws which would include our Wetland's Bylaw. For many reasons, it would not be in the Town's best interest if the crucial wildlife study were to become just another watered down, checklist item with no meaning except to move along the development of a trail. Is there any way for the CPC to prevent this from happening?

At this time, it would appear that  the Town is premature in requesting  additional CPA funds to be spent on a rail trail when so many questions are unanswered...questions that the Town was led to believe would be answered before more money was requested for this project.  Please recall, at the 2005 Town Meeting, voters raised concerns that the $25,000 for the feasibility report was not enough money to study all the issues noted in the Selectman's presentation.  As it turned out, this was exactly the case.

The Town Manager has stated the cost of a trail is unknown. However, it is known the Town must pay for the design, no matter how much it costs, even if it is more than 10% of the project cost.  The estimated design cost at the moment, is $550,000, but it is unknown if this amount will be less than the Town's required contribution.  It was stated at the November hearing that there is not even a guarantee this project will be funded by the state and federal governments, even if the Town spends thousands of dollars to plan for it.  There are so many issues identified in the report without associated costs, it seems more questions were raised than answered.  For example:

The study noted boardwalks may be needed for wetland areas, yet no estimates were provided for the amount of boardwalk or costs to build or maintain.  Other identified needs with no associated cost estimates were also included, such as: erosion controls, special construction methods and machinery, soil testing and storm water control.  The most costly line item included in the Acton Feasibility Study was for removal of the rails and ties from Acton's 4.6 miles, the same mileage as in Sudbury, and that cost was nearly $1.6 million.   There is no estimate for removal in the Sudbury report.

The study provides no parking solutions for a trail's terminus in South Sudbury. This will be especially critical if the intersecting East-West trail is ever built.  Local businesses are not willing to provide or share parking. In order to compensate for a parking problem in South Sudbury, the study states most users would access a trail from Davis Field.  Is this being realistic?  By the way, Fay Spofford, Thorndike, who did the study, stated a spur trail would have to be built from the Davis parking lot to a trail, but included no estimate for that cost either.

CPA funds are used for Community Preservation, but what will the effect of a trail be on the character of the four scenic roads it crosses?  It is required that there must be a clear vision for 200 feet in each direction at each trail and road intersection from 8 feet back on the trail. That is more than the length of a football field on both sides of the road.  What will the visual effect be on the scenic roads and in Sudbury Center? Shouldn't the Town understand these impacts before voting more funds?

Residents were told at the 2005 Town Meeting the study would include maintenance costs, yet the professionals provided no maintenance costs. The Rails to Trails Conservancy has estimated average maintenance and operation costs as being $50,000¹ a year.  However, it is a known fact that maintenance of boardwalks, mowing, sweeping, re-surfacing, fences, portable toilets, signage, tree trimming, litter pickup and all other maintenance, is the responsibility of Sudbury tax payers, yet we have no idea of the true costs. 

We have been given no costs or plans for policing as was promised us at Town Meeting.  The Rails to Trails Conservancy reports that two-thirds of surveyed trails report vandalism, graffiti and theft and that one-third of trails reported problems with dumping, trespassing and illegal vehicle use¹.  With these known issues, why has the Town been given no information on policing costs or even a plan of how or how often a trail would be policed, curfews enforced, and how trespassing situations will be handled? 

It has been estimated by the State there will be hundreds of users per day.  FST has stated most users will drive to a trail and the state has listed this trail, if built, as a regional trail to be promoted for tourism.  Therefore, this is a CPA project unlike any other, as it is a non-essential amenity for the Town that in all likelihood will be used mostly by people from out of Town, and yet something for which Sudbury will pay year after year to maintain.  Also, what will be the cost to the town's infrastructure and character from increased traffic, both vehicular and bicycle, to access a trail?  Shouldn't these issues be thoroughly evaluated before more money is spent?

According to Concord's CPA funding request for the 25% design, two components were singled out that would enable the Town to get a lease of the R.O.W. from the State.  These are the same components, except for the wildlife study, now being requested in Sudbury.  Thus, these two items are required checklist items to move the building of a trail forward, just as the reason for doing the $25,000 feasibility study was not so much to answer questions, but  because it was the first  element required by the State to initiate trail development.

What is the big rush to spend more money on a project that has so many unanswered questions that would cost nothing to answer, such as, "Would the State even allow this trail to be a narrow unpaved one?" Just who is this trail being built for and what is the vision of a trail for Sudbury?  Certainly the mention in the Master Plan of rail trails was only a concept with no indication of what was really envisioned.  It would cost Sudbury nothing to wait for Concord to answer many of the same questions Sudbury now has and after all, Phase I has been planned for twenty years and it still isn't started.  Who knows how long it will take for the first section of Phase II to be built, especially when it is part of the rotary reconstruction and has to cross route 2?

Because there is no urgency for this project, we urge the CPC not to vote for any administrative funds to be used for the rail trail. Furthermore, until the many unanswered questions have been resolved, many of which will cost the Town nothing to investigate, we urge the CPC not to refer the rail trail proposals to Town Meeting at this time.

Thank you,

Sudbury Citizens For Responsible Land Stewardship

______________________

¹Rail-Trail Maintenance: Preparing for the Future of Your Trail, Rails-to-Trails Conservancy, July, 2005, pgs 5-9.