"... implementation of the Guidelines as proposed could preclude the development of pedestrian and bicycle
trails adjacent to NCRA railroad rights-of-way within the County or divert trail funds to maintain or
improve rail facilities."

Section 4.3 Clearances
Section 4.3.3
"The required minimum Setbacks are 100 feet from any main track where train speeds equal or
exceed 79 mph; 75 feet where main track speed is between 78 mph and 50 mph; 50 feet where main track
speed is between 49 mph and 25 mph; and 30 feet where main track speed is below 25 mph."

The prior section ofthe proposed guidelines (section 4.3.2) covers the setback issue completely without
rigorous standards as it focuses on design criteria as the control for setbacks versus rigid numbers. While it
is desirable to meet the distances stated in 4.3.3, it may be completely unrealistic in the majority of the
NWP Right-of-Way. We recommend that the "required" be replaced with "if sufficient Right of Way is
available and the separation distance is not requiring the trail to be placed in a location that may have
geological, environmental or other overriding constraints to construction."

The Federal Highway Administration and the California Public Utilities Commission have established
setback distances that are less than ten feet, which is substantially less than the setback distances specified
above. Given that there are rails with trails projects that use these federal and state standards around the
nation, it seems appropriate for NCRA to consider setbacks as part ofthe engineering design for the trail
and not set rigid limits which may not be achievable. It is understood that these considerations would be
given as to maximize safety while not jeopardizing state of federal funding.

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