Save the American River Association

APPEAL OF REGIONAL PARKS PERMIT FOR

INAUGURAL GOLD RUSH 100K RACEApril 9, 2013

Review of the Gold Rush 100K Permit

① “Review of Permit Results” dated 3/25/2013② Information Provided by Regional Parks – Public Records Act Request dated March 1, 2013– Timely response from Regional Parks– Signed Application & Permit– Request for Permit Amendment, IF ANY

③ No Other Information Received④ Complete Response is Assumed

Save the American River AssociationApril 9, 2013 2

Summary of Conclusions① Gold Rush 100K Permit Violates American

River Parkway Plan– Four Instances

② Regional Parks Permitting Process– No Documentation or Evidence Supporting Findings– Lack of Transparency/Public Review & Input– No resource impact monitoring program

③Other Gold Rush 100K Permit Issues– Potential County Liability for Accidents– Inadequate Permit Conditions

④ Other issues

April 9, 2013 3Save the American River Association

COMPLIANCE WITH PARKWAY PLAN① Parkway Plan is State Law

Failure to be comply with Parkway Plan violates State Law

② All uses and facilities must be compatible with goals and policies of Parkway Plan

③ A Permit may not be issued unless Regional Parks makes Findings of Fact based upon substantial evidence that:

a) Impacts on other Parkway users & Parkway natural resources & aesthetics are minimal,

b) Compliance with all other Plan requirements & County Ordinances will occur, and

c) The activity/event is compatible with the goals and policies of the Parkway Plan.

4April 9, 2013 Save the American River Association

PARKWAY PLAN VIOLATIONS

① Competitive Event Not Allowed on Horse/Hiking Trail● No specific citation in Parkway Plan● Only specific citation is bicycle trail competitive events● Absence of a citation does not imply activity is permitted

② More than 2 Competitive Events in a Month● Gold Rush 100K race● Sac Fit Half Marathon

③ Violates Nature Study Area Restrictions● Based Upon Information Provided by Regional Parks

④ No Findings of Fact documented by Substantial Evidence● No Substantial Evidence = Unsubstantiated Opinion

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Horse Trail at Mile 9

April 9, 2013 6Save the American River Association

OTHER PERMIT ISSUES① Potential County Liability

● Accidents involving horseback riders and individuals a well known risk

● It only takes 1 runner & 1 surprised horse② Permit Conditions Inadequate

● No instruction re avoidance of accidents, user conflicts, impacts on Parkway resources or appropriate response.

③ Inadequate map ● Current map of course NOT been provided● All aid station locations & designs not identified

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REGIONAL PARKS PERMITTING PROCESS① Basis of decisions not documented or

supported• Nothing for independent review to confirm decisions• No substantial evidence = unsubstantiated opinion

② Permitting Process Not Transparent• Post applications and Permits on website• Allow public to provide input & have information• Parkway is a public resource of community interest

③No Resource Impact Monitoring Program • Required by Parkway Plan Policy 3.4• Needed to accurately assess impacts on resources

8April 9, 2013 Save the American River Association

OTHER ISSUES① Group running on Horse/Hiking trail sensitive

● Concern for safety of horses & riders● Concern for Parkway Plan compliance

② Staff Policy to Use the Parkway to make money ● “Pay to Play”

● Regional Parks Letter Dated 12/3/2012● Must comply with Parkway Plan● Potential to exclude individual and family

use

9April 9, 2013 Save the American River Association

PARKWAY PLANThe expression of your community’s desire to: • Provide recreation primarily for individuals and

family groups, and• Preserve and protect the open space green belt,• While allowing controlled group activities and special

events that:Are consistent with the Parkway environment,Only minimally impact other Parkway users,Only minimally impact Parkway resources, ANDAre compatible with the Plan Goals and Policies.

10April 9, 2013 Save the American River Association

REQUESTED ACTION① Permits that do not comply with the

Parkway Plan are at odds with community desires & violate State law

● Gold Rush 100K Permit is one such permit

② SARA requests the Board of Supervisors to:● Vacate and Remand the Gold Rush 100K permit

to Regional Parks with direction to revise the permit as necessary to comply with the American River Parkway Plan.

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