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HomeMy WebLinkAboutDEIR_SJHTC_COMMENTSCITY OF NEWPORT BEACH PLANNING DEPARTMENT 3300 NEWPORT BOULEVARD P:O. BO;'; 1768 NEWPORT BEACH, CALIFORNIA 92659-1768 SJNTC EIR/EIS COMMENTS ON MAY 1, 1990, PRE -DRAFT State of Cal i#ornia Business; Transportation and Housing a9encY Memorandum To Steve Letterly Date: June 8, 1990 Transportation Corridor Agency and Carollyn Lobell LSA File No.: EA 1025,40 J. L: Heyer, Chief From DEPARTMENT OF TRANSPORTATION Environmental Planning Branch B subject SJHTC EIR/EIS REVIEW to I am Before I start the review section, I want point out extremely disappointed that many comments based on my review of the original 10/31/89 screencheck, later docuument sections as they were provided, and memos requesting specific items be changed or L included in document, were ignored. We, Caltrans and FHWA, on the be next preview draft, expect all of our comments will acknowledged, requested areas of conflict-orrected or changed, or, �I if not, an explanation provided. We were particularly concerned that Caltrans was not consul-r-ed regarding the last minute revised project description in the Abstract or the Summary, and that we, were not provided an,opportunity to review the Summary for this document prior to printing. (JLH) COVER (JLH) A cover page with a'photograph and graphics would be appropriate. n { We would like to participate in approving cover design. I have !�+ FHWA and Caltrans logos. Copy on the signature page is printed too close to the left margin interfering with binder punched holes. California Department of Transportation should be included as a Responsible Agency. Michael Cook has been replaced by _James Bednar .at FHWA. Mail address and phone numbers are: James Bednar, District Engineer Federal Highway Administration California Division P.O. Box 1915 Sacramento, CA 95812-1915 (916) 551-1310 i c.I---� ABSTRACT (JLH) Sentence two should read: "There are three alternatives, a Demand Management Alternative, a Conventional Alternative, and a No Build Alternative." The Abstract should be revised to accurately reflect the proposed project as described in the environmental document, Project Description section. Smaller type is recommended for the filing information in upper left and right hand corners. The right hand upper corner information is out of order. It should be: SCH No. 5001 0230 (how were these numbers assigned?) 12-ORA-73 P.M. 0-15 E.A. 102540 The left hand identification should be: FHWA-CA-EIS-90- -D George Beighle, Sr. Transportation Engineer for the SJHTC, comments as follows: The description shown is not consistent with the concepts: 6 lanes plus HOV Conventional Alternative will provide acceptable level of service. A 64, median provides either HOV -OR- transit, NOT BOTH. (GB) Headquarters Comments: Project description should be from south to north, i.e., I-5 to Jamboree as is done on page 1. By convention, highways are described from south to north and west to east. Descriptions on the Cover Sheet, and throughout the document, should conform to that convention - Examples for the Cover Sheet would be: I-5 to Jamboree and Jamboree to Birch. (JR) SUMMARY ( JLH ) In addition to improving flow and understanding, certain items should be included or changed. In general, the Summary should be a stand alone summary of the environmental document and should not r reference sections of the document. Reorganize Summary as follows: Title. SUMMARY In keeping with format established throughout the rest of the document (excepting for Section 7 which should be fixed), title should be centered. SUGGESTIONS: (JLH) Eliminate Introduction. Retitle as PROPOSED PROJECT. ' # I Paragraph 1, in addition should include both County and State and the project length in miles. Description of Project Alternatives (page 3) should be moved over to page 1, paragraph 1 and re -written to make more readable. The information conflicts with Project.Description in Chapter 2. Without adding a separate heading:, bring over Alternatives Withdrawn from Consideration from page 3 and make it,paragraph 2. This paragraph should be re -written. As is it's rion-formative. The Summary should accurately summarize the project and not have to reference Chapter 2A . Delete reference. Birch Street and In paragraph 1, sentence on improvements between Jamboree Road, should be relocated. Present location, in this part of project description is confusing to the reader. We 'recommend you add it as a last sentence to the paragraph in a -form such as, �a f "In addition, improvements to the section of existing SR 73 between -�D ( ) includes improvements that will (_ ).are included as part of this project." There should be an accurate typical cross-section included in the Summary. Current paragraph 2 should be relocated to the Need for the Project section since it describes need., Same for p4ragraph,3. This may require some reorganization of the Need portion of the Summary to make it flow. As we pointed out in several memos the alternative cameabout as a result of joint planning of "transportation and land use over a number of years. There has been a plan,. and developers and transportation, people have .developed the facility together. This has provided a unique opportunity for joint planning, and is a main selling point for the corridor. FIGURE S-1 (JLH) Figure S-1 should have the following problems corrected: `la The words are obliterated by background canyons. Park and Ride lots are included on the project features map but are bnot cleared by this project for 'construction. There is some they be this map. question,whether should on The maintenance station and toll facilities will be constructed with this project but aren't shown on the map. Scale.should be in miles for easier understanding by reader. The .title does not accurately reflect the content,. Project features implies those things that are important to the project which implies wetlands, areas of biological concern, locations of �IC„ major work related to project construction, nearby facilities and resource area, major residential locations, schools, airports, parks, areas with large cuts, etc. as I pointed out in memo and sample map sent to you on 12/13/89. Project objectives benefits include the benefit for jointly planned transportation facilities with planned development, provides for orderly growth. The growth inducing section should provide appropriate wording. Issues to be Resolved Section of Summary (JLH) The major issue probably isn't what is stated. In my 2/21/90 Memo to TCA and LSA I asked that the following paragraph specifically be included in this section: "A preferred alternative must be selected and indicated in the Final EIS. It must be determined and stated which alternative (or design variation) is environmentally preferred. All reasonable alternatives are under consideration. Final selection of an alternative or design variation will not be made until this DEIS is circulated for public review and alternatives' impacts and comments on the draft EIS and from the public hearing have been fully evaluated." IMPACTS Summary of "MAJOR" Environmental Impacts may be a better title 1,{ since all issues are noted in the proposed columnar impact exhibit. `I The significant issues should be summarized by text in addition to the exhibit. Again don't reference Chapter 4. (JLH) Page 16, Add "Materials" after word hazardous. In impact �j paragraph delete last sentence that states, "Other identified sites could be impacted by either alternative." (JLH) Page 17, first sentence, not true, we should discuss net which may be something like 4.5 million cubic yards. Maybe we need a meeting to discuss this subject. (JLH) Comment from Mark Stopher, Caltrans Wetlands Expert: Summary, page 4, the EPA will also have a substantial interest in wetlands and will provide comments to the Corps of Engineers during the Section 404 permit process. This should be acknowledged under TYPE OF DECISION. (MS) Headquarters comments: 1 1 1 M 1 I I � 1 I � I'. I% I (JR) 1, 1st paragraph: Birch St. should be shown on Figure S-1. JR Page 1, 5th paragraph, 3rd line: Should I-5 be I-405. The date for the expected traffic demand increase should be stated - 2010? (JR) (JH) Page 1, 6th paragraph: Travel demand should be compared to planned capacity on I-405 and Rte 1 to shown reed. Indicate when the stated traffic increase is expected. (JR) '01 Page 3, ist paragraph: Aren't #1 and #4 duplications? (JR) Page 4, California Transportation Commission: Under "Type of Z,� Decision": The CTC must also adopt the route for the SJHTC. (JH) IAA Page 5, 2nd paragraph: Explain who is lead agency for CEOA and NEPA. (JR) Page 8, Table A, 2nd paragraph: What is level of significance of incremental contributions? How much is an "incremental contribution"? (JR) Page 10, 2nd paragraph: Are there any endangered or threatened species? (JR) rr Page 11, 2nd paragraph: Per SCr .17 (1989) oak woodlands may ZJl require replacement. (JR) Page 22: Need a listing of Appendices. (JH) 2� Page 14: Is incompatible land use a significant impact? (JR) Page 2-0: Is water use during construction a problem? (JR) Final.note on the Summary. (JLH) The Summary should summarize or bring forth information from the main body of the document. There should be no new or changed information. This Summary, does not accurately reflect the description of the project; either the Demand Management or the Conventional Alternative. It should, be a,stand alone document and include a summary of major project impacts and mitigations related to the alternatives. I believe, when the document has been revised we will need a team meeting to resolve the issues raised regarding the Summary which would normally be completed after preparation of the document. The Summary section should wrap up with, "This environmental evaluation is in response to those.project features known at this time, changes in the project, or its circumstances, or development of new information may require additional evaluation. Unforeseen related features such as haul roads, borrow or disposal sites, storage yards, etc. may also require further review and mitigation." 1.0 PURPOSE OF AND NEED FOR PROJECT The Environmental Handbook'' calls for: (JLH) Accident data Existing and projected traffic data Ability of existing transportation facilities to provide for future transforation needs The Technical Advisory calls for: (JLH) Proposed action and transportation problems or other needs (Identify and describe) Define the needs in terms understandable. to general public Describe the problems the project will correct Provides a list as a guide (page 14) Within this list, the environmental document could more clearly define either by separate paragraph or heading: System Linkage (See TA page 14) CAS Economic Development (See TA page 14) I Modal Interrelationships (See TA page 14) 3 Roadway Deficiencies, i.e. Birch to Jamboree (See TA pg 14) This information may all be in here but, if so, it should be clarified and simplified and easily found. Section 1.5 is entitled Traffic and Circulation. In addition in Chapter 4 (Impacts section), there is another Circulation section. Please put necessary Traffic and Circulation information in Chapter I J� 1 under separate headings and avoid duplication of information. Traffic comment from Dorothy Uyehara, Chief Traffic Analysis Branch, Transportation Planning, on TM 3-19 for SJHTC follows. "After reviewing the above document and comparing it against previous documents we have detected certain discrepancies. Specifically the "2010 Level of Service Estimate August 89" is inconsistent with the previous documents dated March 89 and April 89. In the portion of TM3-19 for SJHTC dealing with LOS for 2010, the Northbound A.M. peak hour traffic for the mainline as well as HOV lane is consistently larger than the Southbound P.M. traffic. In the March 89 and April 89 versions, this condition does not occur. This makes ' March/April 89 in contradiction with August 89 version. The August 89 version appears incorrect, as one expects in a highly metropolitan area like the Los Angeles basin that the P.M. peak hour traffic to be equal to if not larger than A.M. peak hour traffic. The reason is that morning traffic is mainly composed of "home to work trips" for commuters, while P.M. traffic also includes other trips (i.e., home -other, home -shop, etc.)." (DU) Information including size and crews, traffic, and circulation on Caltrans' maintenance facility was submitted to you on 11/19/89, A. 12/19/89, and 1/6/90 including George Beighle's comments on the 10/31/89 screencheck. There should be a discussion in Chapter 1 in traffic/circulation and chapter 2 under project description. (JLH) Figures 1.5.2 and 1.5.3 are a duplication of Tables 1.5.A and 1.5.B. I recommend deletion. (JLH) Editorial Note: Page 1-12, sub information A. and B. shouldn't be to the margin looking like another chapter heading. (JLH) Headquarters Comments on Chapter 1: "Page 1-1, lst paragraph: What is meant by "..ultimate congestion �� can be expected"? (JH) Page 1-3, last paragraph:, 'Consistency is• -needed. The 1st sentence indicates that the Draft Environmental Impact Report No. 494 will be represented by "DEIR No. 494". Subsequent to that statement, "DEIR No. 494" and "DEIR" are used interchangeably. (JH) Page 1-61 Table 1.5.A: Consistency is needed again! Link descriptions (left-hand column) are listed from south to north 0 under I-4.05, north to south under SR-1 and south to north under I- 5. Change the listings under SR-1 so that they are shown from south to north. (JH) ` Pages'l-? & 8, Tables 1.5.A & B: Rearrange,the tables so that the listings are from south to north. (JH) . Page 1-9, 2nd paragraph: Indicate the limits of I-405 and 1-5 that are projected to be overloaded and severely congested by the year 2010- (JH) 2.0 PROPOSED PROJECT DESCRIPTION`: AND ALTERNATIVES �tIn Chapter 2, I did not see .where the realignment work between Birch and Jamboree was described. (JLH) The project description here is not the,same as that shown in the Abstract or Summary. George Beighle, Sr. Transportation Engineer for the SJHTC comments as follows: "The Cover. The description in•chapter 2,, and section 2.6 (page 2-31, all incorrectly define the conventional Alternative as a six lane facility, with a 64' median. This is NOT a viable alternative, as 3 general purpose lanes plus one HOV lane in the median would have insufficient capacity to provide an acceptable .level of service." (GB) On Page 2-2 why is Toll Facilities a sub under Profile Grades and Grading? ( JLH ) CONNECTION AT I-5 It appears that the connection at I-5 has�been labeled to fit one alternative or the other. Caltrans Transportation Engineer, Norm Johnson,. points out there are two study alignments for the G� connection and one has been .arbitrarily chosen to'be with the Conventional and the other Demand Management. ' He believes both alignments work for each alternative. This is brought out again on page 4-9, under Water Resources (Streambed Modifications). This issue should be clarified. (NJ) On Table 2-2A - Proposed General Purpose Interchanges., Norm Johnson, Caltrans Transportation Engineer, comments: A -full R diamond would be appropriate for the -Demand Management Alternative. (NJ) 1 This Chapter seems to be out of order. Shouldn't design features of the build alternatives follow 2.2? (JLH) 2-1 is a brief description of the project build alternatives 2-2 is common features of the build alternatives. QS� 2-3 is Phasing. 2=4 is Right of Way and Project Costs. 2-5 is Design Features of Demand Management Alternative. (build) 1 2-6 is Design Features of Conventional Alternative. (build) ' If the project will cause relocation of MAJOR utility lines outside of the APE, the area will have to be studied to determine whether 11.1 or not sensitive biological or archaeological impacts would occur. I (JLH) Per our memo on April 22, 1990 we asked that project costs including construction for each alternative be included. This section only includes right of way. Table 2.4.A is not complete. Totals should be included for right of way and construction for a 4-q total project cost. Acreage should also be broken down with a total acreage required for the project. The table can be reduced to a 6 point type set without losing reading quality. (JLH) Under Common Features of the Build Alternative there is a section entitled Park and Ride Facilities (page 2-20). It states, "Park ' and Ride lots will be provided along the corridor to serve bus riders, vanpools and carpools at or near the following corridor intersections, etc. This statement is misleading and untrue. The paragraph that starts out, "The TCA will not construct Park and Ride lots," should be paragraph 1 and the section revised to clearly depict what TCA is doing. (JLH) In this section (pg 2-31), George Beighle, Sr. Transportation Engineer, SJHTC, indicates in paragraph 2, the number of general purpose lanes for the Conventional Alternative ranges from eight a (not six) to twelve, with auxiliary lanes for weaving and on steep 5 grades. He points out we should disclose clearly the Conventional Alternative cannot support both HOV -AND- transit. (GB) Caltrans design engineers believe the sentence in the second paragraph under HOV/Transit Median that reads, "The median width Iwidens to 116 feet to accommodate exclusive HOV lane access... etc.." should be moved to the Demand Management section. Please check. (GB, NJ) On Page 2-32, third paragraph down, George points out regarding the last sentence, it is correct, however, it should be noted that the "envelope" must be split at each overcrossing structure to clear centerbent columns. (GB) 2-2 should include a paragraph on water cou section calls for common features. Yet 3 Associated Facilities one paragraph relates and •another on Conventional Alternative. characteristics (and if a similar situation in this section) should be moved to their design feature sections. (JLH) rses crossed. This >n Page 2-22 under .o Demand Management These specific exists anywhere else respective specific n 1 i 1 1 I I 1 I I 1 l�l I a that the 2-7 is No Project Alternative. Somehow it seems i information contained in Table I.8.A and B is related to and-shculd, be included in 2-7. There .should be more information in the No - Project Project analysis. The No Project Alternative is to be discussed 5Aand, evaluated on an equal- level with the other alternatives studied. This is important to identify and evaluate fully the trade-offs in deciding whether to go ahead with a project. (JLH) I think there is too'much detail in Section 2.8 (g). pages 2-38 through 43. (JLH) Page 2-39, Caltrans Transportation Engineer, Adel Malek questions C�pf i the existing lanes shown for Rte 133 to Irvine Center Drive; he believes I-405 to Bake Parkway and Bake Parkway are each 13 lanes, and Alicia Parkway to La Paz Road is 10 lanes,. Please check. (AM) that Norm Johnson, Caltrans' Transportation Engineer, points out Park�and Ride locations don't all --agree with Figure.S-1, and the Ford/Bonita lot also is not located at an arterial crossing with transit service ramps. Please check. (NJ) Figure 2.9 needs to be corrected. In_addition to -now reflecting the median correctly under the Conventional Alternative., to the left of the median, where the.'picture shows lanes vary from-36 to 601, our engineers believe this would be correctly stated 36' to 481. Please check. (GB, NJ) It seems that Potential Future Median Use Options which follows on 5qi page 2-20 should contain more information than the Park and Ride facilities, yet it has only,a short paragraph. (JLH) In that same vein, according to the MOMENTUM brochure put out by TCA, the TCA Board has appointed a .Rail Task Force. If serious consideration is being given to constructiori:.of rail facilities it may be appropriate to analyze rail in this corridor project. Of course, additional studies, and analysis would delay approval of the EIS. In any event, there should 'be• an explanation- for the task force. (JLH) FIGURE 2.13 JLH Eliminate this fold out or include in a Technical Report. ` TABLES-2.B.C.D.Z. (JLH) Eliminate, or put in a Technical Report. 4, ��- FIGURE 2.14 is the side. punched on wrong (.JLH) Section 2.8 is 20 pages long. It seems this section should be reorganized or summarized a little better. It's too. long, and i confusing. (JLH) 1 Comment from Mark Stopher, Headquarters Wetlands Expert on Section I 2_.8, Alternatives Withdrawn From Consideration: Both E.O. 11990 and Section 404 require that alternatives which would avoid impacts to wetlands evaluated. There is no evidence in this section of that taking place. The Analysis of Feasible Alternatives in Section 4.7 (page 4-80) accomplishes this task fairly well. It isn't necessary to reproduce this entire discussion in Section 2.8, however, I recommend that the five categories of Alternatives Withdrawn From Consideration be expanded to six. A category of "Wetland Avoidance Alternatives" should be added. In a single sentence, the text addressing this category should reference the discussion included in Section 4.7 and cite the page location. (MS) Section 2.9: Eliminate Figure 2.15. It is the subject of another environmental document. Discussion summary of related projects is sufficient. (JLH) Also under Related Projects please include the information provided by Alberto Angellini, Chief, Project Management Branch. For additional information regarding these projects please contact him at 724-2131. You'll want to expand on his brief description. (AA) "SR 73 MacArthur Blvd. from Pacific Coast Highway to San Diego Creek. Widen highway. Developing PSR. SR 73 MacArthur Blvd. from 0.2 mi. so. of Bonita Canyon Road to 0.1 mi. no. of San Diego Creek. Widen Highway; Modify Intersection. PS&E in final stages. Award expected 6/90. You may want to add these 2 projects to Table E-A, Related Transportation Projects. You might also want to take these projects into consideration, where appropriate, in the EIR/EIS. We note two places that might be considered: Page 2-5: MacArthur Blvd. to be relocated. "Combined interchange with access to University Dr... via MacArthur Blvd. and ...collector -distributor roads." "...ramp from northbound MacArthur Blvd. to corridor... to remain with an auxiliary lane added at this ramp and extending north." Page 2-27, last Par.: ..HOV access ... using reversible "HOV Dropramps" at University Dr. North and Jamboree Rd. (northern terminus)." (AA) Caltrans Maintenance Chief, Tom Almany, expressed a concern about objects coming down from the bridges and landing in the maintenance yard. (TA) 1 I � I I � 1 Under related projects we were going to also discuss both ETC and FTC projects. (JLH) I The following comments are from George Beighle, Sr. Transportation Engineer with responsibility for oversight on SJHTC: "1. The Cover Sheet and the description „of project alternatives on page 3 describe both. the demand management and conventional alternatives as, six general purpose lanes, with median widths of 88 feet to 116 feet for the demand management alternative, and 64 feet to 116 feet for the conventional alternative. Page 2-31 further describes the conventional alternative as a six -lane facility with a 64 foot median. The conventional alternative must have, eight lanes with a 64 foot median width (or initial construction of six lanes with an 88 foot median) in order to be considered an -alternative., Projected traffic volumes will require five lanes in, the peak direction -peak hour to obtain better than level Gf-service "F".' There is insufficient space in the 64 foot median to provide n ,the, additioal two lanes required in each direction. 2. The cover sheet and. the "Potential Future Median Use Options" paragraph on page 2-20 indicate that ,sufficient area in the median will allow concurrent HOV, lanes and transit facilities. This is not true with the conventional alternative, and is contradicted by section ' 2.6 (page 2-31) and section 2.8 a (page 2-36) which correctly indicate either HOV or transit facilities. The statement in this section, "The cross sections of both design alternatives, however, reserve sufficient area in the median to allow the median to be converted to concurrent HOV lanes AND a fixed guideway rail./transit system including I transit platform stations" is NOT compatible with a 64' median. It is in direct conflict with Section '2.6 ' (page 2- 31) and 2.8e (page 2-36). The statement in the third paragraph on page 2-36 describing the 32 foot wide by 16 1/2,foot envelope for a fixed guideway transit system does not mention that the"envelope" must be 't split at each overcros:sing structure to clear the center bent 1 columns, as correctly described in the HOV/Transit Median section on page 31." (GB) Headquarters comments on Chapter 2: "Page 2-2, last paragraphs "The reversible- HOV lanes will utilize automatic toll collection systems �. exclusively." What happens to the. occasional HOV user, the tourist or the motorist who inadvertently gets forced into the reversible HOV lanes and does .not have an AVI number attached to the car.? (JH) Page 2-4, Table 2-2-A: The FHWA wants at least toll -free interchange north of the I-5./S_JHTC interchange. Avery Parkway only has ramps on the -north side. This does not provide a toll -free ramp for northbound traffic - no northbound off -ramp. .Moulton Parkway -La Paz would be the 1st interchange with a northbound of .' The Table g P indicates this off -ramp as a toll collection location. (JH) Page 2-27, 2nd paragraph: Suggest changing the last word of the paragraph to "interchange" rather than �,p "confluence" . Using the confluence term may confuse the �n�'`�- reader with the "confluence" project - which is the I- 5/I-405. Interchange. (JH) Page 2-39, Table 2.8.A: Descriptions should be south to �'T north by convention. (JH) Page 2-42, 3rd paragraph: The confluence is I-5/I-405, }i not I-5/I-45. (JH) Page 2-51, Table 2.8E: 2nd column from the left - �� "Number of large cuts and fills>" Define what is a large cut and a large fill. 2nd column from the right - "Air quality". Isn't this a superfluous column? All the impacts are identical. (JH) Page 2-53, Improvements to State Route 74 (Ortega OtHighway): Caltrans has not prepared a ND/FONSI for the project. (JH) ! Page 2-54, 1st paragraph: The second phase between I-5 �II and SR-73 is completed. (JH)" 3.0 AFFECTED ENVIRONMENT Page 3-1 is mostly blank. Typist should fix. Same on page 3-15. 6� BIOLOGY Comments from Headquarters: "Section 3-6, page 3-16, Plant Communities: The DEIS refers to the Biological Technical Studies document which r is titled as a Biological Assessment on the actual I report. To minimize confusion these should be consistent. (MS) GEOLOGY/GEOTECHNICAL ! Comment by K.A. Cole, Sacto Translab: Pg. 3-2; Seismic; The second sentence states "There are several local faults, none of which are reported to be i potentially active." The Geotechnical Report presents the reasons for considering these faults inactive and should be referenced here. To merely state that faults have not been reported to be active is not sufficient to establish their potential for activity. (RAC) WATER QUALITY AND WETLANDS Headquarters comments from Harold Hunt, Translab,: ((r p. 3-6, 3.3 WATER RESOURCES. Add brief statements. describing the beneficial uses of the waters of the project area. p. 3-24, Plant_ Communities. Suggest inserting the definition �Q of Wetlands from page 3-27 to just prior to Grassland on this page. (7�! p. 3-25, Wetland habitat descriptions.-Add•brief statements listing the functions of the wetlands of the project area. p. 3-27, Acivatic Resources. The discussion of Bonita Canyon Creek contains the statement "This drainage is narrow along most of its length, but there are,occas.i.onal pools where the water collects, These. areas are- deep enough to provide aquatic habitat." Be more specific about the type of aquatic - habitat. Is this the suspected habitat for the southwestern pond turtle? pp.3-29 & 4-68, Tricolored blackbird and southwestern pond turtle. The analysis for these species on p. 4-6-8 seems weak. Q�I The appropriate habitat for these two species is limited in U ! the project area and the analysis could be more specific. (HH) Comment from Mark Stopher, Caitrans Wetlands Expert: Section 3-6, page 3=27, Wetland Definition Although I, and other people working with wetlands sometimes refer to the Unified Federal Method, the correct name for the reference is actually "Federal Manual for Identifying and Delineating Jurisdictional Wetlands". For accuracy,I suggest replacing the second paragraph with the following: "For this study, ' wetlands were identified using the Routine On -Site Method described in the "Federal Manual for Identifying and Delineating Jurisdictional Wetlands". Habitats identified as wetlands include portions of the �p Forested, Scrub/Shrub', and Emergent plant community types." The list contained in the previous sentence may not be all inclusive because there are some inconsistencies between plant community names in the .Biological Assessment, the text of Section 3.6 in the DEIS and Figures 3.6. (1-5). (MS) The DEIS doesn't present any information on the extent of wetland resources which,exist within the project vicinity and the relative impact of this project on those resources. The DEIS should include a sentence or two explaining the wetlands are very scarce ..(due to climate, topography, and past development) and, the, threatened type' of habitat in the regional setting. This would provide some support for 'the significance determination.. (MS) I� �i f Comments from Sylvia Wells -Vega, Caltrans Biologist: Page 3-27, Why does the consultant insist on using the USFWS definition of a wetland? Please use the following: Wetland Definition: The Army Corps of Engineers (ACOE) and Environmental Protection Agency (EPA) jointly define wetlands (�l as "Those areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs and similar areas". (per Caltrans Guidance for Consultants, May 1989). (SWV) ARCHAEOLOGY/106 CLEARANCE AND 4(f) "Page 3-44, Section 3.10 Affected Environment: This section should discuss the progress of the Section 106 process to date. There should be a statement that the APE for cultural studies was set by the FHWA (1st step in the 106 process), that an HPSR was prepared, and that SHPO concurred in: 1) the adequacy of the studies and findings of the HPSR, and 2) the eligibility or ineligibility of the properties identified in the HPSR. (MB) Page 3-44, 3.10 Historic/Archaeological/Paleontological Resources: Under the paragraph "Historic Resources" the dates of the survey and the names of the architectural Ot6 historian/historian should be added. Also the number of buildings within the APE and their approximate age and type i as well as the number (and brief description) of pre-1945 resources actually inventoried. (GS)" AIR QUALITY Comments from Caltrans Headquarters, Suzanne Lewis, TMR: Pg 7 (Technical Report) - Table 2: The 8 hour CO concentrations should be shown also. Is the data the first annual or second annual maximum? / Pg 18 (Technical Report): The assumptions for temperature and sigma theta should be listed. (SL) Pg 4 (Technical Report) & pg. 3-9 (EIS/S): CO Federal Standards and State 1 hour Standards are whole numbers, CO State 8 hour Standards are to the tenth. Pg 5 (Technical Report) & pg. 3-10 (EIR/S): The CO levels do not appear to be decreasing during 1986-88 for the 1 hour or 8 hour periods. Pg 5 (Technical Report) & pg. 3-10 (EIR/S): The discussion �C on the background measurements is weak. Where were the measurements taken? How was the data reduced? The highest measured value should have been used for the background level:" 1 1 1 1 1 1 1 1 1 1 1 1 Comments from Caltrans Transportation Engineer, Environmental Analysis Acting Chief, An Ph -am: On page 3--10, paragraph 2, last sentence should read The Federal and State 1 hour standards were not exceeded..." (AP) NOISE Comments from Caltrans Headquarters, Suzanne Lewis, TMR: h� s Pg 3-11 (EIR/S)': Leq should be described as an average noise level on an energy basis. 1 Pb Pg 4 ( Technical Report) & pg. 3-13 :( EIR/S )• : Do the schools fall under Section 216 (School Noise Abatement)? (.SL) HAZARDOUS WASTE/MATERIALS (JLH) Number of businesses in third line of paragraph 1 is "11 businesses". Insert as a last sentence under first paragraph: "Review of the files from Orange County Health Care Agency for locations 1-7 revealed the following:" Move Coyote Canyon Landfill paragraph to end of chapter. Renumber starting with Shell'as number 1. Figure 3.11.1 has to be changed because numbers change. Page 3-48: Insert a new paragraph with a heading "Field Inspection Only". and add: Field inspection of sites 8-1 revealed no potential hazardous waste/material to be encountered_ at these sites. There are no files at.Orange County Health Care Agency for these businesses. Insert a new heading called "Landfill".. Under this put the Coyote Canyon Landfill paragraph. 4.0 ENVIRONMENTAL CONSEQUENCES AND MITIGATION MEASURES I believe it would be helpful to the reader- if you would put the page numbers in a third column where the issues indicated in the checklist are discussed. All items marked with -an asterisk should be discussed. My review showed not all were indicated in the section referencing the checklist. Re -check the. sections and indicate in the first paragraph -those checklist sections it discusses. Are the questions answered -posed by the checklist? Recheck your sections to ensure that is the case. For, example, Checklist No. 2, "Will the proposal --destroy, cover, or modify any unique geologic or physical feature? The checklist says there .is an impact but it is- not significant. Then go to Geotechnical, first paragraph, where it says this discussion addresses checklist numbers 1, 21 3 , . and 4. - Looking through the geologic -section I don't see where this issue is discussed. (JLH) 01 Checklist number 4, soil erosion -or siltation is not a geotechnical or seismic issue. Why is it addressed as a checklist item under V.,A geotechnical. This is what I am saying. You should go through all these sections to make sure this is what you really mean. (JLH) JD5I don't see a checklist reference to wetlands or public services. ' (JLH) Number 43 has a sub 1 which may or may not be ok. I've never seen that before. Usually, it is discussed within its section. (JLH) r . Regarding circulation I know I suggested taking a lot of that material and putting it in Chapter 1. Traffic and circulation impacts could go in here, but I believe we need a team meeting to decide what goes here and what goes into the traffic section up front. Chapter 4 is impacts only, not setting or justification. (JLH) I(Pj, Checklist pages are out of order. (JLH) Headquarters comment - Significant Unavoidable Adverse Impacts: The statement indicated no significant unavoidable adverse impacts. This section begins on page 4-6 and addresses checklist numbers 11 2, 3, and 4.- On page 4-3, the checklist indicates that numbers 1 and- 4 will have a significant impact. Apparently, there is a conflict. (JH) Page 4-3, Environmental Significance Checklist No. 21, should the right hand column indicate a "yes" considering mitigation? (JH) GEOTECHNICAL/SEISMIC Sacto Translab (K. A. Cole) comments: Pg. 4-1; Mitigation Measures; Mitigation measures for potential slope instability, including seismicly-induced failures, needs to be addressed. Item 2-4 "Fault zones exposed in cut slopes will be Aavoided where feasible." There is no previous discussion of potential problems from faults in cuts and there is no mention of slides in the mitigation section. Pg. 4-7; Slope Stability/Landslides; The last sentence states that "Seismic activity such as ground shaking is not expected to significantly impact cut and fill slope stability." Our \1� recent experience on Highway 17 after the Loma Prieta Earthquake of October, 198, showed that seismically induced landsliding can and should be a major concern in a seismicly active area. The geotechnical report states that there are many areas along this project which are underlain by either old landslides or adverse bedding orientations. Slope stability under earthquake shaking conditions is of great concern to CalTrans and needs to be addressed fully. (KA.C) 1 1 1 1 1 1 1 1 I � „A1 NOTE: Page 4-7, paragraph 3 appears to contain conflicting information. (JLH) 1 1 Sacto, Comments Gerald Pearce '(Sr. Materials and Research Engineer) comments: "Your May 8, 1990 FAX requested my review of the geotechnical sections of the Draft for "fatal" errors. Though perhaps not "fatal", geotechnical >>� engineers- do not use the word "loam", contained in Section 3.2.. I feel the report's credibility suffers when such non -technical generics are'substituted. The word is even less appropriate: where .the information source for the report is traced directly back to Geofon's report only a few paragraphs earlier., I suggest using "silty sands"' or "sand -silt mixtures". ` The section on "compressible -/Expansive Soils" in Section 4,.2 needs some work., The best compacted embanlnnents will settle if they are constructed, on compress-ible on consolidatable soils. True, for high embankments settlement can occur in the fill itself, but most of the settlement -is usually -doe to the underlying soils.- Such settlement will occur, is expected to occur, and accordingly will be provided. for in the construction to the extent that geotechnical engineering can address it. Seismically induced settlement is a secondary phenomena as it is only a possibility I am curious why the only mitigation measures mentioned are as seismic mitigation. Other, non -seismic conditions such settlement will require mitigation too-. Removal and recompaction of soft, cons olidatable' soils from fill foundation areas- is a likely mitigation measure, as are waiting periods, to allow settlement to diminish before paving or building bridges. What about mitigation measures for the l landslides? Some may be buttressed and others provided with shear keys. Still others may require extensive unloading in the form of large cuts extending well beyond the highway. That, to me, is.an environmental impact. Even areas with no landslides may require -such cuts if the toll road profile requires cutting through adversely -oriented bedrock. These easily foreseeable situations -should be addressed. Seismic mitigation measure 2-1 says that embankment may be supported on piles to mitigate liquefaction potential. I doubt it. Bridges on piles may be extended in -order to avoid placing embankments in such areas, but the embankments themselves probably would not be on piles., Other mitigation me.:,sures may be: stone columns, v.ibro-replacement, deep broadened fills, relief compaction, or strutted .wells, changing the profile, or others. The appropriate measure, will likely be the subject of considerable thought by the Mgeotechnical engineers on a site -by -site basis." (GP) WATER RESOURCES Comment from Dave Bhalla, Caltrans Hydraulics PS&E Group: Transportation Engineer, I 111. STREAM BED MODIFICATIONS: Please refer to para 2 of Sec. 4.3 relating to stream -bed modifications. Environment Impact has been stated as Significant. From Hydraulic Engineering 11(� point of view, no Technical Details are enclosed to verify the 1_I significant impact due to Major Diversions of Channels Fig. 4.3.1 & 4.3.2 show only the existing and diverted Alignments ' of CHANNELS on an extremely rough basis without any technical information of the diversions at all. Technical Details of diversions need to be provided. 2. BASE FLOODPLAIN ENCROACHMENTS: Table 4 .3 . a indicates 1.2 . 6 and 13.9 acres areas of encroachment under two ALTERNATIVES of the Corridor. There is Longitudinal Encroachment on 3 ` channels viz Coyote Canyon, Bonita Creek and Oso Creek (conventional Alternative only). Transverse encroachments take place on Aliso Creek, Laguna Canyon and Oso Creek (Conventional Alternative only). No details are available to check the areas of encroachment. Secondly, with the encroachment of Floodplain area of the streams/channels by the corridor, 100-year flood level is likely to rise. No details are available to verify the rise with respect to the encroachment, which is stated to be significant. As the corridor crosses the tributaries of canyons like Bonita Canyon, Velocities in the encroached floodplain hilly areas are most likely to be more than 10 ft, which are not desirable in the affected areas. Please furnish details in support of velocities in the affected areas." (DB) Comments from Norm Johnson, Caltrans Transportation Engineer: On pages 4-9 and 4-12 please resolve issues of alternative impacts with I-5 connection. Page 4-14 Risk Analysis does not discuss groundwater as a problem or the conflict between the county. He comments, some examples, call for a retaining wall to accomplish risk reduction. He 12' comments also the so-called levee is to prevent railroad ballast from being washed away, but may require some rock slope protection against the railroad track. This risk assessment may need some more work. A meeting should be called to resolve areas of controversy. Under Floodplain Assessment C, paragraph four, first page, change second sentence to read, "The Demand Management Alternative and the Conventional Alternative could cause significant longitudinal 1 encroachment into the floodplain." Delete the works "would avoid significant encroachment into the Oso Creek floodplain: whereas." (NJ) Comments from Harold Hunt, Headquarters Translab: p. 4-9, Streambed Modifications. Will the streambed modifications create the potential for streambed headcutting �14 , or for downstream deposition? p. 4-16, This is one of the better water quality impact discussions. The argument for dilution would be strengthened by providing streamflow data during storms of various intensities. (HH) AIR QUALITY Headquarters Comments: `.Page 4-24, Table 4.4A: The preceding paragraph indicates that the ,nf,[L table "..indicates either of the build alternatives..." The table � only accounts for the Conventional Alternative and does not account for the Demand Management Alternative. (JH) Page 4-27, Table 4.4B: The 4th column from the right, 3rd :entry (Serra Park) appears in error. The number would be -expected. to be in the area of 9.5. rather than 4.5.. (JH) Elements of plans and acts section should be removed to section �- 3.0. ( JLH ) ' Comments from Headquarters. Suzanne Lewis - TMR: Page 4-30: The concentrations used in the toll/no-toll comparison do not correspond to the concentrations recorded in Table 4.4B (page 4-27). (SL) Comments from Caltrans- Transportation Engineer, Environmental Analysis Acting Chief, An Pham: Typographic errors in Table 4.4.B: For the 2010 Conventional Alternative, the 1 hour CO predicted level for the receptor 3 should be 9.5 ppm. ' For the 1995 Initial Operations, the 1 hour CO predicted level for the receptor 7A should be 14.1 ppm and the 8 hour CO level for the same receptor should 7.7 ppm. 1 Sample runs of the EMFAC7PC should - be. included in the Appendix A of the air quality technical report. 1 The basis used to determine the emission factors for the toll plaza analysis should also be included in this Appendix." (AP) IReceptor site maps should show -locations like the airport, residential development. (JLH) i Comments from Headquarters: page 4-32, fourth paragraph, second L� sentence, "In 1978, EPA designated "change" "I ... oft all non - attainment" to "...on all non -attainment." (JH) Pg 4-24 (EIR/S): The DTIM discussion -was. not reviewed -.,by TransLab personnel. "pl,�2J �1 Pg 20 (Technical Report): The cold/hot start % assumptions 1 should be discussed. Pg 22 (Technical Report) & pg. 4-27 (EIR/S): The 1 hour concentrations should be expressed as whole numbers. Pg 4-30 (EIR/S): The concentrations used in the toll/no-toll 1 comparison do not correspond to the concentrations recorded ` in Table 4.4.B (pg. 4-27). (SL) NOISE Headquarters Comment: Page 4-45, Table 4.5A: What is recommended for sensitive l�r'r receptors: R14, R15, R16, R20A, R24 and R41. (JH) Page 4-60. Unavoidable Adverse Impacts: Statement indicates no significant impacts. This section begins on page 4-42, and (� addresses checklist numbers 19 and 20. The Environmental Significance Checklist indicates numbers 19 and 20 will have a significant impact. There seems to be a conflict. (JH) Comments from Caltrans Transportation Engineer, Environmental Analysis Acting Chief, An Pham: 1. The technical report on the Noise Impact Study should definitely have the title of San Joaquin Hills Transportation Corridor instead of SR 73 Extension. I 2. Table 6 on page 14 of the technical report shows the predicted 2020 traffic noise levels in terms of Leq(dBA) instead of CNEL (dBA). 3. Table 8 on page 18 of the technical report: a. For Category C, the wording "or B above" should be placed in the adjacent column. ��� + b. For Category D, the paragraphs referred to (lla and c FHPM 7-7-3) are for construction noise. We )4) C1 recommend to state only "undeveloped lands" under this column. 1 C. first sentence in the footnote should read '�/ q`he "Le h is " d. For Category E, the Leq(h) of 52 dBA should be specified as interior level. 4. Figure 11 of the Technical Report and Figure 4.5.1 of the draft EIR/EIS should indicate all receptor locations and numbers. The same Figure 11 represents the entire length of the corridor, each figure sheet should have a different number to represent a different section (Fig. 11-1, 11-2,...etc). 14� 5. Figures 11 and 4.5.1 do not cover the entire project length for the Conventional Alternative. P The stations in the last .four maps of the Demand Management in Alternative are inconsistent with the stations presented Table 11 of the Technical Report and Table 4.5..A of the draft EIR/EIS. } The last map illegible. of the Demand Management Alternative is 6. Table 11 of the technical report and Table 4.5.A of the draft EIR/EIS: I a. These tables should show two columns- of barrier heights -mitigated noise levels for both the Conventional Management Alternatives. 'These columns, and the Demand based upon their respective predicted 2.010 noise levels i are both represented in- Figures 11 and 4.5.1; respectively. b. In Table 4.5.A the asterisk used in,' -the "LEQ Noise Levels -Existing noise level (dBA)" column is inappropriate. C. Existing noise level for RI1 in Table- 4.5.A is missing. In Table 11 of the technical report the for R15 are lower"than predicted noise levels R11 and existing noise levels. Please explain. be d. For R14, R15, and R16, barriers at the R/W should considered. e. For R1, R17 & 19 mitigated noise level should be presented as noise level of 66 dBA may be considered as approaching 67 dBA. f. For R25 the recommended barrier height should be 10' as it is the minimum -barrier height to break the, line of sight." (AP) No specific mitigations are described. Even though locations of soundwalls are unknown, soundwalls should be included as a L mitigation with a statement such as, "location, height, and length �✓ to be determined during the final design phase of this project." (JLH) Comments from headquarters Suzanne Lewis _ TMR: "Pg. 5 (Technical Report) & pg. 4-42 (EIR/S): Noise should be studied at any peak volume condition (not just during peak traffic volumes), generally at level of service C. The County criteria discussion was not reviewed by Tr,-ansLab i7 personnel. ' Caltrans Pg. 19 (Technical Report) & pg. 4-43 (EIR/S-): 'of definition substantial as at least 12 dB increase over existing and greater or equal to 65 dBA. Pg 19 (Technical Report) & pg. 4-42 (EIR./S): It is not I Caltrans policy to not provide mitigation at • commercial sites. Pg 26 (Technical Report) & pg. 4-43 (EIR/S): The wall height within 15 feet of the traveled way is limited to 14 feet high. There is no Caltrans policy requiring a maximum 6 foot high barrier on structures. (SL) Receptor site maps should show locations like the airport, rC + residential development to show proximity to problem areas. Why include maps that have no walls or receptor sites in the document such as Figures 4.5.1 last two maps. This is ridiculous. (JLH) BIOLOGICAL RESOURCES (JLH) Page 4-62, paragraph 2, in stating that the project impacts include generation of fugitive dust and increased fire incidents related to construction, 1) is sensationalism, 2) not related to plants, 3) is construction related not relevant here, and 4) only a minor, temporary problem, if any. Please delete. Page 4-62 Section ��001 on Resource Categories, if it has to be listed at all, should be in setting or background information setting. I believe this should be in a Tech Memo. ' Page 4-63, Table 4.6.A, is Title Habitats the Impact? ►o�,' Page 4-63, more resource category information. Should be in a T.M. ' Page 4-64, Wildlife. Direct impacts, loss of individuals to road kills, is sensationalism again. Please delete or minimize its discussion. ' �(6 This section has too much technical and irrelevant information as does many other sections of the document. For example, sensitive ' wildlife species, paragraph 3, should be deleted. Under Mitigation Measures (page 4-83), eliminate guidelines for site selection. This is not appropriate place. Remove to Tech Memo or Mitigation Monitoring Plan to be referenced in Findings later. ' Comments from Sacto Headquarters: ' One .potential problem in the future may be the California gnatcatcher. The specie may be taken too lightly in this document. We would recommend the District keep an ongoing dialogue with FWS ' concerning this specie and potential requirements should it become listed. (SF) Sky lights appear to be unnecessary for the deer crossing. (SF) WETLANDS Headquarters Comments: I�QQ Q Page 4-87, Significant Unavoidable Adverse Impacts: Make sure there is no conflict with the Environmental Checklist in indicating significant impacts. (JH) a. Comment from Sacto Mark Stopher, Office of Environmental Analysis: I 1 Section 4.7, A remaining deficiency regarding the assessment of wetland impacts lies with the level of information available on the - context in which these impacts. occur. The DEIS does not,pres-ent -any information on the extent of, wetland resources which exist within the pro jectvicinity and the relative .impact of this project on those resources. I recognize that this information may be difficult to generate and/or 'may not be•available from existing references. However, it was my understanding that LSA was going to- review National Wetland Inventory, maps, and other regional information to evaluate the extent. of wetlands in the area. If that was done, it is not reflected in the DEIS. (MS) In the first paragraph of this section a statement is made that "All acreage impacts to wetlands are considered significant." If some evaluation of wetland resources in the area was performed, this would be a good place to summarize those findings to support this policy. At a minimum, the DEIS'shouid include a sentence or two explaining that wetlands are -a very scar-.ce, (dub to climate, topography, past development, etc.) and-threatened_type of habitat in the regional setting. This would provide some support for -the significance. determination. (MS) I - Table 4.7.A The footnote for Bonita Creek and Bonita Cyn. Reservoir should disclose the wetland acreage impacted by the Pelican. Hill Road project. It could be revised as follows: "Excludes X.XX acres of wetlands affected by the Pelican Hill Road project": (MS) Comment from Harold Hunt,. Headquarters Translab: ,,with regard to Wetlands, this draft is- a substantial improvement over earlier versions. In particular, the technical assessment performed for wetlands. has provided good information for use in the DEIS and�Blological Assessment. Most of my major concerns have been resolved. I have one substantial concern remaining with regard to Section 4-7 which is described below. The other comments are intended mainly to address inconsistencies and errors which can be easily corrected. With these changes I think the.document would be adequate for public circulation, at least with respect to wetlands. (MS) P. 4-83. .Replacement Site Requirements. The statement "2. Maintenance and monitoring goals will be established that are compatible with other mitigation areas." is unclear. The statement should be explained. (MS) Comment from Headquarters: Page 12 Summary and Page 4-73,. 80. and 82: It is not clear that there is no practic-al, alternative to taking wetlands. Refer to Appendix B. Page 4-83: should have wetlands mitigation plan and USF&W agreement now. (JR)� Significant Unavoidable Adverse Impacts: make sure there is no conflict with the Environmental Checklist in indicating significant impacts. (.JH) I Comment from Sylvia Wells -Vega, Caltrans Biologist: What constitutes "unavoidable losses of wetlands"? (SWV) Couldn't locate "Avoidance Alternative" (again). The Wetland Assessment fails to include this alternative. (SWV) 01 LAND USE ' City plans and general background information should be in 3.0. There is too much non -essential information in this IMPACT ANALYSIS section. (JLH) Headquarters Comments: Page 4-100., Unavoidable Adverse Impacts: The statement indicates that there will be a significant (� adverse impact. The section begins on page 4-4.8 and addresses checklist numbers 25, 30, 31 and 32. The Environmental Significance Checklist indicates that there will be no significant impacts. Again, there seems to be a j conflict. (JH) ME Leave out Potential Wetland Mitigation Sites Map. That map doesn't ! show much and as we discussed is not appropriate anyway since we have no negotiated sites yet. (JLH) HOUSING AND BUSINESS RELOCATION Comment from Allan Goldstein, Chief, Caltrans Relocation Assistance Branch: Review of Chapter 3-Affected Environment, Chapter 4-Consequences & Mitigation Measures, Appendix H-Housing & Business Relocation Study from screen check EIR/EIS. On 11/2/89, EPB requested that the R/W Relocation Housing Study group review the above -mentioned sections of the subject document. The following are our comments: The cause for substantial delay of this review is that mapping and a complete document was not provided with the initial request. (Having an entire document, versus particular segments, allows this group a more complete description of a given project.) A secondary cause for delay was the special priority assignment delegated to this group which resulted in absence from the project for weeks. The above -mentioned chapters and sections generally describe where the housing and business impacts will occur. This information seems extracted from a previous writing of the DEIR, but this report states that Appendix H-Housing & Business Relocation Study is to be finalized. 1 1 r 1 F 1 [I L 11 C L� The Appendix H submitted does not address the minimum requirements or format to provide necessary relocation impact information. 1 The objective of a Housing and Business Study is to supply the Department with the scope of relocation requirements in a single project. It should recognize and identify who must be displaced, I what problems must be solved by the Relocation Assistance Program, timing considerations, types of units,, concurrent displacement, and a whole host of other items. The format for the Housing and Busines.s-Study should be a "stand alone" report with an introduction, purpose,' summary,, project data, Y relocation resources, and -appendix. The format submitted is merely a brief summary of the- Relocation Assistance Program, not relocation impact information to support the general description s written within the above -mentioned chapters. i It is this group's recommendation to advise the consultant to reorganize the information presented into a report format consistent with the current State and Federal guidelines. (AG) 1 . ARCHAEOLOGY/PALEONTOLOGY Gene Huey, Caltrans District 12 archaeologist, notes,on page 4-119, 5th (last) paragraph under Archaeological Resources, the last sentence should be changed to. read, All data recovery excavations will be in conformance with an approved mitigation plan approved i by the State Historic Preservation Officer". (GH), pi I Comment from Headquarters - Page 4-121, Significant Unavoidable t� ; Adverse Impacts: Here we go again!' There's conflict between the statement and the checklist for number 48. (JH) Additional comments from Caltrans Headquarters, Archaeologist, Margaret Russ: Page 4-119, Section 4.11 Environmental Consequences/Mitigation: General - the discussion of potential impacts to the sites will have to be _revised to include potential effects of blasting_ during construction and, possibly vandalism. 41th,paragraph: Environmental documents do not mention why site locations are not given; this line -should be deleted or modified to say "...are not included because of legal requirements, regarding site confidentiality (Archaeological site information is, specifically exempted from ;the Public $�p1 Information Act because of the importance of confidentiality, and thus it is not discussed or disclosed in - documents). Delete the line about "Persons with a valid need to know.." Caltrans and TCA should not release this information to j anyone. Violation of site confidentiality can result in sanctions against the agency. 1i 5th paragraph, line 8: Appendix G should also include the ' letter from SHPO concurring on the HPSR and on project I effects. ' { lines 11-12: delete reference to the HPSR. The effects and mitigation will be discussed in a Finding of Effect report. Mitigation will be in conformance with a \ treatment program to be included in the Findings of Effect report. NOTE: The FHWA usually requires the views of the SHPO ' on effects prior to circulation of the DEIS; while this can be obtained informally by memo, it is preferable, if , possible, to have SHPO concurrence on the Finding of Effects document. If that is accomplished, then this section should so and should include a letter concurring on effects in Appendix G. 4(f) Statement: Two of the archaeological sites which have rock art are likely to be determined to be eligible under criterion C and thus "to warrant preservation in place." lqj-li Depending on whether or not these sites are inside the APE or ADI, FHWA may have to consider them as 4(f) properties. That ' decision is still pending info about the site boundaries in relation to the ADI. (MB) Please split the Location of Housing and business Displacement fold Iq p out in half into two 8 1/2 x 11 maps. HAZARDOUS WASTE/MATERIALS Girgis, Caltrans Hazardous Waste Management Coordinator requests: ' Page 4-122, first full paragraph. When discussing hazardous waste, it should say "hazardous waste/materials". Eliminate the first sentence. Use word "would" rather than will when discussing the project. Intl Second paragraph, eliminate the words, "As noted on Table 4.12.A" .: ' start sentence with "The". Mitigation Measures: Delete the following sentences from mitigation 12-1: "Hazardous waste mitigation could involve on site treatment, removal of contaminated wastes to a Class Treatment or l�3 disposal facility, transport off -site by a certified recycler or some method of encapsulating the contaminated material. On site treatment is regulated by local authorities and may include neutralization, solidification, chemical processing or any ' acceptable on site treatment based upon currently available technology." Table 4.12A: Fix Title. Reference numbers change - should be 1- ' 10; eliminate No. 1, the landfill, and fix legend. Legend should _11 denote what DM, and C stand for. I would recommend deleting this Table. It doesn't add to the project. Hazardous Waste is not a significant issue. ��� , Page 4-124: Eliminate mitigation numbers 12-3 and 12-4. f's eet from NOTE: Is it true the boundary of the landfill is only 20 f 1� 6 the current alignment. (JLH) ' PEDESTRI"r EQUESTRIAN AND BICYCLE FACILITIES Comments from ,Headquarters - Page 125, Bicycle Trail Facilities, jqIr 3rd paragraph: The first sentence addresses Class II bikeways - How can the conclusion for the second sentence,dealing with Class bicycle facilities be obtained? (JH) LANDFORM VISUAL RESOURCES (JLH) Delete aesthetics principles and goals pages 4­129; 4-130, visual effects criteria, 4-131 and 4-132: We should have views to the corridor and views from the corridor at strategic locations. Under Mitigation Measure,'I don't believe cuts, maximum and minimum provide Mitigation Measures. At the beginning of the section a short paragraph can point out the project was designed in order to sensitively .address the potential impact as best it could. Also, I don't like anywhere in this DEIS, where it states as a Mitigation Measure, "where feasible." That is a "weasel phrase." I, think throughout we should be site specific. Where we, can do'something it should be so stated,, Significant Unavoidable Adverse Impacts section doesn't tell me anything. We recommend putting two photos per page ta avoid extra pages, a lot of white space, and the several blank spaces. Comment from S. Ankasirisan (Kevin Tong,,Landscape Architecture): Section 4.15.2 - Mitigation Measures 1. Planting and irrigation solutions shall be in accordance to the 'landscape architecture guidelines prepared by CDMG/Caltrans Landscape Architecture. 2. Does "start-up" irrigation systems as described on page 4-1�66 and elsewhere refer to _a temporary irrigation system during plant establishment? 3. The Project Landscape Architect should perform the tree survey with the Project Biologist. 4. Figures 3.6.1 to .3.6. -show that the proposed corridor alignment will affect several oak savannahs and woodlands; identify what mitigation measures may be used. a. Please refer to the memo regarding Senate Resolution No. 17 -- - Oak Woodlands that requires the preservation and protection of --" 5. Any proposed plantings shall maintain visibility of existing business signage in Caltrans as specified Outdoor Advertising Act. ' Other 1. Recommend that the corridors be designated as State Scenic Highways. Have noted that the corridor does not have any County of Orange Scenic Highway Designations. 2. Visual impact assessments not complete for all corridor n� elements and locations. (SA, KT) Imo' CIRCULATION Comments from Caltrans Transportation Engineers, George Beighle, ' and Norm Johnson: 4-169 should be edited. Delete after words LOS D in the fourth , line of the last paragraph, the words AT MOST LOCATIONS, delete those same words in the sixth line: in the 7th line delete the words within the parenthesis. Caltrans design engineers request this edit. (GB, NJ). 4-172, our design engineers require a qualifier in paragraph two, third line from the bottom, to read: "level of service throughout ' MOST LOCATIONS, MOST OF the day. (GB, NJ) 4-173, first paragraph, third line, LOS E should be changed to D (per Caltrans design engineers who have discussed with George Dore). (GB, NJ) Page 4-178: Delete the sentence from caltrans Maintenance Station that says "The volume of trips would increase for emergencies, traffic accidents, overturned trucks, spilled loads and other road debris." (JLH) Starting with page 178 of Chapter 4, West End Studies, there appears to be too much information on theoretical deletions of roads taken from that report. Please delete the information between 178 and 188.HOV information should go somewhere in Chapter 1 under its own heading. (JLH) Regarding mitigation: Park and Ride lots are not proposed as part rIf, `" of this project. Mitigations 16-1 through 16-3 can be included in Z�p Chapter 1 in a little different form. They are problems to be , resolved but not necessarily appropriate as mitigation measures to be included in Chapter 4 and in the Mitigation Monitoring Plan for this project. (JLH) ENERGY r; Comments from Headquarters.: , Page- 4=90: The construction impacts 2 should include energy consumption.. Comments from Headquarters Suzanne Lewis-TMR: ' 1. Pg. 4-187 (EIR/S): Build cases should be compared to existing route if' possible (even _ surface streets if necessary). The comparison of energy consumption totals is meaningless, unless. the alternates have the same volume (of vehicles or passengers). Payback periods can be a helpful comparison between alternates. J 2. Pg. 4-192 (EIR/S)i The 10% increase in fuel consumed for the no -build case should be explained better. I -don't know if I it. agree with 3. Pg. 4-190 (,EIR/S): The construction impacts should ' include the energy consumption. (SL) District 12 response Headquarters to comments above: P A telephone conversation was made between -Suzanne Lewis of HQ and Leha Tran of our staff on June 11, 1990 to clarify that comment: 1. If. there is no existing route and/or no surface street representing the entire proposed corridor, HQ suggested that the environmental document should include a statement such as "there is existing energy being used; however, it is undefined". J 2. The comparison of payback periods between alternates may be � included in other project(s) in the future. We will contact I' HQ.to define new format o,f the Energy Table. 10.0 LIST OF PREPARERS Comments from Headquarters: ,The names and qualifications of the architectural historian and historian who conducted the survey and prepared the HPSR should be added to this section. (GS) Please replace Girgis insertion with the following change: A.Girgis - Associate Transportation Engineer 1 t� P.E., B.S., Civil "Engineering; 35 years experience in engineering, surveys, construction,, maintenance, materials testing, reports, highway design; 2 years experience as District 12 Hazardous Waste Coordinator Please make the following additions: Sandy Ankhasirisan, Chief, Landscape Architecture Branch - nn R.L.A., B.S. Cal Poly Pomona; 15 years experience in Project Development and Landscape Architecture 1 Kevin M. Tong - Associate Landscape Architect R.L.A., B.S., Environmental Planning and Management Landscape Architecture, University of California at Davis. , 9 years experience in Project Development and Landscape Architecture. Comments from Headquarters: Page 10-1, List of Preparers: The D names and qualifications of the architectural historian and historian who conducted the survey and prepared the HPSR should be added to this section. (MB) APPENDIX A, SECTION 4(f) Comments from Headquarters: Attachment A is out of order - should follow Section 4 (f) . (JH) Visual Impact Analysis. Rancho Viejo Bicycle Trail: What's 6:•fc� the difference in the photos on the two pages? (JH) ' 12 J� Your attention is directed to T.A. pages 44-46 for format and content of 4(f).(JH) Page 4-136 and 4-137, Figure 4.15.1, Spotted Bull: Need comparable exposures to get the intended impact of the retouched photo. (JH) Pages 4-138 and 4-139, Figure 4.15.2, Paseo de Colins: The left hand photo composite needs similar exposures. Are the G� ' two photos on the right hand page the same Demand Management Alternative as the titles indicate? (JH) Pages 4-152 and 4-153, figure 4.15.8, Turtle Rock: What is the difference? , The project description paragraph 2, page 1, is misleading. Please correct. (JLH) You may reference Chapter 2.0 for details regarding the project 2description. (JLH) f An introductory paragraph should briefly state the project will cross (# ) pedestrian, (# ) bicycle and (# ) equestrian trails that fall under the 4(f) resource category. The proposed corridor, 22� ' through cooperative planning efforts with cities and county in the area will avoid impacting Crystal Cove State Park and Irvine Coast Wilderness areas. (JLH) Figure 1 should contain a legend that lists what the #'s are by name. There is plenty of room. (JLH) Each 4(f) resource should have its own map showing located after Ul its description showing corridor, impact to resource. (JLH) I think it is a little confusing that avoidance alternatives and y_)I'; measures to minimize harm don't address each particular (4(f) resource, the method used in early parts of this sections. (JLH) In 11 P 7 G Measures to Minimize harm, I think, should be site specific. (JLH) List of agencies to whom letters were sent is blank. (,JLH)- Comments from Landscape Architecture: Item 8 regarding landscape plans should be revised; how will a "start-up" irrigation system assure natural looking slopes? (SA, KT) DISTRIBUTION LIST (JLH) ' Is this list inclusive? Seems to have some names missing. I just arbitrarily looked for Coastal Commission and didn't see it.' We should have a meeting to discuss the list so there are no agencies or group missing that should get copies. What about cities in the area, supervisors, commissions, politicians? Who is Molly King and who is Mary Ann Tucker for example? INDEX (JLH) Should be more comprehensive. I just spotchecked some items and see that Project cost,ssIt Gas 1 was seems the index should be at least twice n the _ g glossary. DOCUMENT LENGTH (JLH) The Technical Advisory for in provides uniformity and consistency �! the documentation of environmental and Section 4(f) documents. 1 1 FHWA subscribes to the philosophy that the goal of the NEPA process is better decisions and not more documentation. Environmental documents should be concise., clear, and to the point and should be supported by evidence that the necessary analysis .has been -made. They should focus on the important impacts and issues with the less important areas only briefly discussed. -The length of EIS-'s should normally be less than 150 pages for most proposed actions and not more than 300 pages for the most complex proposals. The use of technical reports for the various subject -areas is encourage to reduce the size of the documents. The level of discussion should be commensurate with the scale of �3the proposed project and the impact. The adequacy .of a DEIS is Cf measured by its functional usefulness in decision- making, not by I _its size or amount of detail.. Highly technical and specialized analysis ,and data should be avoided in the EIS and should be attached as. appendices , or - footnoted with adequate bibliographic references.,, ' Today, I discussed this philosophy at length with an executive at �• the Council on Environmental Quality in Washington D.C. They not only subscribe to this philosophy but have included it in Codified Federal Regulations. Looking for ways to reduce the document, we suggest.: 1ZI Glossary may be a section that could be deleted to save pages. 1 U, Deleting some of the visual analysis pictures both in the aesthetics section and in the 4(f) since quite a few either don't show much of anything or add to the document. Please go through this document with a critical eye. List those issues that are significant, then go through all the other sections and take out extraneouF information. Focus the document on those areas of concern. There are a lot of fold out maps that don't add much. Figures on pages 4-10 and 4-11 should be on 1 page, for example. There's too much emphasis on Park and Ride lots scattered about the document. It could be discussed briefly in one place since we are not building the Park and Ride lots as part of this project. Maps such as the Air Receptor Sites could be split in half and put on 8 1/2 x 11 back to back. They are only informational and don't need to be on a fold out. Again, why are Park and Ride lots shown on so many maps? There are other ways and places maps can be eliminated, combined, etc. as discussed in our comments. GENERAL COMMENTS (JLH) According to the Technical Advisory and Caltrans Environmental Handbook, fold out sheets should have the title or identification on the right hand side. Please make this change throughout the document on all exhibits. It is much easier for the reader who expects to find it there. An editorial comment, Title and Figure Numbers are too large. An 8 or 10 point would be better for eye - appeal, and should be in a separate block. Legend should be able to have its separate block usually to the left hand side. ! Throughout the document there should be a consistent indentation style. It seems to vary even within chapters. i Please have the consultant put all SJHTC EIS/EIR titles, chapter headings, subject and paragraph headings that are underlined in an outline form for Caltrans and FHWA use in future reviews. Mitigation numbers are out of order, and don't correspond with the a�'1�°: Summary. Mitigation 12-1, for example, is missing. FHWA prefers the title, "No Build Alternative". Please correct i throughout document. Headquarters Comment: Per the Environmental Handbook, Section 3-4.7: The document should have a separate section titled "Unavoidable Adverse Environmental Effects". This would summarize various parts throughout Chapter �4 and would be the basis for the Findings and Statement of Overriding considerations to be assembled at the conclusion of the environmental clearance process. (JH) 1 �1 �I L, 1 1 1 1 1 P 1 H r 1 L C� r r F 1 FROM:MISSION UIEJO TO:714 557 9104 JUN 11, 1990 4:49PM #291 P.02 PASSIOVI VIEJO COMPANY June li, 1990 Mr. Steve-Letterly Manager, Environmental impact Transportation Corridor Agencies 345 Clinton Street Costa Mesa, CA 92626 RE: Review of -San Joaquin Hills Transportation Corridor (SHTC) .Screencheck EIR/EIS Dear Mr. Letterly: Thank you for the. copy of the May 1,99.0 SJHTC Screenchack E3R/EI5. We view the most recent edition of this document as much improved over prior editions that we have. reviewed. Web ave only the following comments, to offer at this point. The comments are organized by page or figure number, with the comment following. Page or Figure N tuber Comment Exec. Summary We believe the level of significance after mitigation should be more. precisely stated. Since this is to serve -aa. a .document complying with 2JEPA and CEQA, we believe HV-1 each impact' category should _ identify whether the impact -has been reduced to an insignificant., level after mitigation. pg. 2-33 Alternatives Withdrawn from Consideration, subsection - With respect to alternative ,c land uses, ve believe the statement should be included that much of the area which `-2 would be considered for alternative land uses is currently governed by existing development agreements- and/or vesting j tentative maps.. The. local -agency changing land uses on these properties would be subject to, various remedies, which would 26137 LA PAZ ROAD • MISSION VIEJQ - CALIFORNIA 92691 • (714) 837-0050 ' JUN 11 '90 15:45 714 477 00183 PAGE.002 FROM:MISSION UIEJO TO:714 557 9104 JUN 11, 1990 4:49PM #291 P.03 I j. *2- June 11, 1990 Page 2 ' include specific performance and/or financial responsibility. while the rationale presented regarding General Plan and past planning efforts is accurate, it should be supplemented by an understanding of the Development Agreement and vesting tentative map status. This is a comment we have made before. fig. 3.6.3 Many of the areas shown on this figure have Ialready been graded and the resources no longer exist. With two anall exceptions, all of the land within the SJHTC project area in the Aliso Viejo Planned Community should be shown as either category 95 (Cultural Disturbance) or category 110 (urban/cultural - Alternative). The two exceptions are the small area of grassland and forested wetland along E1 Toro Road and the Aliso Creek area between the Aliso Creek Trail and the Edison maintenance ' road. All other areas have either been I graded or are being graded. We believe the exhibits throughout the EIR/EIS should be updated to reflect this situation. fig. 3.8.1 This figure does not show the El Toro Road i interchange. pg. 4-70 on June 4, 1990, the Orange County Planning Commission approved the, Aliso Creek Wildlife Habitat Enhancement Project located in Tower Aliso Creek. This followed the execution by the Board of Supervisors of a multi -party agreement ! between the County of Orange, the U.S. Fish and Wildlife Service, the California "�-�o Department of Fish and Game and Mission Viejo Company to provide for an enhancement project and mitigation credit bank. The removals within the Aliso Viejo Planned f Community for the S,7HTC in the area of wetlands has baen accommodated in this mitigation credit bank. We believe this mitigation credit bank should be mentioned in the EIR/EIS and used as mitigation to the extent of the mitigation within the Corridor. Additionally, the EIR/EIS makes I' no mention of the wildlife habitat pond which is located below the retention basin along B1 Toro Road. This pond was established in connection with a 404 and 1 1 J 1 1 I 1 JUN 11 190 15:46 714 477 00183 PAGE.003 , FROM:MISSION UIEJO TO:714 557 9104 JUN 11, 1990 4:50PM #291 P.04 June 11, 1990 Page 3 1 1603 Permit, and provides a stubsstantial wildlife enhancement of the area. Both of MVO these coments are comments we have made, previously. �f Thank you for the opportunity to review this document. We look forward to working with you on .the completion of the project. sincerely, a6��- C'V qj)tu Way Peterson Dirk/tor, Environmental Planning WP: c n JUN 11 '90 15:46 714 477 •00183. PAGE.004 1 5JHTC EIS COMMENTS, DUNE 1990 LiWA we would like to see the overall size of this document reduced to fewer pages either by eliminating portions of the document which neither the decision makers or public will find useful or by moving portions of the document to, technical study reports. '�. Specific sections which could be summarized or ,moved to technical reports are: water Resources and Visual Resources:. Realizing -like that this is a large project, we would still to see less documentation. Cover Sheet Redo cover sheet, Correct the EIS number, include I-5 widening between .SJHTC,and SR 74-Ortega Highway .i.n the description, strike 'RESPONSIBLE OR' from the heading RESPONSIBLE OR, COOPERATING AGENCIES', include Caltrans in the list of.cooperating Agencies, for the FHWA contact person use: .James Bednar, Federal Highway Administration,, 1'. 0. Box 1915, Sacramento, CA 95812-1915, (916)551-1310. Where. the cover sheet says comments -are due to one of the contacts shown above., provide a specific name and address for receiving comments. .- Rewrite the abstract to be more clear and provide more hard Alternatives include two- build information such as: alternatives: The Demand Management Alternative and the Conventional Alternative. A No Project Alternative is also included. '....sufficient median for -future expansion for other forms of mass transit. ' could lead a, person to assume that rail could be added to the median, after reversible or concurrent flow HOV lanes had been added. A clearer description could be provided to describe how the available median width would provide for future expansion for other forms of mass transit. insert the word 'build' between 'Both' and 'alternatives' on the sixth line. Under potential beneficial impacts describe where the improved transportation network is located. Also under beneficial impacts there is a discussion of northern employment, and southern northern and residential areas, this should be defined as southern orange county to provide clarity to the reader. Combine the potential adverse impacts into the first paragraph so that the abstract is contained in one paragraph. The abstract is Silent on the impacts, of the no project alternative, provide at least one sentenc.e,regarding the no project alternative. SUMMARY The content and construc:ti.on of the summary in flow general seems unorganized. The summary does not seem to as a stand-alone discussion of the project and its impacts. Look at the summary in total and improve how it reads. Many persons will read only EIS. the summary without taking the time to examine the entire 1 An important attribute of the SJHTC is the joint use planning of land use and transportation which has occurred within the corridor during the development of the project. Discussion of this should be provided early in the summary by discussing the planning which has gone into this project in a few sentences. Introduction The opening paragraph of the introduction states that ramp improvements will be constructed on the existing SR-73 between �-?-Lill Birch Street and Jamboree Road (see Figure S-1). Figure S-1 does not even show Birch Street. Paragraph three of the introduction states that the corridor was placed an the State Highway System in 1993, thereby making it eligible for Federal funding. Placement on the State Highway System makes a project potentially eligible for Federal funding not automatically eligible. Federal eligibility depends upon the type of work being done. The SJHTC is a tall facility which is generally ineligible for Federal funding. The STURAA Federal legislation of 1987 made the SJHTC toll facility eligible for Federal funding. Clarify these points in paragraph three using information which already exists in Section 1.4. Neesi_for Protect r First paragraph define the usage of LQS F. In the second paragraph say 'Assuming no Project' instead of 'Assuming no Corridor'. Be consistent in your terminology. The last sentence says that I-5 will have traffic demands of up to 330K vehicles per day compared to its present capacity of approximately 145K per day. Explain clearly what such figures mean in terms of congestion. Also explain for what year these I -a traffic forecasts were made. Third paragraph add the words 'without construction of the project' after '...heavier traffic volumes and through traffic movements...'. Figure S-i This figure shows the number of total lanes which are proposed to be built along each link of this project including climbing, weaving and auxiliary lanes. The number of lanes are quite large in some instances such as 14 lanes, 11 lanes and 13 lanes. Changing this format of the figure to show the number of through lanes and also the number of auxiliary, weaving and climbing lanes would be a better representation of the proposed project. It would more fairly represent the proposed project and also be fair to the readers of the EIS. a I �H-Yb fI, - a r DescriRtion of Project Alternatives, Include a scale drawing of each of the two build alternative, cross sections in this section of the summary.., & drawing to scale would clearly show the .reader what the .two alternatives look like. Reword this paragraph the same way that you reword the abstract. State that 'A No Project Alternative is also included.This paragraph states that the Demand Management Alternative ihciudes median space for -additional capacity while the Conventional Alternative includes median space for future expansion, these should be the same wording in order to be consistent. _ The two build alternatives have the same wording relative to the future of the medians when discussed in the abstract. This paragraph needs to mention somewhere that the build alternatives are toll facilities, an important factor in the description of the alternatives. Alternatives withdrawn from consideration Rewrite the opening sentence of this 'paragraph it is awkward. p� t7 when describing Mainline Plaza Location Alternatives use the word L° 'Toll', it is important to, help the reader understand what a mainline plaza is. Permits and avvrovals required IFor the agency U$ Fish and Wildlife service., Endangered Species should be added under the heading type.of decision. Page 4. The EPA also reviews and comments. to they Corps on any section 404 permits required for the project. (DH) determination will be Page 4. A federal coastal consistency required from the California Coastal Commission: The coastal permit is issued by the local coastal agency (e..g,.,' city or county) if the .Commission has approved the local coastal plan or by the commission if the LCP has not be. -approved. Both a -federal consistency and a coastal permit are required for the project. Documentation of the federal consistency determination from the commission is preferred in the final EIS; it must be obtained prior to FHWA approval of the record of decision, (DH) Public involvement In the third paragraph state that 'A Revised Notice of 'was Intent' published in 1989. Discuss the original Notice of Intent. Issues to be resolved tt i T6640.8A requires that the summary discuss major unresolved q y � a 1 issues with other agencies: The decision of which of the two build alternatives to chose is not the issue here, that is the overall purpose of the environmental and project development process. This section of the summary discusses major issues to be resolved such as Air Quality considerations. Other major issues may be appropriate here. Summary of Significant Environmental Impacts ' 'fable A. lists mitigation measures by number, such as 3-1, 6-1 to 6-11, and 15-17. Table A needs to indicate where the �z descriptions of these mitigation measures can be found in the EIS. (DH) The first paragraph says that the build alternatives will have a variety of environmental effects. It then states that these impacts are discussed in Chapter 4.0. To be consistent effects and impacts be interchangeably. should not used spell out what CEQA and NEPA stand for the f i.rst time that they are used. The last sentence of the second paragraph should be modified to say that overall this project has "significant impacts" (beneficial and adverse) on the quality of the environment. 1-0-Purpose-and Need Page 1-3. Table 1.3A should also provide "pictures" for LOS D and E. (DH) , 2.2 Common -Features The park and ride lots are not being built as part of this project and are therefore not environmentally cleared by this �n document. These facts may not be clear to readers of the Z'�`'1 document, but they must be. The park and ride lots Gould conceivably be proposed as a mitigation measure for impacts of the Corridor with respect to congestion relief, air quality, etcetera. 2.5--Demand Management j include complete description of how HOv drop ramps use available width in the median. 3.6 HiQloaical Resources Page 3-27, Wetland Definition. The first paragraph is inaccurate, and the FWS definition of wetlands is not to be used for FHWA projects. This paragraph needs to be removed. .4. LIN The draft EIS needs to document. compliance with 50 CFR g to the 4.02,.12(c) by including a copy of the FWS letter responding written request -for information regarding any listed or proposed species or designated or proposed critical habitat that may be present in the project area. see the attached August'2311989 memorandum. (DR) r The draft -EIS needs,to summarize the analysis from the biological 'in F assessment for each listed,or proposed species provided the FWS letter • See section 18 of the FHWA Technical. Advisory T 6640.8A Attachment (pages 31 to 33) for the issues that need to be addressed. Because of the potential for candidate species to become listed prior to completion of -project construction; it is IEIS- that- the biological. assessment and draft also .recommended address any candidate species provided in the FWS response. (DH) 3.11 Hazardous Waste � The description of identified hazardous waste sites in E2S subsection 3.11 is good; however, the generic, boiler plate r discussion in subsection 4.12 regarding impacts and mitigation is not adequate. The EIS -needs to provide impact and mitigation information that is specific to the -project as outlined in l section 20 of the FHWA Technical Advisory T 6640.8A Attachment (page 34). 4.3 Water The hydraulic and hydrology areas are seriously lacking in content. A hydraulic study has reportedly been done, but nothing of significance was carried to' the PDEIS. specifics are as follows: No runoff information is given - flow rates, velocities, frequencies, depths, etcetera. Several significant channel -,changes will .be required. The length is given but the impact is not discussed. This area is considered to be grossly inadequate. Floodplain encroachments are identified, but the extent of the encroachment and the impact are undefined. Information provided is inadequate. Runoff detention is mentioned, but the discussion is inadequate for the rader to be able to.identify what is y intended on the project'. (AW) 4.4 Air t The discussion of SIP conformity -is irrelevant-. An FHWA project appears in the regional Transportation Improvement Program which 1 W. is found to be in conformity with the SIP. The following statement should be included: Oil November 3, 1987, the Ninth Circuit Court of Appeals issued an opinion vacating and ordering disapproval of Environmental Protection Agency's (EPA's) previous approval of ozone and carbon monoxide (CO) control measures for the South coast Air Basin (SCAB). The State Implementation Plan (SIP) for ozone and CO in SCAB was disapproved by EPA on January 22, 1988. This project is in an area where there is not an approved SIP currently containing any enforceable Transportation Control Measures (TCM's) for ozone and co. Therefore, the conformity procedures of 23 CFR 770 do not apply to this project. A SIP revision has been developed for this area by the local air quality and transportation' planning agencies, but that SIP revision has not been approved by EPA. The mobile emission analysis of the area's air quality management plan, included in the proposed SIP revision is based on a Regional Transportation Plan (and Program) that includes this project. Therefore, it is expected that if a SIP revision is approved for the project area, that this project would conform to it. 4.5 Noise Were the noise effects on adjacent lan the toll plaza/booth locations? Stop tool booths and plaza make the noise normal freeway facility. 4.6 Biolocxical d use analyzed for all of and go traffic at these effects different from a in a series of letters during 1988 FHWA expressed concern over grading impacts on three Federal candidate species: Many -stemmed dudleya, Turkish Rugging and the San Diego Coast Horned Lizard. Grading impacts to the two plant species were of concern in the area of the Aliso Viejo project. Pages 4-63&64 discuss impacts to these plant species. Have these impacts already occurred or will they occur in conjunction with the project? what impacts have already occurred or will be occurring to the San Diego Coast Horned Lizard? Page 4-65, first paragraph. The second to last sentence is so awkward that the information trying to be conveyed is unclear. It also indicates that Caltrans has developed roadway projects "in the Reno area." (DH) 4.7 Wetlands Page 4-83 states that impacted wetlands will be replaced at a minimum of 1:1. Although this may be the case for CEQA or local rt,A�f~ environmental Clearance, FHWA takes exception to anything greater than 1:1 replacement for wetlands. 6 h, I i A 1 1 1 1 1 1 I The draft EIS should provide evidence of project coordination ~( with the section 404 cooperating agencies (i.e., Corps, EPA, and the FWS) regarding the areas sub ,3,ect to Corps. jurisdiction, the impacts to these riparian, and wetland, areas, the mitigation proposed to reduce these impacts. (DH) 4.8 Land Use Page 4-97 states that the prime farmland rating- form is to be found in Appendix'F'. The actual rating form is shown in Appendix 4.11 Archeological/Patleontol4g�l i It is possible that FHwA will not participate in the cast to perform paleontological surveys: !fi General, All disuussion of potential vandalism should be deleted from the EIS including page 4--1191 Table 1 in Appendix D, etc. All reasonable measures shold be taken to prevent vandalism from occcurring as a result of release of information relating to archeological sites. Possible issues relating to vandalism shall be dealt with in the Section 106 effects documentation and consultation with the State Historic Preservation Officer through Caltrans and FHWA. Page 4-119. The Determination of, EligibilityAs one•,step in the Section 106 process and does not f'conclue that the 'proposed preoject conforms to the requirements of 36 'CFR $00 ..." 'r, • %r"fit Coordination with the State Historic Preservation officer (SHPO) has been ongoing for nearly ten years 'including the .submittal of f 'a number of studies, to identify National Register- eligible historic properties that might be affected by the project to the i SHPO for review. The studies should be listed and the. SHPO included Appendix G. response letters should_be in 4.12 Hazardous:Waste The discussion here states that only 4 sites will be impacted by the conventional alternative. Table 4.la.A shows 3 sites. Why the discrepancy? - The discussion. here also states that Figure 3.12.1 shows the sites when in fact Figure 3:12.1 shows bicycle and riding/.hiking, trails, and Figure .3.11:1 shows hazardous waste sites. 14..0 Index Page 1.4-1. The EIS index needs td include a listing for "coastal zone," "section 40,41" " and "section 4,(f):it is unclear why "wetlands" and "wildlife" have been included under "threatened or :w endangered species"; they should be listed„separately,. (DH) 1 endix A. Section 4(f) Evaluation I The discussions of the section 4(f) resources need to be reformatted to separate the actual 4(f) use discussions from the proximity impact discussions. Based on Table A, only two of the 21 resources addressed are "actual" section 4(f) uses. With the discussions mixed it is not clear Which is which. (DH) The discussion of avoidance alternatives needs to address alternatives that avoid all section 4(f) resources. Alternatives ff ��� which avoid some put involve, other need to be address as harm 't minimizing alternatives. The presentation of alternatives needs to be revised to follow the alternatives selection process outlined in the FHWA policy paper attached to a Legion office November 30, 1989 transmittal. (DH) Each of the proximity impact discussions needs to conclude whether or not the proximity impact will reach a magnitude that will cause the existing or planned values of the site in terms of .-ri Lq its prior or potential significance and enjoyment to be substantial impaired. The degree of impairment needs to be determined in consultation with the officials having jurisdiction over the resource. Copies of correspondence from these officials on this issue need to be included in the 4(f) evaluation. (DH) where it is decided that there will be a substantial impairment r or a constructive -use of a section 4(f) resource, the draft section 4(f) evaluation must be cleared by the FHWA Headquarters Office prior to its circulation. (DH) The need to coordinate constructive -use 4(f)Is with the FHWA Headquarters office prior to circulating a draft section 4(f) evaluation also applies to such conclusions for other alternatives as is done in the discussion of "avoidance alternatives" on pages 24 to 31. (DH) The last column of Table A is unclear and troublesome. It is unclear which of the effects remain and to what degree. Does . a 3� "effect after mitigation" mean a significant NEPA and/or CEQA impact, a measurable effect not necessarily significant, or a substantial impairment so as to cause a constructive section 4(f) use? As indicated in comment 21, the text discussions of each of these resources needs to provide a conclusion with supportive -- information regarding substantial impairment of the section 4(f) resource. This conclusion is all that this column should repeat. The column heading and information either needs to be revised in this manner or eliminated. (DH) The section 4(f) evaluation also needs to address the Upper Newport Bay Ecological Reserve, the state Wildlife Preserve (located just north of San Diego Creek between Campus Drive and MacArthur Boulevard), and the Capistrano Bluff Open space as 8 1 1 1 1 1 f I i ., It M I 1 I 1 section 4(f) resources potentially affected by the proposed SR 73-. project or by explaining why they are not -protected by section 4 (f) . (DH) From the discussion on page a, it appears that sycamore, Hills (13) was reserved for the SR:• 73 corridor (a-nd other transportation features) and sycamore Hills (12) and (14) were planned for open space purposes in the development .plan the "SEIR for Sycamore Hills") for the entire Sycamore Hills parcel. if such is the case, then section 4(f) would not apply to the subsequent highway construction on the reserved right-of- way (Sycamore Hills (13)) as-lareviov-sly iplann d. Through. the joint planning and development for the three Sycamore Hills (12), (13), and (14) parcels,, any proximity impacts to (12)' and (14) from the subsequent highway- construction on (13) would not substantially impair (i.e., constructively use) (12) or (14) because the development of each of the three parcels has taken and will -continue to take the activities and resources of the other parcels into account. Therefore; if the above is true for the three Sycamore Hills parcels, the section 4(f) evaluation will need to .(a) provide documentation that., such is the case and (b) to outline all of the measures which have been and will be taken to jointly develop the highway (13) and the two open space parcels (12 and 14). (DR) Page 33. The letters of consultation sent to agencies were found in Attachment D rather than G. The responses were :not located -. A one -week turnaround for this type - of coordination is ! unrealistic; however,• perhaps by :now responses have been retceived and can be incorporated into the section 4(f)' evaluation:- ('DH) Page 11. The heading "impacts on Potential 4 (f ) Pr.operties't needs to be changed to "Impacts on the Section 4(f) Properties" or "Potential Impacts on the Section 4(f) Properties•." A section 4`(f) evaluation needs to address all 4(f) properties in the project vicinity, and all properties evaluated must be 4(f)• properties, not "potential section 4(f) properties." where there -�� is or may be a,question whether a :particular property is protected under section 4(f), the evaluation needs to explain/demonstrate why the -property is or is not a section 4(f) resource. FHWA makes the call whether, 'or not a- property is protected under section 4(f). (DH) The change in the view that is trying to be depicted -in Figures A-2 and A-1.0 is unclear. The before and after views appear the same. Also, is there supposed to be :a "view with the corridor" in Figure A -I? (DH) The EIS table of contents and index need to identify the location of the section 4(f)evaluation in the EIS. (DH) Q I -0! We need a plan or layout of each 4(f) site in Attachment A not 1 pictures, per the Technical Advisory. (DH) Each 4(f) property is to be described in terms of usage and the function of available activities onthe property per the Technical Advisory. Make sure that this is done for each 4(f) property. (DH) Pg. 5, (3)i - Figure A-2 shows Rancho Viejo not Goeden. Pg. 5f(4)&(5)b - insert 'Bicycle Trail No. 61' between the words r land' and 'paved'. Pg. 61 (10)&(11) - What is (11) actually, Woods Cnyn Park as shown on page 6 or Aliso Creek Trail system as shown on page 7? Pg. 6, (10) & (11) b - What is the size of the park, 5400 acres as shown on page 6, or 5000 acres as shown on page 7? Pg. 71 (10)(11)g - This discussion and the one which follows for Sycamore Hills refers the reader back to Chapter 1.0 for a discussion of the Laguna Greenbelt. Use a specific page number in referring a reader back to Chapter 1.0. Pg. S, (12)(13)(14)b - The 453 acres shown in this paragraph does not add up to the three parts shown as 69 acres, 67 acres and 324 acres in paragraph d. If (13) was donated for use by the corridor and that is all that the corridor takes, then there is no 4(f) for Sycamore Hills. Pg. 61 (12)(13)(14)d - This paragraph states that an equestrian trail is shown on Figure 1. Where is this shown on Figure 1? Pg. 8, (15)g - This discussion and the one which follows for Bommer Cnyn Park state that these resources are separated by the major ridgeline of the San Joaquin Hills. what importance does this have? 1 Pg. 9, (17)d - This sentence does not make sense. Why would a bicycle trail be improved to accommodate bicyclists? Clarify what you mean. Pg. 10, (21) - This paragraph mentions Culver Drive shown on Figure B-6. Culver Drive does not show on Figure B-6. IPg. 110 (1)b - Relate the anticipated noise levels due to No Project with the I-5 noise to the Build Alternatives with the ' I-5 and the Corridor noise. The Noise study report should have this data available. If the Build Alternatives make no !� appreciable difference to the noise impacts then there is no 4(f) ' involvement. This case holds true for several of the potential 4(f) sites such as the Rancho Viejo Bicycle Trail (2), Goeden 10 4-1 I �+ Equestrian Trail (3), Arroyo Trabuco/# 81 (4)(5), Hike Trail # 66 (17) San Diego cr/Santa Ana Heights Eq Tr/# 61 (18) (19) (20) , , Northwest Park (6), and oso Cr (7). Similar considerations should be given to air quality -impacts. Pg. 12, Table A, Impacts Summary - Shouldn't the indirect noise effects for Crystal Cove State Fark'be a No instead of a Yes? 2t do touch the at all. appears that the noise contours not park ` Pg.. 12, Table A, Impacts Summary - Should the actual use for the County of grange Bicycle Trail No. 61 (20) be No instead of Yes? I see no mention of an actual taking from this .trail in the 'page MW I narrative description of potential 4(f) impacts on .20. 1 1 1 f 4 1 pg. 13, (2) -- portions of this bike trail will be removed entirely. Discuss the opportunity for users of the bike trail to use other routes in lieu of the bike trail. These other routes may be other bike trails or streets. Use of these other routes should be examined in terms of what effect having to use these other routes will have upon the recreational users of the bike trail. pg. 13, (2)d Define. unusual and unexpected conditions during construction. This needs to be done for this property and also properties such as Arroyo .Trabuco Eq Trail/#81 (4) (5) , Niguel Eq Trail (8), Bike Trail #12 (9), AliS6 Creek Trail System (10),, Bike Trail #66 (17), San Diego Cr Channel/Santa Ana Hts Eq Trail/#61 (18)(19)(20), aso Creek (7)., pg. 16, (10) - Is Aliso Creek Trail System (10), (11) or neither? Pg. 17, (11)b - Will the noise impacts at Aliso/Wood Canyon Park effect any sensitive recreational activities or do the noise r contours simply pass through a portion of the park? If no sensitive recreational activities are impacted then noise could be discarded as causing a 4(f) impact. Pg . 17, (11) d and pg . 18 , (15) d - What are you saying about the wildlife dispersion effects in these two parks? Are you saying that these are wildlife refuges and therefore qualify under 4(f)? Page 33 under Measures to Minimize Harm states that a wildlife undercrossing will be built at Station 9844. Does this undercrossing location address the wildlife dispersion at Aliso/wood Canyons Regional Park and Crystal Cove state Park? Pg. 18, (12,13,14) - Will the noise impacts at, Sycamore Hills effect any sensitive recreational activities or 'do the noise contours simply pass through a portion of the open space? if no noise sensitive recreational activities are impacted then noise could be discarded as causing a 4(f) impact. Pg. 24, No Project Alternative - The last sentence should state " that overall adverse impacts are significant rather- than 11 extremely severe. �-, Pg. 26, Table C - Does this table represent the impacts of feasible alternatives to the build alternatives? Pg. 27, Table D - Show which alternatives are the build alternatives. It would be clearer to the reader which alignment alternatives are included in the build alternatives. Attachment B, Noise Contours - Include the property number (#) on the figures. ' Attachment G, Cooperative Planning - The material included in this section is good but unnecessary. Much of this material is repeated in other portions of the Bis. I think that the last t-'p section 'Results of the cooperative Planning Program' is good and should be retained. The remainder of this attachment can either be summarized or eliminated. Attachment D, Agency Coordination - The results of this Coordination will have to be included in the 4(f) evaluation for -- each property where there is determined to be a 4(f) impact. Especially important is the level of significance which the park agency places on the park facility, and any new or previously unknown recreational uses which they identify. Based- on the information provided in the Draft 4(f) evaluation the following properties can or cannot be dropped from further 4(f) consideration. If a property is found to not have 4(f) involvement it shouldn't be in the 4(f) evaluation section, but you may wish to discuss why it is not considered for 4(f) in a short paragraph: San Juan school (1) - Subject to the above questions concerning ,1 air and noise impacts relative to existing I-5 there is no 4(f) impact. Rancho Viejo Bicycle Trail (2) - Due to a physical take of a impactsportion of this needdefined.is are involved. Construction need to be Goede,n Equestrian Trail (3) - Construction impacts need to be better defined. Temporary construction disruption of the trail ��-tp'k does not constitute 4(f) impact. Subject to the above questions concerning air and noise impacts relative to the existing I-5 there is no 4(f) impact. Arroyo Trabuco Equestrian Trail (4) and Bicycle Trail No. 81 (5) - Construction impacts need to be better defined. Temporary construction disruption of the trails does not constitute 4(f) impact. Subject to the above questions concerning air and noise impacts relative to the existing I-5 there are no 4(f) impacts to these trails. 12 r, I I r� I � Mi ai 1 I � I ! i I Northwest Park (6) - Subject to the above questions concerning air and noise impacts, relative to the existing I-5 there is no t 4(f) impact. This park was also cooperatively planned which negates 4(f) impacts. l " ! Quo creek. Corridor (7) - This recreational area was cooperatively impact. planned with the corridor in mind.. No_, 4 (f) Niguel Equestrian Trail (8) - subject to the above: questions � V ; concerning air and noise impacts•- relative to existing adjacent roadways there is no 4(f) impact. Bicycle Trail No. 72 (9) The visual impacts make. this a 4(f) indirect impact. Subject to the above questions• concerning air and noise impacts r.el.ative to existing adjacent roadways there impacts. .may not be air and noise Aliso Creek Trail system (10) - The visual, noise and air impacts ff make this a 4(f) indirect impact.- Aliso/Woods Canyon Regional .Park: (11) - These parks received r cooperative planning to help avoid 4(f) impacts. subject to the above questions relative to the noise and wildlife impacts this is probably not a 4(f) impact.' Sycamore Hills 12 13,14, - This open space received cooperative planning to help avoid 4-(f) impacts. Subject, to the above questions concerning noise impacts -this is probably not a 4(f). Crystal Cove State 'Park (15) The. 'corridor has no� 4 (f ) impacts 1 D on this park. No• 4 (f) . Bommer Canyon Park (1.6) - The document concludes that there will be visual impacts upon this park Figure A-11 shows the view, from the park with the, Corridor built. Based on the views shown in Figure A-11 there is no visual indirect impacts. No 4(f). Bicycle Trail No. 66, (17) Subject to the above questions concerning noise impacts relative to existing adjacent roadways -�2 this is probably not a, 4(f) impact even though the bike trail will be physically -relocated as part of the construction sequence. San Diego Creek channel, Santa Ana 'Heights Equestrian Trail, Bicycle Trail No,. 61. (18,19, 20) - Subject to the above comments 1 3 relative to noise and air impacts relative to existing roadways this is probably not a 4(f)-impact. Bonita Creek Park (21) - The noise impacts upon the driveway and parking area do not constitute .a 4 (f ) impact therefore there is no 4(f) at this park. a Appendix.._B, Wetlands EIS, Appendix B and Biological Assessment Technical Report, page 67. The "wetlands assessment" in Appendix B is so general and provides so little information that it is not meaningful. It is understood that this "assessment" is supposed to be the precursor to a final EIS wetlands only practicable alternative finding; however, this finding, if required, is for the preferred alternative in the final EIS and is not to be placed in the draft EIS. This "assessment" should be eliminated from the draft EIS. (DH) A2nendix D. Archeological "of Y -- Appendix D. Delete Effect" from column headings "Location of Effects ... It and from Table 1 title. Appendix D. A dash or 'IN/A should be placed under the column I4-rII headed "Potential Impacts" for sites CA-Ora-1082 and -1085. These sites are identified as destroyed, ineligible sites. Therefore, there is no project impact. Appendix D. CA-Ora-737 is identified as not eligible with 20 ' percent of the site in the ADI and with potential indirect TAM -75; impacts. The discrepancy between the ADI column and the potential impacts column should be corrected. jAppendix D. Additional refinements to Table 1 may be warranted based on results of effects evaluations. At present FHWA does not have clear information to support the indirect impact for CA- 4ra-107, -270, -1082, -1085, and -1092. In addition, geotechnical studies may conclude that direct impacts on CA-Ora-- 270 and -1088, the rock art sites, will likely occur as a result of blasting. As this project involves some unusual potential effects, close coordination with Caltrans and FHWA should be --70 maintained. For instance, the APE upon which the studies to date if is based was made larger than the ultimate project area of effect in order to allow for shifts in the project alignment in the planning stages. This original. APE might be more accurately considered a Study Area. Therefore, it is expected that adjustments to the APE will be evaluated and approved by the FHWA Area Engineer for inclusion in the Section 106 effects evaluation and will potentially require changes to Table 1. Biological Assessment Technical Report_May 1, 1.9go t�4-t E.O. 11990 does not apply only to "transportation facilities and projects" as stated on page 67 of the technical report. It applies to actions of all federal agencies. Biological Assessment Technical Report, "Analysis of Alternatives- Wetlands ImRacts.11 1A t ' EIS page 4- Notwithstanding the fifth paragraph on pre -draft 80, this "analysis" does not provide -the -alternatives analysis required by the section 4.04(b),(1), guidelines as outlined at 40 CFR § 230.10. The.";analysis" provided only indicates without ;.supportive information that some F r-f, alternatives are- not practicable and Eor the other it identifies impacts and alternatives considered just possible mitigation sites: Alternatives ,that completely avoid or that -,reduce impacts 'to each wetland area need to be evaluated. If such alternative's are- not practicable, specific reasons with supportive information need to be given. In addition, the identified "project purpose and need" is very general and not clearly defined. It needs to be substantially edited to explain why such a large facility to freeway standards must be provided in this corridor. It could be argued that a four -lane, low -speed roadway would also "further . . . planning objectives , . . and (would) provide access to . educational and recreational facilities" and, therefore, satisfy the project need with less wetland impact. The above revisions are needed in the draft EI.S so that (a) the final. EIS will be able to rebut the S 230.10(a)(3) presumption that practicable alternatives, exist. which do not affect wetlands and (b) that the final EIS wetlands only practicable alternative finding will be able to demonstrate that the preferred alternative is the - practicable alternative with the least environmental impact -on the aquatic ecosystem. ri 1 I 1 t If the final EIS does not address alternatives in sufficient detail to respond to the requirements of the section 404(b)(1) guidelines, then the Corps will require additional information to be developed,, and possibly a supplemental EIS, prior to determining whether or not to issue a 404 permit. See the remaining portion of 5,230.10(a)(4) that was not quoted on page I. OH) Floodp ain Hydraulic Stud Technical Report_, -May 1990 Pages 7 and 8. If the impacts to the natural And belief icial floodplain values of a base floodplain remain "significant" (NEPA) after mitigation, then. by definition (-23 CFR .S 650.1,05(q)) the floodplain encroachment of that base floodplain would be a significant encroachment. The "natural and beneficial floodplain values" that need to be. considered are listed at 23 CFR 6 650.1-05(i). If any significant base floodplain encroachments remain for the final EIS preferred alternative, then the final EIS, and not the draft EIS (see Appendix C), will need to include 15 1 a floodplain only practicable alternative finding for each such encroachment. (DH) 16 0$/1ti;9U 1L'{�E9 �8489262U FHWA R-e AL DO W)b Alternatives selection Procos for Projects Involving Section 4(f) of .the DOT Att The first test under Section 4(f) is to determine -which alternatives are _ feasible and prudent. An alternative nay be. rejected as aot being feasible and prudent far any of the fvilor►1ng reasons: (1)-not meeting the pr-oject purpose and need, (2) excessive,pst of construction, (3) severe - operational, or safety problems, (4) unacceptable adverse social., economic or.onvironmental impacts, (S) serious community disruption, -or (6) an accumulation of a lesser magni-tude of the foregoing types of factors. Harm to a Section 4(f) resource should i14l be included in -those factors which are considered in determining whether an alternative is feasible and prudent.. Where sufficient analysis has been completed to demonstrate that a particular Alternative is not feasible and prudent, no additional analysis or consideration of that alternative is required. After the aiternatives which are not feasible end prudent are eliminated, a determination must be made on whether one or more of the re0aining' alternatives avoid the use of land frog Section-4(f) resources. If such avoidance alternatives exist, one of them Must be saloctod. On the other hand, if all of the remaining feasible and prudent alternatives use land from Section 4(f) resources, then a (least harm) en.alysis must be performed to determine which alternative does least ovarall' ham to .the Section 4(f) resources. In performing this analysis the U1 harm (after mitigation) to the resource is the governing factor, The net'harm should be determined i.n consultation with the agency (the SHM in the case of historic sites) having jurisdiction over or. ownership of the resource. The feasible and prudent alternative which does the least harm must be selected. where there is more than one least harm alternative, 0 .e.., there is little or no difference in the overall harm to the .Section 4(f) resources), any of the least harm alternatives may be selected. The following examples illustrate the tl.ternative°selocti.oa process described above. On project 1, Alternati-ves C and Q are. determined not to " be feasible and prudent. No further attention freed be given to these alter- native*. While these alternatives may or may not use hand from.a Section,4(f) resource, it is immaterial, and' no further analysis is warranted. Since Alternatives A and B are fessi.bl0 and prudent and because 030 does not use land from a Section 4-(f) resource, alternative 6 must be &#31gJgd,. It is not necessary to determine the relative harm that alternative 'A" has on the Section 4(f) resources-', because 'b" is a feasible and prudent avoidance alternative.._ - an project 2, Alternatives G and D are determined not to be feasible and prudent. No further consideration need be given these alternatives. Of the remaining feasible and prudent alternatives, both "A' and 080 use land from Section 4(f) resources. The FHWA can approve only the feasible and prudent r 06i18�9�1 12�01 �89892620 FHWA R-9 --- CAL DO , 2 alternative, which does the least overall harm to the Section 4(f) resources. For project 2$ all feasible and prudent alternatives use land from e Section 4 f resource, sa OV must be selected since it does less harm to the Section 4�f resources. ra Land _n Feasible and Uses Sec. 4 M ftdr- IC2J= AlternalJJS krudent dt1-g-AjjSifl 1 A Yes Yes N.A.** B Yes No None C No Yes (N.A.)* N.A.* D No No (N.A.)* N.A.* 2 A Yes Yes Creator N Yes Yes Fester C No Yes (N.A.)* N.A.} D No No (N.A.)* N.A,* *Since this alternative is not feasible and prudent, it should be eliminated from further consideration. Whether Section 4(f) land is used and the factorse harm to Section 4(f) protected properties are no longer relevantIs **In Project 1 there is a feasible and prudent alternative which does not uss Section 4(f) protected property (Alt. 0). Any alternative which uses Section 4(f) protected property must be eliminated from further consideration. r- v0,: ' _v•ili IyL.+ :'l lr.i.7 iflWA (:tt Olv LLIJ•k)N)j I' FAX TRANSMITTAL. SHEET U. S. Department of Transportation Highway Administration -Federal 9 y °n Catiforn-ia Division , P. 0. Box '1915, S.acramento," CA 95812-1916 Phone: {916 651-1274 I To: �. ' _ Location: FAX Number. .714 � .1 �L� � Time Sent: �- �=' � ~' Date Sent: TCJJL ' Number, of pages transmitted f including this sheet}: Subject/Remark: l���t•� I:-�kw A ,mmE� s C-,c, `._:�a..n AV comw* Ar C_OMAQ.1`�% C' ��•`uu`C�.c�u , jQ c{r ��, I I ■ ` � u . � ■III o .Iu I I��w.+Iwww. nw�i.� . .I .�� From: Location: Sender's phone -number•��` Our FAX Number; - FTS 460-1273 or (916) 561-1273 If there are any problems with the transmission, piesse contact the sander 1mmadiately. Preliminary Draft ETS San aoaquin Hills TrAnmpnrtmt,inn Cnrridnr, FAP-73 Orange County 1 a nni so nnm1 r%i i nrrdn to hP nmmin1 MtMd far n11 fintion 4 (f 1 properties where there is human use. The analysis should include existing noise levels, rrnjPntPA nnimn lnvnIn with and without mitigation (noise abatement measures) and an analysis of whether, with mitigation, the noise impacts along with other impacts may substantially impair the actual poction 4(f) use of the Section 4(f) properties. See also comment FH-46. (JB) 2. The EIS shouia snow existing and future traffic noise levels for all Activity Category C land uses and identify impacts and consider abatement if needed where outdoor human use occurs. It is not acceptable on page 4-42 to simply list the areas as "mitigation not required" because it is "Caltrans policy not to provide mitigation at commercial land uses." See also comment CAL-156. (JB) 3. Page IV-43: The discussion on abatement measures should discuss a range�of factors to be considered in addressing whether noise abatement measures are reasonable or practicable such as: costs, views of residents, existing and future noise levels, changes in noise levels, noise abatement benefits, and environmental impacts of abatement construction. (JB) 4. Page IV-43: FxwA noise regulations require the consideration of noise abatement measures whenever the predicted noise levels " anu, r_hes or exceeds the FMWA noise abatement criteria." (JB) 5. Page IVY-45: it would appear that the noise levels at the Montessori School are at levels that would warrant consideration of interior noise levels, particularly if noise walls at the property line may not be considered under after approval of the final EIS. Bee also comments CAL- 137 and -149. (JB) 6. Figure 4.5.1 page 4-56 does not show a noise wall at Bonita Creek Park as included in Appendix A, the Section 4(f) Evaluation. As indicated above, noise abatement measures need to be considered at all Section 4(f) resources included existing bikeways and trails such as relocated biketrail 066 and the San Diego Creek Trails (040 and Santa Ana Heights). e 1 memorandum June 26, 1990 To: Steve Letterly From: Bill Olson Subject: Screencheck Corridor EIR comments - Direction to Consultants At our meeting of June 5, you asked Gail Shiomoto-Lohr and me to prepare draft direction to the EIR Consultants based on Gail's comments on the documents. We have attempted to capture the general direction derived from the meeting on her major comments and translate them into specific direction to consultants on each document. If you and Rob Thornton concur, it is assumed you will communicate this direction to consultants. PROJECT ALTERNATIVES 1. Assumptions re: transportation system improvements included in the no project alternative should be made explicit in the traffic study appendix of the various documents which in turn should be referenced in the Circulation Section of the EIR/EIS. The discussion of related transportation projects should contain a general statement that -unless otherwise noted,. all related projects are assumed to be built, i.e., related projects which are not assumed to be built should be so noted by exception. No need to analyze an no project alternative which assumes that none of the corridors would be built. Actually the existing approach which assumes. that the other corridors would be built is conservative in understatingthe need for the project. SJHTC: Section 2.7,-page 2-3.2 of the present 'EIR/EIS states that "under that No Project Alternative, the SJHTC would not be built. Language should be added to the EIR/EIS which clar.ifies that the No Project Alternative does include related transportation projects to be built, including the County of Orange MPAH as well as specific reference to the ETC and FTC. Further, the EIR/EIS should include an appendix which details the assumed transportation improvements Z incorporated in the No Project modelling analysis. A summary of his discussion should then be included in the circulation section of the document to enable the reader- to understand which related 3 transportation improvements, are incorporated in the document's analysis. + ETC: Page S-3, "No Project" section, is explicit in identifying related transportation improvements that are assumed to. be built under the No Project Alternative. The EIR/EIS should also include 1 1 'o 'm an appendix which details the assumed transportation improvements incorporated in the modelling analysis. Also a summary of this discussion should then be included in the circulation section of the document to enable the reader to understand the related transportation improvements which are incorporated in the document's analysis. FTC: Section S.4, page S-2, "Summary of Major Alternatives Considered"; and Section 2.2.1, page 2-2, "No Project Alternative": These sections should be revised to clarify that other related transportation improvements in addition to the I-5 STIP improvements are included in the No Project analysis, such as the County of Orange-MPAH as well as the SJHTC and the ETC. The EIR should also include an appendix which details the assumed transportation improvements incorporated in the No Project modelling analysis. Further, the EIR should contain a summary of this discussion in the circulation section of the document. to enable the reader to understand the related transportation improvements which are incorporated in the document analysis. 2. All documents should address a strict "demand management" alternative with no construction of the corridor and clarify how this relates to the no project alternative since some demand management measures would presumably be implemented with or without the corridor. If this alternative has been addressed and dismissed in previous documents, it will be adequate to summarize that discussion in the newer document. If not, a more complete discussion may be needed. SJHTC: No change is necessary to the document. The EIR/EIS, on page 2-34, contains detailed discussion as to why the TSM Alternative was dismissed for consideration as a primary alternative, stating that even with such a component, six general purpose lanes are still necessary. ETC: Page 11-2; "Transportation Systems Management (TSM) Alternative: A Transportation Systems Management Alternative is included as a primary alternative to the project. The document should further identify how the TSM components were modelled in the traffic analysis. For example, if a specific AVR was included, this AVR and its basis and derivation should be discussed and then compared against the AVR of the "No Project" Alternative. FTC. One of the project alternatives included in the Eastern Transportation Corridor is a Transportation Systems Management Alternative. As identified in the attached excerpt, the TSM Alternative includes improvements and activities beyond the No Project Alternative which would increase the efficiency and effectiveness of existing transportation facilities , without significant capital investment. TSM measures under this alternative include public and private transit, rideshare and paratransit programs, and bicycle and pedestrian improvements. Further, techniques that would be used to increase ridesharing I include HOV Preferential treatment and use of bypass _lanes. and ramps. The SJHTC further summarizes in detail in its EIR/EIS, that such an alternative ,was considered in previous environmental documents, but was dismissed for consideration as a primary alternative because the need for six general purpose lanes was necessary above the traffic capacity of the TSM Alternative to warrant construction of the SJHTC. The FTC EIR contains. no discussion of. such an alternative in "Section 2.2: Primary Alternatives Under Discussion." The EIR # should be revised to include discussion as 'to. whether such an alterative was previously discussed and dismissed in earlier environmental documents to'the FTC, and so noted and summarized in this EIR. If not previously dismissed, such an alternative should be included in this EIR for' consistency in approach with all corridor documents. the document should further identify how the TSM In addition, Y components were modelled in the traffic analysis. For example, if a specific AVR was included, this AVR and its basis and derivation "No should be discussed and then compared against the AVR'of the Project" Alternative. PARK AND RIDE 3. The ETC and FTC documents need to at least address Park and Ride facilities to indicate why none have been included as part of the project at this time and to identify them as probable future facilities to facilitate trans it/ ridesharing. As to SHHTC, OCTD needs to"be consulted'on P & R Locations as part of consultation on transit operations it foresoes for the SJHTC. Presumably, OCTD will also comment on lack of P & R locations on the ETC and FTC if it feels there is potential need for same at this time. OCTC consultation is a TCA responsibility which is underway at this time, SJHTC: On page 2-20, the EIR/EIS contains general discussion on park -and -ride locations that would accompany construction/operation of the corridor.) Verify if OCTD has conceptually endorsed these ocations in conjunction with its review of the SJHTC EIR documents. ETC: The EIR/EIS needs to include a section on park -and -ride facilities. The purpose of such a section is to identify ancillary facilities which are planned in conjunction with the corridor's construction and operation to promote ridesharing and use of HOV lanes. If no park -and -ride facilities have yet been conceptually identified and endorsed by the OCTDthere should be, at minimum, EIR discussion and justification asto-why they are,not included with corridor planning at this time, with language :noting that such facilities shall be considered as possible future facilities which will be undertaken at an identified and appropriate time•frame. U Because ETC serves San Bernardino/Riversides to Orange County trips, consultations with those counties (especially Riverside) and Caltrans re: park -and -ride facilities planned to serve those intercounty trips should be referenced. FTC: The EIR needs to include a section on park -and -ride facilities. The purpose of such a section is to identify ancillary facilities which are planned in conjunction with the corridor's construction and operation to promote ridesharing and use of HOV lanes. If no park -and -ride facilities have yet been conceptually identified and endorsed by the OCTD, there should be, at minimum, EIR discussion and justification as to why they are not included with corridor planning at this time with language noted that such facilities shall be considered as possible future facilities which will be undertaken at an identified and appropriate timeframe. PROJECT DESCRIPTION 4. The section on Potential Future Median Use Options in the SJHTC should a) make it clear that HOV lanes are not one of the future options but a part of project; and b) reference discussion on transit alternatives to explain why transit (rail) is considered a future option and not a part of project. HOV lanes should be part of the ETC and FTC projects as well, but this direction needs to be confirmed by TCA Management as both these projects now treat HOV as a "future option in the median" much the same way as transit has been treated. Since the RMP assumes HOV lanes in these corridors, failure to explicitly include HOV lanes in the project definition may be fatal to a finding of conformity with AQMP Guidelines. SJHTC: Page 2-20• "Potential a Media needs to be g ntial Future n Options" revised. Specifically, the discussion on project phasing and the HOV/transit median should clearly: a. identify that the HOV lanes are part of the project, and not solely considered as a future option. In being considered as a part of the project, the EIR/EIS should explain that the timing of �Vv construction of the HOV lanes (i.e., at outset or phased) will be determinedin part by bond finance considerations. While the financial documents will not be included in the EIR as technical - appendices since these projections will be changing throughout the course of project development -these documents can be referenced in the EIR/EIS discussion. b. include traffic engineering data documenting the demand for exclusive HOV lanes, as a traffic technical appendix to the EIR/EIS. Further, the EIR/EIS should summarize this discussion by Wb VI clearly documenting the need for appropriate phasing of the HOV lanes, and documenting, under the Demand Management Alternative, that heavy utilization of the HOV lanes is critical for successful I operation of the facility to achieve its 1.5 AVR assumption at LOS D objective at Year 2010 demand. c. explain why rail transit is not a part of the project, but rather, is considered a future option. ETC: In this EIR/EIS, the HOV lanes are considered as a future option in the median, similar to the rail component. However, SCAG's Regional Mobility Plan assumes HOV lanes in this corridor, and their deletion in the project definition could result in a no finding of non -conformity with the Air Quality Management Plan guidelines. Subject to confirmation and direction by TCA management., the- EIR/EIS should be revised in all appropriate references and discussions such that the HOV lanes are identified as part of the project. Further, it should be noted that the timing of the construction of the HOV lanes (i..e., constructed as part of initial construction and operation of the corridor,, or phased) would be determined by traffic demand- and -the- projects, bond finance considerations. Lastly, the EIR/EIS should include traffic engineering data do.cumenting,the demand for exclusive HOV lanes in relation to appropriate phasing of construction, and should also explain why rail transit is not a,part of the project,, but rather, is considered as a future option. FTC: Page 2-1: "Project Description"; In this EIR; six general purpose lanes and two HOV'lanes are narratively described as being proposed for the entire length of the project. However, Exhibit 2- 2 identifies that the HOV lanes are considered'as a future option in -the median, similar to the 'rail component. SCAG!s Regional Mobility Plan assumes HOV lanes in this. corridor, and their deletion in the mainline project definition could result in a no finding of non -conformity, with the Air Quality Management Plan guidelines. Subject to confirmation and direction by TCA management, the EIR/EIS ,should be revised in all appropriate lanes clearly references and discussions such that the HOV _are identified as part of the .project. Further., it. should be noted that the timing of the construction of the HOV lanes (i.e., constructed as part .of initial construction and operation of .the corridor, or phased) , would be, determined, by, the project' s bond finance considerations: Lastly, the EIR should include traffic engineering data documenting the demand for exclusive HOV lanes in relation to appropriate phasing of construction, as well as discussion explaining why rail transit is not a part of the project, but -rather, is considered as a future option. 5. Concur that the ETC needs to include a .discussion of alternatives previously considered and why the alternative was dropped as infeasible or inferior to the project alternatives. SJHTC: No change is necessary to the document. ETC: Both the SJHTC and the FTC EIR/EIS's contain narrative documentation as to the different corridor alternatives which were L__1 1 V originallyconsidered in conjunction with project development, with J P J P subsequent presentation, in each alternative, as to why that specific alterative proved infeasible and was subsequently dismissed for consideration in the development of the final project alternatives. A similar section needs to be included in "Section II: Alternatives" of the Eastern Transportation Corridor EIR/EIS. FTC: No change is necessary to the document. 6. Agree that SJHTC needs to identify basis of 1.5 AVR assumption and relate it to AQMP goal of 2.10 AVR at worksite (believe we agreed that since 1.5 was for corridor as a whole, 2.10 at worksite was not in conflict). Also agree that other two documents need to discuss the TSM alternative to the project as does the SJHTC. SJHTC: Page 2-34 and 2-35; Transportation System Management Alternatives," states that under the most optimistic HOV ridership assumptions, with 1.5 ridership on the Corridor, the demand is still present to warrant said corridor and to thus preclude implementation of the TSM-only alternative. This section needs to include clarifying language which identifies the basis and derivation of the stated 1.5 AVR assumption and in turn, contrasts this with an identified AVR for the "No Project" alternative. ETC: See Comment 2 above. FTC: See Comment 2 above. 7. All documents need to discuss Mass Transit Alternatives in lieu of a corridor with general purpose lanes. This should include a discussion of bus transit, a mode which already exists in Orange County in spite of low densities. It was agreed at our meeting that the best argument as to the inadequacy of the "rail transit only" option is that the AQMP does not call for rail transit on the corridors. It was also agreed that SJHTC may place too much emphasis on the "lack of land use intensity" argument against transit feasibility. This can be used to explain why transit has not to date been considered feasible, but then emphasize fact that corridors provide future transit option and indicate that such options will be addressed as part of the countywide study effort to which your comment refers. SJHTC: Pages 2-35 and 2-36: "Mass Transit Alterative": This section's discussion on land use reorganization and the unlikely demand for rail transit should be eliminated. Rather, the conclusion section of this discussion should reference that the issue of rail transit is part of a countrywide study effort that is assessing feasible rail options from both an intracounty and intercounty perspective, and that any subsequent implementation of the SJHTC 's rail transit option would be assessed in accordance with that larger study effort, with the appropriate rights -of -way 1 1 so reserved. This section should also include, in addition to rail, a discussion of bus transit, a mode which already exists in Orange County despite low density of development. ETC: As noted in Comments. 2 and 5 above, the EIR/EIS needs to include discussion as to the different corridor alternatives. Both the SJHTC and the FTC include discussion of a "Mass Transit Alternative" to the corridor. This alternative, which was originally considered but subsequently dismissed, explores the feasibility of constructing .an all' transit facility along the corridor to reduce -the demand- for motor -vehicle oriented facilities. Such as:alternative needs to be discussed in -the ETC EIR/EIS in the "Alternatives Considered" section. Further, the alternative shouldalsoinclude, in addition to rail, a discussion of bus transit as a component to the alternative. FTC: Page 2-9 through 2-11.; "Mass Transit Alternative": .The conclusion .section of this, discussion should_ reference that the issue of rail transit is part of a countywide study effort that is assessing feasible rail options from both an intracounty and intercounty perspective, and that any subsequent implementation of the FTC's rail transit option would be assessed in accordance with that larger study effort, with. the appropriate rights -of -way so reserved. Also, this section should include a,discussion of'bus.transit-as a component to the Mass Transit Alternative, a mode which already exists in Orange County despite low density of development. 8. As noted in 1 above, the traffic study for each corridor should provide documentation as to the improvements assumed in the traffic numbers/LOS data for the no ,project .and build alternatives; and the "related projects" which are -not assumed of as part of these calculations should be, called out as exceptions. In each case, the document should 'make a clear statement supported by the traffic data that even. with the related projects, the corridor is needed to achieve adequate LOS; and that ,.construction of the corridor , does, not -obviate the need for the related projects (at least, those included, in the traffic projections). It, is assumed that related projects not included in the traffic projections will.be- very_few and that these can be handled by exception in the discussion. SJHTC: Pages 2-53 and 2-54, Section 2'.9, "Related Transportation Projects": This section needs an introductory paragraph which clearly states that even with the construction'of the identified l� related projects, the SJHTC is still necessary to achieve adequate LOS, and further, that the construction of the corridor does not obviate the need for the- related projects (supported by traffic data in the appendix). Further-,, this list of related improvements should be cross-referenced and c-ross-checked against the appendix requested'in Comment 1. Any related project which is not assumed 1 in the modellinganalysis should be called out as an exception, Y P ► with appropriate explanation. "Transportation ETC: Pages III-64 through III-70, Facilities": This section needs an introductory paragraph which clearly states that even with the construction of the identified related projects, the ETC is still necessary to achieve adequate LOS, and further, that the construction of the corridor does not obviate the need for the related projects (supported by traffic data in the appendix). Further, this list of related improvements should be cross- referenced and cross-checked against the appendix requested in Comment 1. Any related project which is not assumed in the modelling analysis should be called out as an exception, with appropriate explanation. FTC: Similar to the SJHTC and the ETC, the Foothill Transportation Corridor EIR needs to include a discussion in the Circulation section which details related transportation facilities (regional and arterial) that are planned in the FTC study area. Further, this section should include an introductory paragraph which clearly states that even with the construction of the identified related projects, the FTC is still necessary to achieve adequate LOS, and further, that the construction of the corridor does not obviate the need for the related projects (supported by traffic data in the appendix). Further, this list of related improvements should be cross-referenced and cross-checked against the appendix requested in Comment 1. Any related project which is not assumed in the modelling analysis should be called out as an exception, with appropriate explanation. GROWTH INDUCING IMPACTS 9A. The documents should clearly identify the growth forecasts used in the analysis and how any discrepancies between them were reconciled. Agree that traffic analysis should address need for corridor assuming SCAG GMA-4 (J/H) forecast assuming it shows less jobs in OC and more housing than OCP-88. This can then be referenced in documents. It was also agreed that some analysis would be done assuming OCTAM II results and that TCA needed to develop a work program and schedule to insure that such analysis was completed in time to be folded into the circulation drafts. Chapter 5: Growth Inducin Impacts, page 5-2, "Background": ocument should clearly identify the growth forecasts used in nalysis, and how any discrepancies between the SCAG GMA-4(J/H) ast and the OCP-88 forecast were reconciled as to employment ousing projections. Further, the sensitivity analysis of the II forecasts should be included for discussion in the with a concluding paragraph added which explains that dless of the discrepancies in land use data, that the onmental analysis has analyzed, for environmental purposes, a scenario. SJHTC The d the a forec and h '?,• envir I The /obs 7 jhousing balance discussion on page 5-7 needs.to be made relevant to the corridor project by answering the question: how �3 'does the corridor affect/contribute to, a)inter-County and b) intra-County J/H balance. Some readers may be confused by discussion as between pages 5-8, Status of Land Use Plans, and 5-10.. As I read : it,, 64.5% of the benefit area is existing development and 35.5% is -planned for urban uses or open space. Of the latter, 98% is covered by development agreement or tentative maps or is dedicated open space, leaving almost nothing to "induce" unless plans are changed. The real potential for growth -inducing impact, then, is in - recycle at higher densities, perhaps in anticipation of transit improvements in the median. Concluding sentence of 'paragraph 2, on page 5-10 is weak. It is also unnecessary as are the preceding two sentences which should also be deleted. The document should include and make distinct its discussion of inter- vs. intra-County growth -inducing impacts. In the case of SJHTC, potential to induce growth in San Diego County is probably in that both SJHTC most critical, although it may be cumulative and FTC together which are needed to have this effect. rETC: Pages VII-2 through,VIII-4: "Historical Growth Patterns" and "Population and Employment Distribution": This document should identify the key sources used for the assessment of growth projections, and further identify how discrepancies between the SCAG GMA-4(J/H) forecast and the OCTAM I OCP-88 forecast were reconciled as to employment and housing projections.to conclude to the growth forecasts described in this section. Further, the sensitivity analysis of the OCTAM II forecast should be included for discussion in the section, with a concluding paragraph added which explains that regardless of the discrepancies in land use data, that the environmental analysis has analyzed, for environmental purposes, a worst -case scenario. This section should also include a) a discussion of how the project affects inter -County jobs/housing balance and its potential to induce residential growth in Riverside and San Bernardino Counties; and b) an indication of the extent to which land uses in benefit area were conditioned to dedicate land or otherwise contribute to corridor construction on premise that it was needed to provide adequate circulation capacity to accommodate such uses. FTC: Page 6-2, Section 6- 3 "Growth Inducing Impacts": The section needs to discuss how any discrepancies between the SCG GMA-4(J/H) forecast and the OCTAM I OCP-88 forecast were reconciled to conclude to the growth forecasts described in. this section. Further, the sensitivity analysis of the OCTAM II forecast should be included for discussion in, the section, with a concluding paragraph added which explains that regardless of the discrepancies in land use data, that the environmental analysis has analyzed, for environmental purposes, a worst -case -scenario. 1 The document should also discuss the extend to which land uses in benefit area were conditioned to dedicate land or otherwise contribute to corridor construction on premise that it was needed to provide adequate circulation capacity to accommodate such uses. I believe that the County argues that its buildout projections will happen "with or without the corridor." I suggest that we ask the County to provide additional rationale for this position which can be incorporated into the documents. Beyond that, the issue raised here re: whether or not development is conditioned upon corridor construction is probably answered the same as that for ETC since the Foothill/ETC is a single benefit area for development fee purposes. GSLCOMM.6802 I 1 r 1 1-1 1 RECEIVED JUN '6 1990- I. I 1 DRUG USE IS B June 4, 1990 MEMBERS OF THE CITY COUNCIL ANTHONY L. BLAND LAWRE•NCE F. 13UCHHEIM KENNETK: E. FRIESS GARY 'L. HAUSDGRFER PHILLIP R. SCHWARTZE' CITY MANAGER STEPHEN B JULIAN Steven Letterly, Environmental'Manager Transportation 'Corridor Agencies 345 Clinton Street Costa Mesa, California 92626 Subject: Screencheck Environmental Impact Report, San Joaquin Hills Transportation Corridor (SJHTC). IDear Steve, The Planning Division has completed: a review of,,the screencheck environmental impact report and appreciates the opportunity to provide comments on this document. The report is comprehensive and in almost all cases, identifies and addresses potentially significant environmental impacts associated with. this project. We recognize the fact that this project will create unavoidable, adverse environmental impacts. However, the "no project alterna- tive" creates significant impacts which in many cases are more significant than the "build alternatives". As we have indicated in previous scoping meetings and correspondence, our City's primary concerns with this project include the following: 1. Traffic and circulation. 2. Drainage and hydrology. 3. Noise. 4. Grading and topography (landform alteration). 5. Aesthetics. 6. 7. Growth Inducing Impacts, Construction impacts. The Summary of Impacts and Mitigating Measures discussion on ✓ \ traffic and circulation is quite brief and is limited to discussing _the potential traffic congestion impacts associated with the demand management alternative (ref. page 19). More• importantly, 'the Corridor will most likely attract additional traffic on regional arterials thereby requiring improvements to those roa_dways.. The draft EIR should recognize these indirect circulation impacts and identify appropriate mitigation measures, even in cases where your 32400 PASEO ADELANTO, SAN JUAN CAPISTRANO, CALIFORNIA, 92675 •' (714) 493.1171. 11 Steven Letterly May 18, 1990 page 2 agency believes that those mitigation measures should be the responsibility of local jurisdictions. The report identifies noise impacts and concludes that the area in the vicinity of Spotted Bull Lane and the Roston Montessori School could not be effectively protected from increased noise impacts. Noise mitigation measures appear to be exclusively limited to "noise barrier walls", however, other alternatives may exist. In C_ the case of the Montessori School, it may be possible to provide specific building related noise attenuation which may be less J� expensive and more effective. We recommend that the report identify additional potentially effective noise mitigating measures which could minimize these impacts. Hydrology mitigating measures include the referral of drainage ' reports to affected local jurisdictions for their review and response (ref. page 10). All drainage/hydrology reports which include Oso Creek impacts should be forwarded to Ted Simon, City Q Engineer so that we may confirm that the proposed changes meet our standards. The visual impact of the Corridor as the report notes will be quite significant. We believe that a significant aspect of the aesthetic impact includes the effect on the Capistrano Valley. However, the report draws no distinction between the potential aesthetic impacts of the Corridor alternatives on the Valley (ref. page 18). We recommend that the report be revised to discuss the relative impact of the alternatives as viewed from northbound and southbound traffic on Interstate 5. In terms of growth inducing impacts, the report concludes that the ■ Corridor will have relatively little impact due to the fact that �4 previously proposed projects and vested tract/parcel maps have recognized the plans for the Corridor: However, proceeding from plan approval to construction, as may 'be the case with many projects in the region, may be contingent on or made more financially attractive by the Corridor. The Corridor proposes a number of interchanges which allow convenient access to arterials and undeveloped land adjoining those arterials. Consequently, we ��-- recommend that the report be revised to examine the necessity of the numerous proposed interchanges. In particular, the report should identify those interchanges which would clearly improve r access to nearby undeveloped properties and quite possibly hasten their development. For areas where growth inducing impacts may be significant, the TCA may want to consider modifying or eliminating the proposed interchange design. As an alternative, the actual construction of potentially "growth -inducing" interchanges could be phased so that they respond to demand as opposed to prematurely attracting demand. 1 Steven Letterly May 18, 1990 page 3 As part of our review we have noted several minor corrections we want to bring to your attention. Figure 2.3 in the visual analysis SAC- appears to be 'incorrectly labeled as "Aliso Creek Road Pacific Park 7 Drive Interchanges". In fact,. the photo appears to depict the "Aliso Creek Road/Glenwood Drive Interchanges" and should be corrected accordingly. Also, the visual analysis photos appear to cT - be in random order and could be organized so that they appear in directional order.from east to west or vice -versa. 1 1 1 I n 1 In summary, the screencheck EIR effectively identifies and addresses almost all of•the potentially significant environmental impacts with the exception of several items we've identified and discussed herein. We believe that the inclusion of our recommended revisions will improve the clarity and thoroughness of this important document. Should you have any questions or want to discuss this our review of this project further, please don't hesitate to call me at 493- 1171, extension 505. Sincerely, Qc Czi,, 0, 4-' William A. Ramsey, AICP Senior Planner cc: Stephen Julian, City Manager George,Scarborough., Assistant City Manager Thomas Merrell, Director,. Community Planning and Development William Murphy, Public Works Director Thomas Tomlinson, Planning Manager Ted Simon, City Engineer Bud Vokoun, Senior Civil Engineer 11 RCV BY:XEROX TELECOPIER 7010 ; :'01234S6789-9 ;# 2 1 FROM:ema planning rm238 TO:95579104 we CJ F "GF. - JUN 18, 1990 5:00PM P.02 MICHAEL M. RUANE DIRECTOR, EMA 12 CIVIC CENTER PLAZA SANTA ANA, CALIFORNIA MAILING ADDRESS: P.o. BOX 4048 SANTA ANA, CA 92702-4048 TELEPHONE: (714) 834-2306 ENVIRONMENTAL MANAGEMENT AGENCY FAX # 834-2395 Steve Letterly Manager Environmental Impact Transportation Corridor Agencies 345 Clinton Street Costa Mesa, CA 92626 JUN 1 Is 1990 FILL NCL 90-49 SUBJECT: San Joaquin Hills Transportation Corridor Screen Check EIR/EIS Dear -Mr. Letterly: The above referenced item is a Screen Check EIR/EIS for the San Joaquin Hills Transportation Corridor. Thank you for the opportunity to review the project at this stage of development. We appreciate the coordination efforts extended by the Transportation Corridor Agencies (TCA) and Caltrans to date and are available to meet with you regarding these comments a`t your convenience. Specific technical comments on the proposed project ,are attached. Ve look forward to future coordination on this. project. Please send five (5) copies of the draft EIR/EIS to Kari Rigoni at the above address. If you have questions, please call Ms. Rigoni at (714) 834-2109. Very truly yours, Joan S. Golding, Program Kanager Regional Coordination Office 4;"1'-Kar'i A. R go, i, S Planner ' CH:tk 0061412143605 Attachments ec: Supervisor Vasquez-, District 3 Supervisor Riley, District 5 B. Peterson N. Porter RCV BY:XEROX TELECOPIER 7010 ; ;0 1 2 3 4 5 6 7 8 9 4 CO-1 FROM:ema planning rm238 TO:95579104 JUN 18. 1990 NCL 90-49 SCREEN CHECK FOR THE SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR Technical Comments WATER RESOURCES 5:01PM P.0 The subject document has been reviewed relative to previous comments made on the NOP. The issues of streambed alteration and sediment control have been adequately addressed, but no mitigation measures are given for water conservation either in the landscaping or at the toll booths. A landscaping plan should -be required prior to approval of plans and specifications, showing the stabilizing vegetation and the water requirements for the cut slopes. The issues of water quality mitigation have been deferred to the Urban Run-off Management Plan (URMP). This document should include Best Management Practices (EMPs) to mitigate water quality degradation due to stormwater run-off. Examples of appropriate BMPs to be included in the URMP include but are not limited to: extended detention ponds, retention ponds, infiltration basins, infiltration trench designs including those for median strips, multi -chambered water quality inlets to stormdrains, and the use of filter strips in landscaping. ° In addition, the section on water quality contains the statement "...actual pollutant loadings within each stream would not be significant, primarily due to the dilution of run-off from divergent watercourses and length and intensity of storm events..." (page 4-17). This is incorrect. Environmental law makes it clear that dilution is not a treatment for pollution and this statement is inconsistent with the required mitigation measures. The EIR/EIS indicates that the SJHTC will cross the following regional drainage channelss San Diego Creek (F050) Bonita Channel (F04) Coyote Creek (F04S01) Laguna Canyon (IO2) Niguel Creek (IO2S01) Aliso Creek 001) Narco Channel (J04) Oso Creek (L03) The EIR/EIS proposes to provide new crossings for all of the above facilities except Niguel Creek and Narco Channel. Niguel Creek was designed to fit the SJHTC. Narco Channel and its tributaries near SJHTC require the extension and/or reinforcement of the existing facilities to accommodate the proposed SJHTC. The concepts proposed in the EIR%EIS are satisfactory to the EMA/Plood Program Division. In conjunction with bridge over Trabuco C� of the I-5 at this 160500 efs but the should be used for the proposed project the I-5 Freeway may be widened. The Creek (L02) may require modification as a result of widening location. The design discharge for the existing facility is current 100-year 0 is 18,500 cfs. The current 100-year 0 any modifications or improvements needed at Trabuco Creek. t F 1 1 1 1 1 1 1 L7J -1- RCV $Y:XEROX TELECOPIER 7010 ; FROM:ema planning rm238 ;0 1 2 3 4 5 6 7 8 9 4 TG:95579104' JUN 18, 1990 # 4- 5:02PM P.04 1 1 AIR QUALITY ire have reviewed the Air Quality Study Technical Report (May 1, 1990) and have the following comments: ° Page.,5: The discussion on CO concentrations should also -reflect some -of the more positive aspects of the measured CO data. For example, no state or federal CO 1-hour standards were exceeded at the Costa Mesa and''E1 Toro air quality monitoring stations;.state and federal CO 8-hour standards were only exceeded three times in 1986 and three times in 1988, and were not exceeded in 1987. ° Page 12, last paragraph: This paragraph states that,"'... the corridor size (under either the Conventional Operations or Demand Management Alternative), s would remain the same if SCAG',land use and population projections (from the Growth Management Plan) were used to forecast traffic data 'for=the Corridor rather than the traffic forecast based upon OCP-88." This statement should be supported with a traffic analysis or the data source should -be referenced. I ; in addition, the EIR/EIS should discuss the differences between the SCAG GMP s and the OCP-88 socioeconomic -.forecasts, and the ramification these forecasts has on the Corridor. ° page 13, second paragraph: The discussion on the area shown - in Figure-3, f should also indicate that the area depicts where the Corridor has a direct 1 -effect on traffic and the related air quality impacts. Negl"igible.air quality impacts are anticipated outside this area due to primary pollutant emissions. ° Page 17: There appears to be some contradiction between the second and fourth paragraph, regarding average speed and vehicle miles traveled, between the Conventional and Demand Management Alternatives._ The second paragraph states that both alternatives are similar in terms of average speed and vehicle miles traveled, therefore a separate regional analysis was.not required.. The fourth pars ra h states that the Demand Management Alternative would have more of a reduction in air contaminant emissions than the # Conventional Alternative due to higher average vehicle speeds and lower vehicle miles traveled. These "qualitative" statements should be supported with data, or the report should 'include a detailed discussion that supports these statements. CIRCULATION The traffic analysis should include a time delay/benefit analysis of construction of the corridor vs. no corridor. The benefit -of time saving and associated environmental assets should be.emphasized in this report., The study recognizes that if HOV use on corridors is less than 30%, then congestion will occur on the general purpose travel lanes; however,'it does not define a program to encourage 30% usage. Figure 1.5.1: The source of data should be added -to all figures. Also, - some discussion should be included in the text to rationalize why the Y2010-without- -Z- RCV BY:XEROX TELECOPIER 7010 :0 1 2 3 4 5 6 7 8 9 4 :# 5 FROM:ema planning rm238 TO:95579104 JUN 18, 1990 5:02PM P.01 corridor forecast on a number of arterials in south county and the Newport Beach area is lower than existing, e.g. Y1990. Page 1-12, Paragraph 2: The statement that the corridor would "minimize regional through traffic use of arterial highways" is not substantiated by W Figure 1.5.1 and Table 1.53 as referenced. Page 2-29, I-5 Connections Will there be provision for direct HOV access from �' � . I-57 Page 2-38, Paragraph 5: There is'a typographical errors Table 2.8.A should be changed to Table 2.8.B. Traffic and Circulation Study, Page 14, Table 2 corrections: E1 Toro Road Primary/Major 4/6 Laguna Canyon Road I �j✓ Sand Canyon Avenue Primary/Commuter 4/2 Pelican Hill Road Major 6 A more recent MPAH should be used for this table. The graphics in the study need better labeling (e.g., Figures 1,3,4,5). OPEN SPACE/RECREATION Appendix A Section 4(F) does not completely assess the adverse environmental impacts upon Harbors, Beaches and Parks' properties and provides incomplete mitigation measures for the admitted environmental impacts. In order to insure the natural characteristics of Harbors, Beaches and Parks' properties are maintained, the following comments should be addressed. I. Master Plan of Regional Parks i A Ida; Aliso and Wood Canyons Regional Park Sufficient mitigation measures should be incorporated to eliminate or greatly reduce any viewshed intrusion identified. Potential noise impacts should also be identified and appropriate mitigation measures stated. Specific mitigation measures should include the provision of sound attenuation walls and/or extensive landscape treatment where the corridor traverses this regional park. Ix. Master Plan of Riding and Hiking Trails Harbors, Beaches and Parks' Trails: Arroyo Trabuco Equestrian Trail San Diego Cree Channe and Santa —Ana-Heights Trail. c� I Construction level documents should provide for trail crossings which meet County standards. Crossings should be landscaped and screened as much as possible to lessen the impact of the roadway. Also, adequate signage should be provided at the crossings. -3_ RCV BY:XEROX TELECOPIER 7010 ; ;0 1 2 3 4 5 6 7 8 9 -) ;-# 6 r F 1 FkMema planning rm238 TO:95579104 III. Resources Element Open Space Component JUN 18, 1990 5:03PM P.06 Prior to approval of plans, specifications and estimates, a Resource Survey and Management Program should be completed which clearly delineates the limits of roadway development (i.e., grading, structural development, fuel modification requirements, haul routes, storage/stock-pile sites, heavy equipment staging, etc.) relative to natural resources (i.e., oak woodland, riparian vegetation-, grassland, foraging areas, streams,,creeks, springs, rock outcroppings, paleontological and archaeological resources, etc.) with provisions for permanent preservation during and after construction. IV. Encroachment Prohibitions A. Construction activities and the storage of construction equipment within regional park property which abuts the San Joaquin -Hills Transportation Corridor are prohibited. CULTURAL/HISTORICAL 3.10 Historic/Archaeological/Paleontological Resources To assess those remains,unearthed.during construction, procedures are being developed for collection and curation which reflect public and research interests. These procedures should be established prior to construction. ELEMENT PLANNING At the request of the TCA, County Planning staff has prepared acreage estimates for the SJHTC area of benefit (AOB). Staff provided acreage estimates for three categories of land use: 1) Existing! 2) Planned, and 3) Not Committed. A draft copy of acreage estimates was transmitted by PAX to Carollyn Lobell on April 27, 1990. Since that time staff has had the opportunity to gather additional information and double check estimates. Revised estimates differ from those previously transmitted. Section 5.0 Growth -Inducing Impacts, page 5:--8, "Status of Land Use Cj� { Plans and Development", reflects, to some degree, the draft estimates transmitted to the TCA. This information should be updated using the updated Information which has been forwarded to'the TCA under separate cover.' According to our -figures,, slightly over half (55X) of the estimated total acreage consists of existing development. Approximately one-third (33%) of the AOB remaining undeveloped area is planned for development. Of the remaining undeveloped acreage, twelve percent (12%) is not committed for development at this time. The Screencheck EIR states that there are no "unplanned" areas. This statement should be corrected. CA:tk 0061408153839 - 4 - 1 1 I CrrY OF LAGUNA NIGUEL 1 City Council 'Patricia C. Bates Paul A Christiansen James F. Krembas. Ed. D. Larry A. Porter Thomas W. Wilson 1 r June 15, 1990 Mr. Steve Letterly San Joaquin,Hil,ls Transportation Corridor,Agency 345 Clinton Street Costa Mesa, CA. 92626 Re: Screencheck EIR/Support Documents Dear Steve: Enclosed are our preliminary Planning and Traffic related comments on the above mentioned documents. Please note that these comments are preliminary only, and that more detailed comments will,be forwarded to you within the next two -weeks. If you have any questions regarding this matter, please call me at 643-1610., Sincerely, Micki Harris Senior Planner encls. ij �0 To: Micki Harris, Senior Planner From: Solveig Darner, Traffic Liaison ' Re: Screencheck EIR/Support Documents Date: June 15, 1990' Following our meeting with the City's Traffic Consultants, the , following preliminary comments were prepared and should be included in your submittal to the SJHTC Agency. * Figure 1.5.1 Shows Existing (1988/1989) volumes as well as year 2010 volumes without and with the Corridor. There appears to be a dramatic reductions of daily volumes from the existing to the projected 2010 without the Corridor as well as with the Corridor on Crown Valley, Golden Lantern and La Paz, all in Laguna Niguel. , This is inconsistent with the expected link impacts to arterials running either parallel to or perpendicular to a freeway/transportation corridor and needs to be ' clarified.(Screencheck EIR) Previous forecasts refer to the Crown Valley Parkway/I-5 interchange as "heavily impacted". Potential relief to Crown Valley Parkway (between Greenfield and I-5) as well as the -Crown , Valley/I-5 interchange by providing southbound on -ramp and northbound off -ramp at Greenfield has not been fully evaluated. (Screencheck EIR) A comparison between Option #1 & #2 PM Peak volumes entering/exiting I-5 or SJHTC via Greenfield, Crown Valley Pkwy and Paseo De Colinas (to/from Laguna Niguel), indicates a , substantially reduced use of both I-5 & SJHTC with Option #2. The roadway link network pattern needs to be examined to determine why this reduction occurred with alternative #2. (South End Circulation Study - Technical Report) The methodologies used in the traffic analysis is not consistent with the methodologies established by the County of Orange through the Growth Management Plan Element of the General Plan and does not provide needed consistency between the various agencies/jurisdictions using the GMP methodologies for their traffic forecasts. (Example - Lane capacities used) This inconsistency with the GMP should be addressed.( South End Circulation Study - Technical Report) I * The ADT and Peak Volumes projections for Paseo De Colinas do not reflect the expected volume differences between the various alternatives as they relate to I-5/SJHTC access. Paseo De Colinas volumes need to be examined. (South End Circulation Study - Technical Report) 1 1 1 1 1 1 [i Date: June 15, 1990, From: John Anderson, Planning Consultant Re: Screencheck EIR-San.Joaquin Hills Tr.ans'po;rtation Corridor As requested by Laguna Niguel and Mission Viejo; I have reviewed the subject screencheck EIR and offer the following comments: GENERAL COMMENTS: 1. Why does TCA identify the two alignment alternatives as functionally different, (conventional vs demand management)? It would seem that actually there are (or should .be) four alternatives: conventional function -alignments A and B... and demand management function -alignments A and B. These relationships should be adequately clarified in the introduction. 2. The document seems to be overly negative towards light -.railand ignores any prospect for multimodal- with Amtrak ... in the immediate vicinity of the southerly confluence. 3. 'Land use data seems to be inconsistent, deficient and overly generalized. Relocation is not discussed at all in its designated section 3.8. Although it is discussed later. See comment #4 following. 4. The EIR seems cumbersome and fragmented by the separation of the "affected environment" vs "environmental consequences and mitigation measures" vs "cumulati.ve impacts". It would' be easier to get the "sense" of a particular issue if the document were organized by impact factor ie land use section: setting, impacts, mitigations, cumulative impacts, unavoidable. impacts: Also, it would be very helpful to provide a summary of impacts/mitigation by affected community i.e. Laguna Niguel, Miss-i_on Viejo,, etc. 5. Some of the generalized exhibits are not adequately keyed to a corresponding list or text or are not sufficiently specific and should be supplemented by additional local detail. 6. Mission Viejo is impacted and is a significant related land use; but is given very little.'consideration... inconsistent coverage. 7. Laguna Niguel is probably the most highly impacted area; but the_individual and cumulative impacts are not -readily understood because the data is not organized or summarized by jurisdiction. 8. Funding, financing and retirement of bonds may have considerable impact on operational configurations/phasing ie HOV/'light rail revenues vs regular toll rev.enues.,Also, there are a number of potentially significant impacts associated with displacement/disruption of businesses. Thus it, would seem appropriate to prepare a Technical Report fo-r Economic Impact and to include the findings of that repo.rt.in an Economic Impact. Section within the EIR. Perhaps the just distribti-ted Environmental/Financing/Engineering documents will address -some of these needs? C DRAFT EIR-SUMMARY: Page (la 3. The objectives and expected benefits which stress access to various areas/nodes might also specify Mission Viejo/Laguna Niguel at the southerly terminus of the Corridor. 5. The "Areas of Controversy" does not include the potential <<b displacement and disruption of businesses in Laguna Niguel. 18. Visual impacts "to Paseo de Colinas" will be significant with l�C the Conventional Alternative. What about other local visual impacts? DRAFT EIR-MAIN BODY: Page: 1-1. Para 1.1 States that the objectives include provision of access to various areas. Might this also include reference to the Mission Viejo/Laguna Niguel area? 1-1. Para 1.2 might include reference to the location of the confluence as being MIssion Viejo/Laguna Niguel. 2.3. (Fig 2-1) and 2-3 (Table 2-2-A) describe the Greenfield Drive interchange as being a half -diamond (north side) and as being located in the unincorporated County area. 2-6. (Fig 2.2) and 2-7 (Table 2-2-B) does not seem to clearly locate and describe HOV access/interchanges. 2-8. (Fig 2.3) does not show the alternatives in the same scale or perspective and does not provide identification of major features. Perhaps these could be replaced by or supplemented by a line drawing or plan view having the same base ... to allow for ease of reading and comparison. 2-8. (Fig 2.3) continued. As noted in my general comment, why do f the Conventional and Demand Management alternatives have different alignments? 2-17. Seems somewhat unclear as to operation of the Corridor ,., south of ramp toll plaza at Moulton... relative to alternative use r� I� of and impacts on arterials/local streets in the locale. 2-20. Lists several Park and Ride facilities including Crown Valley Parkway which in other areas appears to be referred to as the Greenfield Park and Ride. 2-21, 22, 24 and 26 were originally missing from the drafts supplied. 2-27. Suggests that sufficient right-of-way will be provided at the Avery interchange to accommodate future construction of HOV direct connectors... however "The direct connectors would require a separate environmental document in the future". What are the implications? 2-27,29. Implies no direct HOV connections at general purpose interchanges; however, seems unclear as is Fig 2.1 vs Fig 2.2. ' 2-30. Fig 2-11 Delete or label conventional alignment. 1 1-7, L 1 1 I 1i is 11 �l 2 ti 25I LEI 174 1 �4 1 �3i 1 3$I 1 2-31 Locate/describe first available interchange s/o confluence. 2-35/36. Seems very critical of, or negative regards, light rail although implying provision for? 2-51/52. What about potential for interchange at Crown Valley Parkway ... what about frontage roads along Greenfield? 2-53/54. Add discussion of Amtrak service improvements and prospect for multimodal. 2-?. Fig 3.2.2 Doesn't show slope instability as is discussed on paqe 3-5 #5. 3-11. Where were 7 sites at which noise measurements were taken? 3-13. Table should identify land use type and which exceed exterior/interior noise maximums (Caltrans/County). 3-33. Fig 3.7.1 does not seem to show _potential for office or industrial/commercial in the Laguna Niguel area south of the confluence. Also the Figure does not seem to show potentially affected residential in Mission Viejo. 3-35. Notes the clustering of commercial/industrial uses around the "project termini" but does not recognize the Laguna Niguel/Mission Viejo cluster. Add 'same. 3-38. Table 3.7.B shows zero additional undeveloped/unconstrained land available for commercial development; but does show 28 acres available for industrial apparently citywide? 3-39/40. Table 3.7.0 generally summarizes private development plans along the corridor;but does not seem to -relate this data to the previous table. This table should be keyed to a graphic exhibit ... more detailed than Fig 3.8.1. Additionally this tabl,e notes that certain Laguna Niguel projects have` a reserved "window" for the proposed corridor ... but do not clarify if the "window" will accommodate either alternative. 3-41. Section 3.8 is titled "Housing and Business Relocation"; however, .there is no discus-sion of relocation; the narrative description seems totally inadequate and the Figure 3.8.1 is much too generalized and inconsistently describes use types, sometimes giving only the project name.. 3-49. Implies that Trabuco Creek and Oso Creek hiking and equestrian trails are in the jurisdiction of San Juan Capistrano? 3-50. Implies that Trabuco Creek and Oso Creek bike trails are in the jurisdiction of the County. 3-51. Fig 3.12.1 Trails should be labeled ar keyed to an associated list. Notes could be added to locate impacted segments. 4-3,5. Regards the Initial Study Checklist: the pages are out of sequence; #38, 39 and #40 probably should 'be checked as significant; at least as they apply to Laguna Niguel(displacement of uses, affect employment, tax base, property values, etc). 4-9. Notes that the ' conventional alignment would require realignment of Oso Creek for about 1700 feet. This may suggest some flexibility in the arrangement/use of the flood control properties as for local circulation. 4-10,11. Figs 4.3.1, 2. Locate/identify before/after st_reambed modification. 4-19. How certain is the Caltrans maintenance facility as .part of the corridor project? Note that the use would include cove -rage of 42 1 431 44 I' 5�I the flood control channel. 4-21. #3-4/3-7 notes that open/underground flood channels will be provided and that they will be coordinated with various cities agencies ... but Laguna Niguel/Mission Viejo are not mentioned. 4-38. States that the project is consistent with policies including: joint land use and transportation planning, advanced systems technology, transit, etc. It may be useful to describe how, for example, coordination is being conducted with cities such as Laguna Niguel/Mission Viejo to assure consistency with local land use and transportation policies. 4-39/40. Not sure how #1,2 and 3 interrelate and what does #3 mean? 4-49. Fig 4.5.1 Add legend and labels for noise barriers. 4-59. Explain to what extent recommended noise barriers would mitigate noise at each site. What would be visual impacts of barriers at each site...view obstruction, aesthetics, etc. 4-74. Fig 4.7.1. Locates forested wetlands and a potential mitigation site; but does not describe the mitigation site or suggest other mitigation sites elsewhere. The potential mitigation site in Laguna Niguel does not seem to be -very suitable. If so the EIR should so note. 4-83. Provides a discussion of the intended TCA wetlands mitigation process; but does not imply coordination with the local agency. 4-85? Fig 4.7.6 and 4-86. Locates and further describes the Oso Creek wetland mitigation site in considerable detail,; but again does not seem to identify sites elsewhere, except for other mitigation sites associated with remote, localized portions of the project. It would seem that other sites along Aliso Creek, Trabuco Creek, Salt Creek, etc may be much more suitable. 4-89. Describes Mission Viejo land use in some detail, but states the corridor would be adjacent to medium residential uses to the west ... but these would seem to be in Laguna Niguel? Also it is implied that corridor would serve as a buffer which complies with a County policy to provide a buffer between commercial/industrial and residential. however, it also notes that it is County policy to locate major commercial and industrial centers proximate to existing or planned transportation facilities. Seems to suggest some conflict of policy interpretation. 4-90. Describes Laguna Niguel land use in some detail and notes that several businesses will be displaced; but that the displacement impacts are discussed in more detail in Section 4.9 Housing and Business Relocations. 4-100. The complete takes of businesses are noted as unavoidable - adverse impacts. Probably it should be noted that there would be significant revenue loss to the businesses and to the City, but that this would be mitigated to an insignificant level? 4-103,110. Table 4.9.A. Needs to be double-checked. Several parcels listed as being under the jurisdiction of the County are in Laguna Niguel, for example: Costco and Allen Cadillac. 4-111,114. Relocation opportunities should be reviewed as part of the Gobar study. 1 u 1 � I P 'I 1 u 1 � psi i 5�1 ' n3 1 1 1 1 1 1 1 4-125. Bike trails not mentioned include: Oso'Creek and Aliso Creek Trails? 4-127. Grading/offsite disposal impacts at.the local level are not possible to assess without an exhibit/table similar to those for other factors. 4-133. Viewsheds are difficult to assess given project vs the limited graphic. "snap.shots". 4-167. Visual impacts are, considered to be the scope of the unavoidable in certain areas such as Colinas however, there may be additional areas such as in Greenfield? Also; the mitigation measures do not potential impacts from noise barriers. 4-172. HOV "success" will apparently require an from 15% to 30%; however, there seems to be some ability to achieve the required success and it would be the toll revenue impacts of HOV significant and de Capistrano; the vicinity,of seem to address is increase in use question of the not, clear what v's conventional operation? 4-178. Add consideration of Amtrak as o-ther mode of travel. 4-187,188. Out of page sequence. 4-190,196. Some out of page sequence. 4-196. #18-22/23 Add discussion of impact/mitigation on local access/business disruption. 5-1,14. Should the basis for determining growth -inducing impact be limited to only the immediate "area of benefit" or should the analysis also include Mission Viejo, San Juan Capistrano, etc? 5-10. It is assumed that the corridor is not expected to increase pressure for intensification or change plans... because plans already account for the corridor and the corridor is designed to accommodate the planned growth. However, if by 2010 it is feasible to incorporate light rail, that provision would likely increase pressure for intensification/redevelopment of areas adjacent to the corridor, especially in areas adjacent to -transit stations. Could the concurrent incorporation of light rail be financed with appropriate value capture mechanisms in recognition of the stated potential for resultant land use intensification? This again suggests some kind of economic impact analysis. 6-2. Related development projects do not include Mission Viejo and Laguna Niguel (although Laguna Niguel is included in the referenced tables). 8-1. Specify where (ie Laguna Niguel) the business uses wi.11 be displaced ... as "irreversible and irretrievable commitment". 9-7. Appears as no comment received. from Lacuna Niguel regards #9.2 Areas of Controversy ie displacement of businesses? 9-8 Omit.s Laguna Niguel and :Mission Viejo from extensive list # 9.3 of agencies consulted with during EIR p,repar-ation. 11-1. Omits Laguna Niguel and Mission Viejo from list #11.0 of agencies to which EIR has been sent. =0 N 10 1q- 11) 0 ATTACHMENTS Fig A-8, B-3. Seem to show major impact on Aliso/Woods Canyon Regional Park. C-2. Assessment of openspace implies "Ultimately, Orange County would obtain a far greater land area for open space purposes than was contemplated in this (1973) comprehensive plan" vs C-3 Para 3.which implies "funding shortages precluded an acquisition program on the scale projected by the Concept Plan" and in a different emphasis "Other land use needs also commanded the attention of County planners, particularly the need for ' harmonizing land use and circulation objectives in southern Orange County". This seems to begin a long rationalization of how the corridor is mainly justified as means to access County open , spaces. This rationalization concludes on C-6 with the statement that "... the corridor does not use the greenbelt areas. Rather, the Corridor is a component of the recreational system itself...". C-?. Several from letters from the TCA to various planning agencies including Laguna Niguel refer to each respective list of recreation facilities as being owned by the City of San Juan ' Capistrano (these include Crystal Cove State Park ... near Newport Beach). The letters to Laguna Niguel and Mission Viejo list no recreation facility "owned by San Juan Capistrano" that would be affected by the corridor...but does not correctly list several facilities in those cities which could be affected according to the EIR. ' APPENDICES A-22. Notes that Oso Creek Corridor is a cooperatively planned resource which extends southerly from Paseo de Colinas/Avery Parkway about 3 miles to San Juan Capistrano. The area includes the as yet to be aligned Oso Creek trail. The EIR states that as part of this project dedication of areas adjacent to the Creek ' will provide for open space (Creek channel?) and the Oso Creel: trail. It probably should be noted that the Oso Creek Corridor also extends northerly into Mission Viejo and that at least a ' portion of the Oso Creek trail is aligned and competed. A-30. Refers to a Rancho Viejo bicycle trail which cannot be implemented being to constrained by Oso Creek, Camino Capistrano and the AT&SF Railway. But this discussion seems to be at odds with the statements in A-22? An adequate exhibit would help locate/clarify these items. E-?. Cumulative land use tables do not include Mission Viejo? ' E-18. Does Table E-E #167 Laguna Niguel Planned Community include Country Village and Colinas de Capistrano? E-23. Mission Viejo not included in description of landforms/geotechnical. E-32.Laguana Niguel habitats..."retention of significant open space areas will mitigate impacts to biological resources to an ' acceptable level by retaining and enhancing natural riparian habitats and significant biological communities". How will this r� 1 ' be done? �� I E-32.Land use impacts are given in several tables but are not discussed in any detail. E-35. Is it appropriate to assert herein that in the Laguna Niguel Planned Community, compliance of future development -with the Feature Plan will minimize cumulative- aesthetic imp -acts in the subregion? TECHNICAL REPORT_ -TOLL VS TOLL FREE 1. It seems that there are some serious questions regards funding and retirement of bonds ... ie availability of Federal funds; amount/rate of developer fees/tool fees;. -and although not stated, the potential implications of a...._lessening of_ the amount/rate of toll fees if HOV and light rail were implemented earl;' in the operation of the corridor? All of this suggests preparation of a Technical Report"for Economic Impact. 2. Para 2.1. Obs.erves that for toll vs free corridor operation "there is little difference in either mainline or arterial traffic projections". This seems questionable? There probably should be an analysis, of the impact of "cheaters" who could possibly use much of the length of the Corridor but -yet avoid tool booth segments. TECHNICAL REPORT -AIR QUALITY 11. Para 3. HOV lands or lanes? ... Typo? _7q 11. Para 5. HOV lands or lanes? ... Typo? What about provision for multi -modal transit given location -of Amtrak lines in the immediate vicinity? 13. Would it be appropriate to note the proximity to the Amtrak line and speculate on the potential for multi -modal with Amtrak as apparently has been discussed. in transportation some committees? 14. Mission Viejo is in Regional, Air. Quality Analysis Area,' Tech Report covers airquality impacts for corridor.-. however in EIR g� HOV lanes at Avery Parkway are said not to be covered in the present EIR but are to be subject to subsequent environmental assessment. Are those- HOV impacts included in this Technical - report? 17. Para 2. States that traffic models could not consider HOV g2 lanes; thus these were not modeled in the Demand Management Alternative and thus not, available for DTIM to assess the regional air quality impacts. What does this mean!? TECHNICAL REPORT-FLOODPLAIN &WATER QUALITY Flood facilities -generally. The PD Technology confluence study should provide for sufficient consideration of multiple use of S these facilities in the vicinity of the confluence of the fcorridor/I-5 in Laguna Niguel...as mitigation of the impacts to local circulation and commercial/i.ndustria.l uses. 17. Fig 11. Shows that I-5 will be widened across Trabuco Creek. What is the relationship of. environmental ass-essment of the $C� var-ous I-5 improvements to the assessments being done for the corridor? �I� 1 19. Notes that under the Conventional Alternative, Oso Creek would need to be realigned and also channelized for about 1800 feet. Again, it might be noted that flood facilities may allow for multiple use (as will be explored in the immediate future via the PD confluence study). 25. Greenfield is not included in the list of park -and -ride facilities? Water quality: 8. Oso Creek is designated as being beneficial for uses including: agricultural supply, body contact recreation, freshwater habitat, wildlife habitat and/or preservation of rare and endangered species. Some of these uses do not seem to apply to this portion of the Creek. This should be clarified. 12. Mitigation of pollutant runoff would include Sg detention/settlement basins and grass covered drainage courses. These should be located and described in this EIR so that their location and characteristics can be assessed. TECHNICAL REPORT -BIOLOGICAL ASSESSMENT 13. Provides classification of importance/significance of plant communities and corresponding level of mitigation; however, no further use of this rating system seems to be made in subsequent text/figures...as would be helpful. S� 36, 38 & 39. Additional classifications and codes are given for Federal/State catagories of sensitive; but these do not seem to be used in subsequent text/exhibits...as would be helpful. 56. Oso Creek is described here and in other pages/exhibits as having 1.4 acres of wetlands north of the channelized portion. This wetland would be mitigated as described on Page 64. 64. Suggests that as impacted by the Conventional Alternative, the wetland could be mitigated by use of a 4.8 acre site adjacent to the unimproved natural portion of the Creek. Mitigation would include grading of this site to the level of the existing stream channel; diversion of the creek channel into the q d mitigation site and redirection of the flow from that site into an improved downstream channel. These are useful considerations, - but again, the flood control facilities in this vicinity should be evaluated for multi -use to help mitigate impacts to local circulation/land use impacts. If this site is questionably suitable; that should be expressed and the point made that be a i superior mitigation site is likely to be found outside the study i area; as for example in Salt Creek (as perhaps implied in the mitigation measures outlined on page 65). 68. The 1.4 acre Oso Creek "forested wetland" area is not i included in the discussion of significant woodlands/habitats. ql Does this mean that it is not significant and would not require mitigation? Appendix: 3,4. Describes the Oso Creek "wetland" in more detail. Based on 2�this description it does not seem to be significant. :f so then that should be clarified. E L I L t I l04 TECHNICAL REPORT-GEOTECHNICAL Introductory letter: 2. Notes that portions of the corridor are underlain by undocumented fills, collapsible materials, shallow groundwater, deeply incised canyons, old landslide debris, etc. Report: 14, Notes a large slide complex south of Crown Valley Parkway near Cabot Road. 26, and subsequent pages. Refers to several figures which are not provided herein. Thus the reader cannot locate the geographic areas referred to as Area 1, 2, etc in the subsequent discussions of cut slopes, fill slopes, etc. Subsequent tables/discussion refer to specific slopes keyed to exhibits which are not provided. TECHNICAL REPORT -NOISE General. Exhibits show the anticipated noise contours and the location of mitigating noise barriers; but does not show the resultant noise contours as needed to evaluate the results of mitigation and resultant impact. Further, the Noise barrier analysis beginning on page 26, typically does not address the visual and aesthetic aspects -of the up to. 16-18 foot high noise barrier walls, with the exception of Site 24, Laguna Niguel Town Homes where the wall height would be determined during preliminary design subject to approval of the property owners. TECHNICAL REPORT-TRAFFIC/CIRCULATION General. It must be assumed that the City Traffic Engineers of Laguna Niguel and Mission Viejo will offer professional comments on this Technical Report. Nonetheless, the following comments may provide additional useful perspectives: 2. The functional distinction is made between the Conventional and Demand Alternatives. However, the difference in alignments is not included in theses descriptions and should be clarified as well. 4. HOV demand analysis seems unfortunately speculative. This would seem'to have a number of significant implications for corridor traffic/phasing/funding/bond retirement/lo-cal HOV ingress/egress... and yet HOV seems to be the primary reason for the functionally . different Demand alternative. Again this suggests the need for some appropriate economic impact/cost- benefit discussion in the EIR/Technical Reports. 6. Vehicular mix implies use of transit buses on the Demand alternative median; but are not included in the table. 7. Why would vehicle occupancy "be 1.1 in general purpose lanes of Demand alternative vs 1 ... assuming availability of HOV lanes? 9. The discussion implies that the corridor will be congested unless HOV demand reaches optimistic levels as via aggressive operations policies/promotion. 12,13. Again, the benefits of the Demand alternative seem based upon rather speculative assumptions. t6 16. In the Conventional alternative, an "A" Level -of Service (LOS) seems rather high for Greenfield? ' 17. in the Demand alternative, an "A" LOS seems rather high for Greenfield... also there is no data for the Avery Parkway interchange? 24. On the basis of the somewhat speculative analysis; the report finds that the Conventional alternative would require up to five lanes in each direction, plus concurrent flow HOV's (how many?) r and auxiliaries (how many?); but the Demand alternative would require only three general purpose lanes in each direction, plus 2 reversible HOV median lanes in each direction plus auxiliaries (how many?) ... need simple table to directly compare conventional vs direct alternatives ...assumptions, lanes, operational levels, costs, etc. TECHNICAL REPORT -SOUTH END CIRCULATION It must be assumed that the City Traffic Engineers of Laquna Niguel and Mission Viejo will provide a professional review of this Technical Report. Nonetheless, these comments may offer additional useful perspectives: General. How does this report relate to the EIR, especially land use Projections and special analysis (elimination of easterly extension of Avery Parkway and Avery interchange connections). 1. This report addresses the two alignments but does not describe the functional differences (Conventional vs Demand) thus does and not seem to relate to the other Technical Report- Traffic/Circulation. Also the text refers to connections with Rancho Viejo Road which is not shown or identified on the accompanying figures. An option considered was Avery Parkway interchange with or without ramps to/from the Corridor... does this mean HOV ramps? The EIR indicates that there is right-of-way for HOV ramps here; but that these would be considered in subsequent environmental documentation? 3. Land use data includes Mission Viejo General Plan study data and County demographic data? ... what about Laguna Niguel and San Juan Capistrano data for portions of the designated study area? 6. Report should include some kind of summary or conclusion; ideally accompanied by a summary table (alternative, uses, peak generation, impacts -by major intersections). Appendix B: B-1. Land Use Data ...table is missing? In missing table, �s Mission Viejo included? What Laguna Niguel uses are included? B-2. Subarea traffic zones should be overlain with some kind of street base and ideally should provide land use overlay on this or on a comparable Figure. 1 RCV BY : XEROX TELECOP I ER ?010 ; CCITT 634 t p s u. '✓� % tx 2 �19-90-fJ:,-i"8 11 19 714 647 5622 / 006 P02 MAYOK ALI. AM[RICA CITY 196243 Dan Young CIIY MANA(1R mAY()Ei F'Rn TEM John Afnita 1)1vict N. Rc:nm FY f.OUNCILMLMAM t'.111' and 1.R uui U.nu(+I L. l�rlfNt Ldw.�rcl I. Cucryxr Ron May CITY OF SANTA ANA C`lanu.i'C.`G;�Y.I)UNCII Patricia A. McGulgan PUBLIC WORKS AGENCY KiCk Norton 101 W. fourth Street, M21 Migut:) A. Pulidn P.O. Bua 1988 Santa Ana, California 92702 Junp 15, 1990 Mr. Steve Letterly Transportation Corridor .Agencies 345 Clinton Street costa Mesa, CA 92626 S-UBJ] CT: SAN JOAQUINPACT REPORT TRANStOPTATION IMPACT R) R (S,7HTC) SCREEN !` CHECK ENVIRONMENTAL Dear Mr. Letterly: City of Santa Ana The _ Public Works Agency has reviewed the San Joaquin Hills Transportation Corridor screen check ntsrforental your Impact Report (SJHTC EYR) and have the following consideration: ••_-^ Transit Al ern�Rr (pages �,[� _ i.a) 'In Chapter Two,, Section e. i�o�� 2--35 and 2-36j, Rail systanq are discussed but it has already been determined that High occupancy Vehicle (HQV) lanes are the preferred alternative method for the proposed median area. Although the Air Quality* Management Plan (AQMP) does not call use for fixed rail - transit along the oorrfou d la d rail densities are not as dense as generally corridors, the City believes adequate space should be provided in the proposed medians to all'Ow for both a rail trans.itway and HOV lanes.. We .feel it is just a matter of time before land use densities will increase, therefore, justifying a mass transit system. If the nee'ded.right-of-way were acquired now it would eliminate the need to purchase additional right-of-- way in the future at a much higher cost, especially with property values escalating due to development. b� The median area is proposed from 64' to 1161 for the corridor odate future ail length. In the order o should be a mini u>Q otf :38 lanes to allow rfor transitway this joint use. F-1 1' RCV BY:XEROX TELECOFIER Mie ; 1990:Ot--8 11:19 714 647 5622 CCITT 334 ;# 3 006 P031 I Mr. Letterly 2 June 15, 1990 The City supports the 88' median for the Design Management Alternative typical section that would allow the median reversible roadways to be converted to concurrent HQV lanes, s�— b and a 24' wide by 16-1/2v high envelope for a fixed guideway transit system. This is preferred as opposed to the 641 median of the Conventional Alternative typical section that provides for either concurrent 110V lanes or a 32' wide by 16- 1/2' envelope for a fixed guideway transit system. gA- — 2. Land use adjacent to the proposed SJHTC should be more fully des-ribed in conjunction with local land use policies for both existing and future development to ensure compliance with the Air Quality Management Plan (AQMP)I the Master Plan of Arterial Highways (MPAH)I the Regional Mobility Plan (RMP), and the Congestion Management Plan (CMP). This will ensure that Transportation System Management (TSM) can be incorporated and implemented in future development. Additionally, with the incorporation of TSM measures, vital open' space and future' growth will be environmentally acceptable. The City of Santa Ana would like to thank you for allowing us to comment on the proposed San Joaquin Hills Transportation Corridor Screen Check EIR. If you have any questions or would like further information please call me at (714) 647-5659, or Mr. Randy Kensing at (714) 647-5615. Sinoerely, George Alvarez City Engineer GA/am/SJHTC I June 12, 1990 F 'I • To: Steve Letterly From: Bill OlsonD memorandum Subject: SJHTC EIR/EIS Comments Transmitted herewith are my comments on the SJHTC EIR/EIS which for the most part are noted in the document with yellow note -its. Other comments are as follows: 1. Mitigation measures are duplicated between subsections of Chapter 4. In such cases they should be cross referenced to -� duplicate measures in other sections so that if one is changed, consideration is given to changing the other to conform. Cross ref erencing should include mitigation measures listed in the 4 ( f ) discussion. 2. It is not clear to me that the .noise methodology is the same for this document as for the ETC. I suggest we - ask Vince Mestre and Steve Wolf to collaborate on a joint memo to confirm �2 that in fact their approach to mitigation is the same or explain why it isn't. We shouldn't be following two different mitigation policies for these corridors (if indeed we are). 3. I see no mention of adverse aesthetic/visual impacts of noise walls required to mitigate noise impacts except briefly on pg �j 4-131. These should be documented in Section 4.5 or 4.15. And landscape mitigation should be offered. 4. References in the text to contour grading as a mitigation measure need to be confirmed with CDMG. Presume this is mitigation measure 15-10 and 15-11. Need to be sure we're serious about this as it will need to be monitored. 5. As a policy item; need to decide if TCA- is to submit some plans to County EMA for approval as proposed in various mitigation measures. On the plus side, this provides for "third party" review, makes it easier to monitor mitigation measure compliance, etc. -�j Alternatively, it also giveCounty a measure of control over s project which may not be acceptable to Board or staff of TCA. In any event, we need to provide guidance to consultants on this once and for all. 6. Except for an editorial note, did not review Growth Inducing Section as we will deal with that via.Gail Shiomoto-Lohr and my collaboration on direction to consultants paper we discussed BD on June 5th. 7. See areas of controversy listed on page 9-7 and 9-8. Of these items, I am concerned that truck use, need for and effect of Sand Canyon and Laguna Canyon Interchanges and visual effects of noise barriers may not be addressed sufficiently in text of document. Please call if you have questions. Enclosure sjhtcomm. nts I � TIC- 2 T(C - 3 4. 5. 7 C - 6. T(, - 7 TIC S.J.H.T.C. Screencheck Concerns Objective statement should be expanded as follows: - a) Project should be related to planned development and to regional transportation needs. b) Define the RMP functions as a major project objective. c) Project purpose and benefits analysis should portray the rationale that the agency travels in reaching its conclusions. Alignment Alternatives a) RBF study should be referenced. b) b) SEOCCS/Greenbelt planning history is necessary to justify the conclusion that other alignment alternatives have been validly rejected. Have arterial highway modifications been addressed a) Jamboree flyover b) MacArthur realignment c) Pelican Hill Road d) Laguna Canyon Road �255 Demand Management Alternative is needed for both -6-. ,Rnd options. Need for further assessment of 73/405 impacts. a) Traffic volumes with and without project. b) Weaving and merging issues. Discussion of related transportation projects. a) Pelican Hill b) Bison/UCI c) MacArthur/OCUTT d) Confluence Noise study should address impacts on existing communities/4f areas a) Turtle Rock b) U.C.I. c) Spyglass d) Harbor View e) Newport North 7 G - 8. 71 — 17. -1-16— 18. -2- Laguna Canyon flooding — a) Corridor b) Park -n-Ride Wetland Replacement Sites are unacceptable to TIC Wildl:'e crossing has not been coordinated with TIC Ford Road realignment and indirect connector to San Miguel has not been addressed. View analysis should be expanded. a; Not clear as to where Corridor is visible (i.e. Turtle Roack, Newport Beach, U.C.I. Bommer Canyon Park OCTAM =I - impact on noise/air quality/��equirements. SJH Rcad - Corridor design impacts `:PAH. I5 Realignment impacts have not been thoroughly discussed (i.e. floodplan) Additional discussion is warranted for the following: a) Laguna Canyon vs E1 Toro b) Moulton vs La Paz Toll rate sensitivety should be acknowledged. Geotechnical section is weak. Should include: a) Identification of gradin7 limits �) Disposal sites? c) Park-n-Ride 1 d) blasting/ripping e) erosion -3- TiG'_ 19. Water Resources Quality - a) ,,/;Jater Analyze impact "no build" % of alternative which might have downstream greater pollutant impacts. b) Treclude summary of Upper Newport Bay sediment Control Program as major long term mitigation program for development -related impacts. Add c) site specific mitigation measures in sensitive areas. d) Assess wetland/riparian area filtration capabilities. TIC 20. Aesthetics a) Views from-Corrid6r vs. Views of th'e Corridor b) Document needs to demonstrate the effect of the 9 site specific mitigation measures on p4-165. t c) The document does not differentiate between public and private views. / d) There is no assessment of alternative cross -sections, e) The photographs tend to focus on views from residential areas rather than public viewing areas. f) There are no impacts on views from the Irvine Coast dedication area trail. g) There is nothing portraying the corridor presence through the coastal hills. h) There is no impact depicting deletion of Laguna Canyon or E1 Toro interchanges. No visual mitigation measures (15-8) are identified in visual exhibit. G" 21 Biological Resources a) Need to articulate scope and impact context for the 16,000 acre greenbelt - relate the 300 acre category 3 impacts as not a significant regional impact. b) { Need to describe significance of sub -area habitat impacts similar to listing of inventory. I�sserteuc� i CMAl 1 1 1 :v 'e. Cr e z :enief Plaza. rC Bcx 'c /'5. ..v • 'nia a 71 -�1 , 4- 5 �� ne. Ca;.ro. 2. 3 ) 72 0= June 19, 1990 Mr. Steve Letterly Manager of Environmental Planning Transportation Corridor Agencies 345 Clinton Avenue Costa Mesa, CA 92626 Dear Mr. Letterly: RE: DRAFT SCREENCHECK DRAFT EIR FOR THE SAN JOAQUIN, HILLS TRANSPORTATION CORRIDOR (SJHTC) Thank you for your cooperation in extending the 'City's review/comment period for ten days, and in meeting with City staff on Thursday, June 14, 1990, to go over staff concerns on the proposed Corridor. We appreciate the opportunity to review the Draft EIR/EIS for the San Joaquin Hills Transportation Corridor. In general, our comments indicate that there are several errors and omissions that make the report incomplete at this time. our_ detailed comments and suggestions for improvements are enclosed. One major concern is the format which depends on references to technical memorandums. We appreciate the intent of this approach which is to minimize the size of the circulated document, but the EIR/EIS needs to contain better summaries of the specific issues, data, and recommendations contained in the technical memorandums (i.e., Executive Summary). Reference numbers for technical documents also need to be used more frequently. Thank you for your cooperation with the agencies in developing this document. We request that a revised draft copy of the EIR be forwarded to Jennifer Regan, containing the missing information and revisions we have requested, per our attached comments. The revised copy should be sent to Ms. Regan before the document is circulated to the public. Mr. Steve Letterly June 19, 1990 Page 2 If you have any questions please contact Jennifer Regan, Assistant Planner (724-6355); or Shirley Land, Principal Transportation Analyst (724-7340). 5inc rel , RO ERT C. JOHNSON Director of Community Development RCJ:SML:rh/sltcac Enclosure cc: Paul Brady, Jr., City Manager Bernie Strojny, Assistant City Manager Allison Hall, Assistant City Manager Steven A. Stackhouse, AICP, Manager of Development Services Peter Hersh, Manager of Planning Services William M. Huber, City Engineer Loren Anderson, Principal Engineer Steve Haubert, Principal Planner Charlene Gallina, Acting Principal Planner Mark Tomich, Senior Planner Stephanie Keys, Senior Planner Ruben M. Santana, Senior Transportation Analyst Jennifer Regan, Assistant Planner Heather Johnston, Assistant Planner CD File r 1 1 J SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR DRAFT EIR/EIS CITY OF IRVINE COMMENTS AS OF DUNE' 15, 1990 GENERAL ISSUES 1 A The Table of Contents should be placed in the front of the document for easy reference. If -this section is not placed in the front of the document, consideration should be given to tabbing it for reference. 2A The figures and exhibits in the document require the reader to realign themselves and their relationship to the Corridor. One standard orientation of the alignment would be recommended. 3A A summary should be provided identifying the differences between the Demand Management and Conventional Design Alternatives. 4A The document has a significant portion of the Noise and Air Quality sections missing.• The text received to date fails to provide clear conclusions and recommendations regarding the impacts. We were unable to complete our review .of these sections. 1R,V— 5A The approach of referencing technical memorandums needs to be improved in providing both a consistent, clear reference to the document and a more detailed summary of issues, data, and recommendations. It should be assumed that the general public or residents who have not been a part of this process will need some of the information. `^ 6o4 The Introduction states, that this document analyzes the SJHTC as a toll facility; but the traffic methodology, results, and interpretation do not clearly discuss how the toll operation impacts the traffic assumptions in the mainline system and the arterials. This has been a specific concern of residents within our community. (,/- 7The EIR/EIS is not clear and consistent regarding the SR73/55/405 Interchange. We support a separate EIR/EIS, but the analysis needs to clearly state the portions that this project will include. The Transportation Corridor Agencies Board has also been asked to vote a $13 million contribution to the interchange. Is the limit of that work per the Birch ramp connectors, or per an interchange that is never defined in this document? Ford Road discussion included more detail than the subject connection. _J:(�2, '/ - Irvine Comments SJHTC Page 2 SPECIFIC ISSUES 1. Page 1 - In "Need for Project" the description of additional daily traffic demand is contrasted to present capacity rather than existing volumes. This approach is confusing and misleading since most readers will not be aware of the difference and other portions of the document display existing volumes in excess of the capacity. We recommend using a comparison of future and existing volumes. 2. Page 1 - Should include in paragraph three the year Draft EIR #494 was completed and why that EIR is being superceded by this draft EIR, per similar discussions in other sections of this document. 3. Page 1 - Should discuss how vehicle speed will be reduced as congestion increases in other facilities, if Corridor is not built over the years. 4. Section 1.4 - Should provide a summary of all prior environmental documents for this project and prior alignment determinations considered by the TCA in the previous EIR since this draft EIR supercedes #494. 5. Page 3 - The "Description of Project Alternatives" should include a reference to transit as a feature that might be implemented in the median similar to the HOV comment. It could be qualified that it is still subject to a separate EIR, but the median width of the demand management is designed to address this concept. 6. Page 3 - The objectives section could be supplemented by adding "improving air quality." 7. Page 6 - "Table A - Summary of Impacts and Mitigation Measures" makes references that are difficult to find in this document. It is recommended that a summary be included for easy reference. The list of impacts also seems incomplete. For example, the goal of this EIR/EIS is to address roads as toll facilities, but the circulation category does not even reference this condition. 8. Page 1-3 - We would like to obtain a copy of the matrix indicating where the comments on DEIR No. 494 have been incorporated into this EIR/EIS. 9. Page 1-4 and 109 - The same previous comment regarding the use of projected daily volumes in contrast to capacity. The balance of the tables utilize volumes and level of service descriptions. It should be noted that existing conditions exceed this same capacity. The projections for SR-1 indicate 40,000 to 57,000 vehicles per day, while the figures display a range of volumes from 43,000 to 64,000. 1 1 1 1 1 7 1 1 1 I Irvine Comments SJHTC Page 3 10. Figure 1.5.1 - These volumes are not always posted consistently in this map and the related Tables 1.5.A and B. On Pacific Coast Highway (SR-1), the two posted volumes between Sand Canyon and Laguna Canyon two significantly without any obvious reason. 11. Page 1-6 - Table 1.5.A contains, several serious errors in LOS for 2010 conditions with and without the corridors where volumes increase and LOS improves: There are segments that the volumes do not match the previous Fig. 1.5.1. The SR-1 information is repeated on Table 1.5.B (page 1-8) referenced as Pacific Coast Highway; however, the data does not match. 12. Page 1-9 - The previous tables indicate that the forecasted 2010 volumes assume the operation of the Foothill Transportation Corridor, but there is no reference to this in the text similar to the discussion of the planned Caltrans improvements. 13. Page 2-2 - Even though the grading impacts will be substantial, there should be some statement of the TCA's intent to minimize them whenever possible. This is an example where "brief" statements are not always concise or positive in their presentation of information. 14. Page 2-17 - The reference to setting a speed limit for AVI is a new item. It was our understanding that they could operate at mainline speeds. The "Truck Traffic" should indicate if there are features of design that accommodate the truck 'traffic rather than just a statement they will be permitted. The trucks- are never included in any analysis regarding their impacts on the roadway operation with 6% grades. 15. Page 2-20 - Under "Park and Ride Facilities," Caltrans also develops park -and -ride lots:. least be The "sufficient size" of the median should at identified in a range of feet (i.e., 64-88) in the section regarding "Potential Future Median Use Options. The description and the figure 2.9 do not seem to support the comment that both the demand management and the conventional medians can accommodate both HOV and transit. It is our understanding that both uses would require at least 88' minimum .sections. 1 Sri ii Irvine Comments SJHTC Page 4 16. Page 2-27 - In the "HOV/Transit" section there is a reference to a surveillance system. The text indicates that it is discussed in detail in Chapter 4, Section 4.16. The only detailed discussion was found on page 4-188- Mitigation Measure 16-3. It should be clarified that the HOV feature is actually part of a proposed traffic management system for the total corridor. 17. Page 2-29 - Why is the realignment option for I-5 connector only associated with the Demand Management Scenario. It seems that the direct alignment could also be used. The approach of the document should be that there are two I-5 connector designs and how each of the two corridor concepts (Conventional and Demand -management) would apply to the options. This suggested approach, for example, would permit the Demand Management Corridor concept without the realigned I-5 connector. It is also needed to prepare comparative cost estimates. 18. Page 2-31 - Same comment regarding the I-5 Connection considered for Conventional Alternative (see Comment page 2- 29) . 19. Page 2-53 -The description of Barranca/I-5 Overcrossing states that it will open a major east/west arterial but the benefit ends at Sand Canyon. This seems to overstate the potential of this arterial. 20. Page 2-54 - The description of the SR73/55/405 interchange indicates it has received environmental clearance, while other statements in this EIR/EIS document indicate that the environmental is needed and will be processed under separate environmental analysis. Please clarify. Description of the "Ford Road Extension/Realignment" in the first sentence does not read well. There are four alignments under discussion. To eliminate confusion with the pending EIR, the detail of Ford Road Realignment should be deleted. 21. Page 3-11 - There should be more information regarding the noise impacts to Turtle Rock and UCI Housing, even if it is negligible. Figure 3.5.1 does not indicate that any measurements were taken in this area. This will be an issue with the residents. Caltrans uses a format where the individual segments for each direction between arterials have a summary of their findings versus the adjacent land uses (see I-5 EIR). This is very effective in dealing with property owners. Irvine Comments SJHTC Page 5 22. Page 3-49 - The City of Irvine.'s Bicycle and Equestrian/Hiking trails are not documented. We have consistently requested ,the development of a corridor crossing that accommodates open space trails, such as Bommer Canyon, and have indicated the need to incorporate our design standards .for both on -street bicycle lanes and :sidewalks. Sand Canyon was missing from the list of arterial sidewalks. 23. Page 4-23 - The "Air Quality" section discusses a study without any cross reference to either a technical memorandum number or the table which lists it as an available supplemental document. This paragraph does, not indicate whether or not the following information is based on the reference document. Is this section complete? The page numbers are skipped, especially where figures have been included (i.e.., page 4-28 goes to 4-58 after eight pages of maps). 24. Page 4-125 - The comment that 'the -County and/or local agencies will assume construction of a bicycle crossing is not per our understanding. The previous discussion with staff during the planning phase, has been that a•wildlife and/or emergency access to the open space areas would be be needed so the bicycle and equestrian/hiking trails would considered in the design. The discussion under this section (4.13) and the referenced 4.18 does not adequately address the impacts of the Corridor to the trail elements. This Corridor will sever natural areas and require.overcrossings or undercrossings to restore the access. 25. Page 4-126 - Per our comments, mitigations are required. 26. Page 4-146 - The discussion does not include the view impacts of the, mainline toll facility to Turtle Rock. The copy of Figure 4:i5.8 was very poor and the corridor feature could not be evaluated. 27. Page 4-169 - The statement that OCTAM,II traffic.projections would not have significant impacts does not seem consistent with the higher traffic numbers it is producing. 28. Page 4-169 - The 2010 traffic volumes per the referenced Figure 4.16.2 does not match Figure 1.5.1. There is no explanation why they are different. 1 F-1 Irvine Comments SJHTC Page 6 29. Page 4-172 - Where is the 30% HOV requirement analyzed? It should be contained in a technical memorandum with a summary of the issues and a reference to the document. 30. Page 4-172 - Where is the analysis regarding the ramp intersections? The issue regarding the use of the regional traffic model for this level of analysis as well as the design of the ramps are issues that have not been resolved. Again a technical memorandum is needed with a reasonable summary of the information. Our residents will request this information, especially at ramps where toll plazas will be operating. 31. Page 4-173 - The assumptions regarding the toll operation impacts have not been documented. The EIR/EIS needs additional information regarding tolls, especially regarding the realized benefits of the arterial system during the period the Corridor operates as a toll facility, since the justification for the revised environmental document is based on the toll condition. The toll issue warrants a technical memorandum to document the assumptions. This is a significant issue raised by residents. The exhibit'regarding reductions in traffic is probably per a toll free condition but it is not clear. The traffic forecasts need to be consistent and clear, regarding whether or not the numbers reflect tolls, given the purpose of this EIR/EIS. In the analysis of arterial impacts, the toll condition would represent the worst case. 32. Page 4-175 - The toll analysis needs to be referenced. The City has submitted comments on the draft toll report and no response has been received to date. Part of our concern is reflected on Figure 4.16.3 where volumes on the parallel arterials increase with the Toll Free estimates. 33. Table A - Summary of impacts and Mitigation Measures identifies that 18 areas will be impacted, and identifies only 15 areas as requiring mitigation. Not only do these two appear inconsistent, but also the Technical Noise Study identified at least 32 sites as requiring some form of noise mitigation. This needs to be corrected. 34. Tables 2.8C and 2.8D - An exhibit should be provided depicting the route segments. 35. A view perspective and profile should be provided in the document for Bommer Canyon showing the relationship of the Corridor to the habitat, open space, and bicycle/equestrian trails in the project area. 1 Irvine Comments SJHTC Page 7 SOU- 36. Discussion should be expanded on the the Corridor alignment and design options which facilitate wildlife migration. 37. On the environmental checklist for the proposed project, it indicates that surface water will not be negatively impacted by the proposed project. This information is in conflict with that contained on pages 4-16, 4-17, and 4-18 which states that negative adverse impacts will occur to adjacent drainage areas. 38. The City's Master Environmental Assessment (MEA) identifies Bonita Canyon Reservoir as a moderately significant habitat area, and as such, requires a 30.0-foot buffer area around it. The Draft EIR should address if the buffer area will be impacted, and if so, how impacts will be mitigated. All efforts should be made to mitigate wetlands' impacts which may include refining the Corridor alignment. Using the worst -case scenario for biotic impacts, the demand management alternative, and the total number of biotic acres that may be impacted by the project within. the City of Irvine and its Sphere of Influence, represent 66% of the total. Hence, consideration should be given to Alternative "R," as documented in Draft EIR #494, for the Phase II alignment alternatives. 39. Since various habitats will be destroyed by the construction of the Corridor, the Draft EIR should include a discussion on the diminished availability of wildlife breeding grounds, and the cumulative effects of this in terms of species relocation, crowding, and species compatibility at the possible habitat mitigation sites. 40. Page 4-9 states that Bonita Creek may be realigned or placed in an underground conduit for 8,400 linear feet (nearly a mile and a half). This will have a significant impact on the biotic habitat. It is unclear whether the biological assessment considered this streambed modification. The Draft EIR needs to analyze the impacts from realigning and undergrounding the conduit. The acreage total for Bonita Creek should reflect this modification, if it does not do so currently. 41. The environmental checklist should be placed at the front of the document like the Table of Contents for the reader's reference. The checklist can then serve as a guide to the reader while reading the document for impacts. 42. The Draft EIR should more fully explain how the Corridor will produce new light and glare, but no negative impacts on the adjacent biotic communities. The Draft EIR discussion needs to be supplemented with details and specifics. Irvine Comments SJHTC Page 8 43. The proposed project will encroach upon the habitat of unique and/or species of special concern. The Draft EIR concluded that this was significant, and therefore, proposed off -site habitat mitigation. Thus, #28 should be revised from "yes, no" to "yes, yes." 43. 9.3 Consultation should be revised for the City of Irvine to state the following: Irvine. City of: Chief Leo Peart, Irvine Police Department; Steve Haubert, Mark Tomich, and Heather Johnston of Planning Services; Steve Stackhouse and Jennifer Regan of Current Planning; and Shirley Land and Ruben Santana of Transportation and Engineering Services. 44. The City of Irvine should be included on page 11-1 for agencies, organizations, and persons to whom copies of the document have been sent. NOISE TECHNICAL STUDY 113 The Introduction should be revised to be identical with that contained in the Air Quality technical study and of the Draft EIR. As it is currently written, it is inconsistent and missing important pieces of information. 25 Page 2 - The noise descriptors section is very brief and is written for someone who has a working knowledge of noise terminology. This section should be revised to contain a detailed discussion of noise and its elements, since the Draft EIR also does not contain it. 3E3 Page 3 - Are the noise prediction sites the same as the , noise sensitive receptors? The text needs to be revised to clarify this issue. Sensitive noise receptors should be defined. 43 Figure 4 is out of sequence in the document. 543 Need to have at least two noise receptor sites in Irvine, and preferably around the Turtle Rock area. Previously in the City's comments and public scoping meetings for the Draft EIR #494 two years ago, Turtle Rock residents voiced concerns over potential noise impacts from the Corridor. Currently, the only site monitored in the Irvine area is site 11R-42" for Crystal Cove State Park, a passive recreational area. 1 Irvine Comments SJHTC Page 9 6 B Page 6 - The impact assessment only addresses roadway noise impacts. It excludes aircraft noise impacts, which several of these noise sensitive areas also experience. If this information was included in the CNEL's, then the text needs to state that. If not, the CNEL's should be revised, or another section added that addresses the impacts from aircraft. 7[3 - Page 15 An increase of 3.0 dB is noticeable; therefore, the conclusion in the last paragraph, last sentence should delete the word "barely." 88 Page 26 - The noise barrier analysis states limitations on barrier heights, yet the proposed mitigation measures appear to be contrary to the criteria. 9$ Page 30 - The mitigation measures are too brief. More detail needs to provided on who is responsible for constructing the barriers, when they will`be constructed, who will review and approve their design, etc. 'I AIR QUALITY ANALYSIS zKU- 1C The introduction prefaces the technical study as being under a "no toll" operation, since that, it concludes, would be the worst -case scenario. The fifth paragraph, however, is confusing. It states that the analyses are based on toll - free traffic projection "with toll plazas in place." In terms of air quality analysis, what is the purpose of analyzing this condition (plazas in place)? 2Z Page 5 - Under 4.2, it should be said that the monitored CO ' levels were well below state and federal standards as Table 1 demonstrates. 3C Figure 2 - Is this map current? Whenever the City receives AQMP reports, they always include the lower -desert with Indio. 4 C The document needs to include a discussion on the,RMP, GMP, and Prop. 111 consistency (congestion management) in terms of the AQMP. 5C Page 21, Table 4 says the percentage of while the percentage of cold starts is 12%. What happened to the other 88%, are 1 hot starts is 2%, 10%, which totals they cold or hot? n Irvine Comments SJHTC Page 10 ,V- 6G Figure 5 could be deleted since on Figure 4 the park -and - ride lots were already shown for the Corridor. 7;0_ Where are the mitigation measures for air quality impacts? There are no mitigation measures identified, including construction impacts. BIOLOGICAL ASSESSMENT 1The Draft EIR needs to identify where off -site mitigation will occur for habitat removed to construct the Corridor. The discussion should also include the agencies and process that will need to be undertaken by the TCA to replace the habitat. 2 P The City of Irvine would like to be involved in planning and approval of the habitat removal and off -site mitigation program that the TCA will have to undertake for this project, since 66% of habitat impacts lies within the City and its Sphere. slsjhtc LI, 1 11 CITY OF COSTA MESA CALIFORNIA 92628-1200 P.O. BOX 1200 FROM THE OFFICE OF THE TRANSPORTATION SERVICES MANAGER June 20, 1990 Mr. Steve Letterly Manager, Environmental Impact Transportation Corridor Agency 345 Clinton Street Costa Mesa, CA 92626 SUBJECT: SAN JOAQUIN HILLS -CORRIDOR DRAFT EIR COMMENTS ' Dear Mr. Letterly: Enclosed are comments relative to the Draft EIR for the San Joaquin Hills Corridor. Generally, the City of- Costa Mesa is concerned with the future impacts projected on the I-405, existing SR-73, and the confluence of these corridors. It is our intent that these issues be identified, resolved, and mitigations implemented prior to the completion of your project. A formal request will be submitted to your agency within' -the -next few weeks to participate in defining impacts and developing funding mechanisms to initiate improvements. Your critical review and response to the attached comments is appreciated. S inc 7rely, WILLIAM J. M RRIS Director of Public Services DS:,cv enclosures cc: Peter �Buffa, Mayor Allan Roeder, City Manager David Sorge, Associate Engineer Jerry Bennett, Transportation Corridor Agency Gene Foster, Transportation Corridor Agency Daryl S. Fleming, Corridor Design Management Group `Jill Wilson, Larry Seeman and Associates 1 77 FAIR DRIVE • (714) 754-5334 L SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR REVIEW OF DRAFT EIR/EIS 1. Impacts of the extension of SR-73 on existing SR-73 requires more in-depth discussion, for example: o How much additional traffic will use existing SR-73 if it is extended (both ADT and peak hour volumes)? o What is the impact on existing SR-73 from the additional traffic if it is extended? 2. Impacts on I-405 if SR-73 is extended, require a better discussion and understanding, for example: o Figure 1.5.1 and Table 1.5.A show very little, if any difference in traffic volume on I-405 with and without SR-73 being extended. Studies prepared by the City of Costa Mesa (which are based on the Orange County OCTAM traffic model) show somewhere between 60,000 to 70,000 vehicles diverted to SR-73 from I-405 if SR-73 is extended. Figure 1.5.1 is incompatible with the City's analysis and simply does not make sense. o Figure 1.5.1 also shows no traffic on existing SR-73 currently which is not correct. Figure 1.5.1 also shows an ADT volume of 135,000 in the future at Jamboree. Studies previously performed by the 'City show this amount to be about 125,000, this agrees fairly closely. The City estimates the current ADT volumes on existing SR-73 to be about 60,000 vehicles. It seems reasonable to assume that if there are about 140,000 vehicles on SR-73 at the northern end, a significant volume of traffic has been diverted from I-405 through Costa Mesa and Irvine. This does not appear to be the case from Figure 1.5.1 and other data in the EIR. o What is TCA's estimate of the volume of traffic diverted to the SR-73 freeway, if it is extended, at the SR-73/I-405 interchange. A.M. and P.M. peak hour volumes estimated for the City of Costa Mesa are about 4,000 and 5,000, respectively. This amounts to about two to three lanes of traffic off of I-405 in the morning and added to I-405 in the evening. 3. Page 2-2 contains a reference to Figure S-1. This is probably Figure 2-1. 4. Section 2.8 of the EIR discusses alternatives considered for transportation improvements but withdrawn from consideration. Page 2-37, item g. discusses widening I-405 and I-5 in lieu of extending the SR-73 freeway. Table 2.8.A addresses lanes on I-405 with and without SR-73 extended. The City does not agree with the required number of lanes with the corridor 2 1 L� 1 1 1 extended. We consider- at least four more lanes are required if the corridor is not.extended.Also Table 2.8.A does not agree with Figure 1.5.1. Figure 1.5.1 shows *no difference in traffic on the I-405 with and without the SR-13 extension, and Table 2.8.A shows at least two more lanes are required if SR-73 is not extended. There seems to'be no justification in the EIR to support Table 2.8.A. Page 2-38 discusses three impacts with respect to I-405 if SR-73 is not extended. While the City agrees with the discussion, the data is not provided in the EIR to support the conclusions reached on page 2-38.. Page 2-42, item (71 states that 1143,000 daily trips would travel on the corridor between its interchange with I-4.05 and I-5 and these trips would use I-405 if SR-73 were not extended." This seems to support the City's position that about 60,000 to 70,000 vehicles will divert to SR-13 from I-405 if SR-73 is extended. However, this does not agree with Figure 1.5.1 or Table 2.8.A in the EIR. This apparent discrepancy needs to be clarified.^ The last paragraph on page 2-42 states that "based on the ' assessment of the factors summarized above, widening of I-405 was removed from consideration -due to the extraordinary magnitude of impacts to the remaining freeway and arterial system." The City agrees with this conclusion but not how it was arrived at in the EIR. There is no information in our opinion presented in the EIR to prove this point which we ' believe is correct. Findings from the Costa Mesa I-405 Access Study between SR-73 and SR-55 indicate that if SR-73 was not extended, the traffic volumes remained appropriately, the same. The City concluded there was not a practical manner in which to widen I-405 through this stretch without spending significant dollar amounts, and this still was not feasible. 5. Page 2-54 discusses the fact that SR-73/SR-55 and I-4-05 confluence improvements for some of these improvements are expected from the adjacent -cities, the County, Caltrans and TCA. The TCA needs to further define their responsibily for funding these improvements-. This would tie into the additional amount of traffic using -these facilities, if SR-73 is extended. TCA's contributions and assistance are vital in improving the existing SR-73 and other freeway improvements in the area. ' 6. Section 4.16, Circulation, states that one of the objectives of extending SR-73 is to reduce congestion on I-405. Figure 1.5.1 shows virtually no change on I-405 with SR-73 being extended which would appear to defeat one of the stated objectives of extending SR-73. Other information provided in the EIR also fails to support this objective. The City agrees 1 3 1 1 with the objective but fails to find any support in the EIR to clearly demonstrate this objective being met. Figure 4.16.1 shows 140,000 ADT volume on the north end of SR-73 in 1995 which appears to support the City's position with respect to diversion of traffic from I-405. 7. Page 4-173 has a table showing the reduction of traffic on I-405 with SR-73 extending in the range of 5,000 to 20,000 ADT. The City feels this figure more correctly approaches 60,000 to 70,000 ADT. This difference should be resolved, otherwise the justification for extending SR-73 is significantly weakened. 8. Page 4-175, second paragraph entitled Impacts to Existing SR-73 North of the Corridor states "The traffic will increase on existing SR-73 by 46,000 to 68,000 vehicles 'per day if SR-73 is extended." This supports the conclusion of the City, as previously stated, but does not support other information contained in the document, notably Figure 1.5.1. This discrepancy needs to be resolved. 9. The third paragraph on Page 4-175, entitled Impacts to I-405 North of the SR-73 Confluence states that extending the corridor only increases the traffic volume on I-405 by 2%, which is considered insignificant. This is because it is assumed the same traffic would occur on I-405 whether SR-73 was extended or not. The City would contend that if SR-73 is not extended, the amount of traffic generated would be reduced because the County would not allow development in South County to occur. This appears to beg the question of the impact on I-405 without extending the corridor. If SR-73 is not extended and the development does not take place the traffic volumes on I-405 north of SR-73 would be significantly reduced. Therefore, the impact is much more than 2% assuming development is not reduced in South County if SR-73 is not extended. This should be analyzed by TCA and findings should indicate that the impact on I-405 with and without the extension of SR-73 will be significantly greater than 2%. 10. Page 4-187 lists some additional mitigation measures. The City particularly supports additional mitigation measure 16-1 and would like to explore these -studies in the near future. The City requests information on the status and timing of the proposed studies. 1 7 I 1 1 11. The following comments relate to the Traffic and Circulation ' Study Technical Report dated May 1, 1990. a. The last two lines on page 10 state "Alternatively, the SJHTC seems to have little anticipated impact on I-405." The City believes this to be completely wrong and 4 1 misleading, and disagrees with the stated objective of extending the corridor and much- of the information contained in the EIR. This additional discrepancy also needs resolution. b. The summary on page- 24 should be expanded to discuss the impacts of extending the corridor on existing SR-73 and on I-405 more in line with the City's position and comments contained in the EIR. The City believes the ADT ISummary volumes shown in Figure 4 for the north end of I-4-05 are incorrect based on the previous discussions of the amount of additional traffic on I-405 if the corridor is not extended and development in South County continues. The EIR presents confusing data with respect to freeway volumes at the north end of the corridor with and without the corridor being extended. The assumptions behind these figures need to be discussed and evaluated very carefully and listed in the EIR. It appears from an evaluation of the traffic information provided in the EIR, there is little justification for extending the corridor as -Figure 1.5.1 shows no impact on I-405. The differences in traffic projections (or land use assumptions) needs to be resolved in order for the EIR to support the stated objective of reducing congestion on I-405 and adjoining arterial highways if it is extended. The conflicting traffic -projections in the EIR and -the Traffic and Circulation study need to be resolved also. A clearer presentation of the traffic projection ADT volumes would be of ' great assistance in evaluating the impacts of the corridor extension and its impacts at the north end of the -project. 1 5 1 VI J 1 1 Comment No. Response RESPONSES TO COMMENTS ON MAY 1. 1990 PRELIMINARY DRAFT SJHTC EIRfEIS July 23. 1990 ' CALTRANS CAL-1 Refer to responses to comments on this Preliminary Draft EIR/EIS which follow this -response. CAL-2 Cover has been included with this second preliminary draft. CAL-3 Coversheet revised. CAL-4 Included as cooperative agency per FHWA. CAL-5 Changes made consistent with FHWA comments. CAL-6a Text changes make. CAL-6b Text changes made. CAL-7 Text changes made. CAL-8 Text revised. CAL-9 Title centered. '. CAL-10 Text Cross revised. section added. CAL-11a-e Figure revised. Aerial photo figure is being prepared. CAL-12 Text on joint planning added elsewhere in summary. CAL-13 Text added. CAL-14 Text/table revised. CAL-15 Text modified. I 07/24/9O(TCA901A\RESPONSE.CMT) 1 1 1 Comment No. Response CAL-16 Revised Table 4.1.A consistent with revised Section 4.2. CAL-17 Text edit, p. 4. CAL-18 Figure revised. CAL-19 Text revised. CAL-20 4 relates specifically to access to recreational areas. CAL-21 Per TCA staff, route adoption is covered by existing language "approve project." CAL-22 Text revised. CAL-23 "Incremental" is utilized to mean the additional pollutant loading from the Corridor would, in and of itself, be insignificant, yet would contribute towards the cumulative pollutant loading into downstream drainages. The precise amount is not discernable given the potential fluctuation/variation of stream flow and pollutant source factors (i.e., rainfall and oil and grease produced by Cor- ridor vehicles). CAL-24 Discussion has been added in Section 3.6 re: Least Bell's Vireo and results of Spring Survey. Additional text has been added to Bio- logical Assessment from DEIR No. 494 analysis of other Federal/ State listed and candidate species. However, we did not include in current EIR/EIS as they were not found in the Corridor APE. CAL-25 The mitigation provided in the EIR/EIS (Measure No. 6-15) indicates that replacement plantings for impacted oak woodland acreage will be determined as part of the revegetation program to be developed by the project proponent in conjunction with the project biologist prior to construction. If, prior to distribution of the Draft EIR/EIS, the guidelines as set forth in SCR 17 become available, specific replacement ratios may be included. CAL-26 Appendices added. CAL-27 Text has been clarified. 1 r 1 1 1 07/24/90 MA901AVESPONSE.CMD 2 1 C IComment No. Response CAL-28 Despite the current four year drought that exists in the area, ' developing a water supply is not anticipated to .be a problem be- cause water districts in the area of the project have indicated (in writing) an interest in supplying the project's contractors with reclaimed water. Specifically, the Irvine Ranch Water District is on record with the San Joaquin Hills Transportation Corridor Agency as offering reclaimed water for.both .construction uses and land- scaping. CAL-29 Summary revised. Second paragraph, sentence added as edited at ' June 25 meeting. CAL-30 No -accident data included per June 25, 1990, meeting. Other infor- mation provided. CAL-31 System linkage and modal interrelation not applicable. Revised text to include two headings under need for project: 1) Social ' Demands and Economic Development, and 2) Roadway/Capacity Deficien- cies. CAL-32 Changed Traffic and Circulation heading (Section 1.5) to Roadway Capacity Deficiencies under Section 1.3. CAL-33 No revisions to document. CDMG/TCA -acknowledges that this anomaly exists. It is a result of derivation functions in the model for AM and PM Peak Hour estimates. It's impact is to somewhat overesti- mate AM Peak Hour trips, thus providing a conservative design through identification of the maximum section necessary. CAL-34 Included in Circulation section; no changes to Chapter 1. CAL-35 Text modified and Figures 1.5.2 and 1.5.3 deleted. CAL-36 Deleted "ultimate;" replaced with "traffic." "DEIR" "DEIR CAL-37 Revised to No. 494" to be consistent. CAL-38 Table 1.5.A has been revised to list SR-1 links from south to north. ' 07/24/90(TCA901A\RESP0NSE.CMT) 3 P 1 Comment No. Response CAL-39 Tables 1.5.A and 1.5.6 have been revised to list links from south to north. CAL-40 Text revised. CAL-41 Text modified. CAL-42 Text revised. CAL-43 Text modified. CAL-44 Text added to Chapter 2, Design Features of Demand Management to clarify that either I-5 connection could be considered for Demand Management. Per TCA direction, majority of text in EIR/EIS re- flects Alignment #2 I-5 connection with Demand Management. CAL-45 Text not revised. EIR/EIS based on Conceptual Design Report. Discussed with George Beighle 7/18/90. CAL-46 Reorganized Chapter and moved 2.5 and 2.6 after 2.2; additional edits were made to clarify Chapter 2 organization. CAL-47 The major underground utility lines along the project consist of the following: 16" high pressure gas (SCGC), 36" water (MWDSC), 42" water (MCWD), 12" high pressure gas (SCGC), 27" sewer (IRWD), 48 duct telephone conduit (PacBell), 24" water (IRWD), 54" water feeder (MWDSC), 18" water (IRWD), 36" water transmission main (LBCWD), 24" effluent transmission (AWMA), 16" water (MNWD). These have been reviewed by the TCA, and it is intended to relocate all of them within the APE. The major above ground utilities consist of several 12KV, and 66KV lines belonging to SCE. SDGE also owns a 220 KV line along Camino Capistrano and Laidlaw Gas Recovery Systems owns a 66 KV line. It is the intent of TCA to relocate these lines within the APE typi- cally on higher poles to clear the project where possible. In both the below -ground and above -ground cases, TCA believes all relocations can be made within the APE. In the event that unknown utilities are encountered during construction, TCA recognizes its r] 1 I�I 1 it 1 0 1 07/24/90(TCA901A\RESPONSE.CMT) 4 , i 1 _7 IComment No. Response responsibility to conduct additional environmental documentation if �. relocation outside the APE is required. ' CAL-48 Table has been revised. CAL-49 All text on park and ride lots has been moved to one location. Text revised to clarify relationship of lots to the project. CAL-50 Added text to Section 2.4 to clarify -that HOV would be displaced by light rail. ' CAL-51 Text has been moved to Demand Management discussion per comment. CAL-52 Text modified in Chapter 2, "Design Features of Demand Management Alternative," I-5 Connection. CAL-53 Section 2.2 modified per comment. ' CAL-54 No Build alternative expanded to incTude references to types of features that would not be built, as discussed June 25, 1990. CAL-55 Per TCA direction and Caltrans note, no changes to text. CAL-56 Table 2.8.A modified. CAL-57 Park and ride locations were removed from Figure 2.1 (now Figure 2.9); list of potential locations still remains in Section 2.11. CAL-58 Figure revised. CAL-59 No text changes made; additional text on potential future median use is provided in each section related to build out. CAL-60 No change to document. Page 2-20'-of the"E1R/EI.S clearly states the TCA's intent with respect to rail: "these transit options are not proposed as part of the project." The TCA has consistently stated in a clear fashion that the Corridor is being planned to accommo- date a range of future improvements in the median and that one of these may be rail transit; furthermore, the TCA has consistently stated that we do not have the funds to build rail transit'as part ' 07/24/90MA901A\RESPONSE.CK) 5 L Comment No. Response of the Corridor project at this time or in the foreseeable future. The TCA has also consistently gone on record with engineering data that shows that rail transit is not an immediate solution to traf- fic congestion due to the density and form of land use in the area. Further, we have explained that future changes make it wise to plan the Corridor to accommodate this lifeline facility for the high tech developments which rail transit may achieve in the future. Given the extreme length of time it takes to develop funding for the operations, vehicles, facility stations and services points of a rail system, TCA's study group is prudent. At the Board meeting establishing the rail study, it was stated for the record that rail is not a part of the Corridor project at this time. The TCA under- stands its obligation to prepare a separate environmental study when rail becomes a goal of the project and the TCA is committed to that process in the long term future. CAL-61 Tables 2.0 through 2.E and Figure 2.13 remain in text; titles change on Tables 2.0 through 2.E to clarify that they are from EIR No. 267. Per subsequent direction, Section 2.8 was left in, with edits made per comments. CAL-62 Wetlands Avoidance Alternative was added to Section 2.0 and sug- gested text modifications per comment were incorporated in this section. CAL-63 Figure 2.15 was deleted. CAL-64 Text revised to incorporate information. CAL-65 Text not added; covered by Related Transportation Projects text. CAL-66 Text not added; covered by Related Transportation Projects text. CAL-67 No change needed in document. Design issue. CAL-68 Text added. CAL-69 Cover sheet revised. P 1 1 07/24/90(TCA901A\RESPONSE.CMT) 6 , 1 t 1 Comment No. Response CAL-70 Revisions .to text (Design Features of Conventional Alternative) were made per input from Gene Foster. CAL-71 Revisions to text in Design Features of Conventional and Demand Management have been made to clarify median use. CAL-72 See response to comment CAL-71., CAL-73 See response to comment CAL-52. CAL-74 No change in document. Design issue. CAL-75 This is a issue d"esi. n which g u hi h can be handled by signing. 1 CAL-76 Changed "confluence' to "interchange." CAL-77 Table was updated per comment. CAL-78 Edit made per comment. CAL-79 Added definition of "large;" deleted "large" and added "100 feet" per EIR No. 267. CAL-80 Edit made per -comment. CAL-81 Edit made per comment. CAL-82 Text will be pulled up to fill up page. Inadvertently not pulled up in.July 23 version either. CAL-83 Changed cover page to Biological Technical Studies document. CAL-84 Text has be e ' been r v�sed to discuss why faults are not considered active. CAL-85 Added text. CAL-86 Comment CAL-91 from Sylvia Wells -Vega has been inserted to replace previous text on wetland' -definition. Definition moved to precede Forested Wetland/Scrub/Riverine description in plant communities. 07/24/90MA901A\RESPONSE.CMD 7 Comment No. Response CAL-87 Agreed in June 25, 1990, meeting to not address comment. CAL-88 Text revised and inserted. CAL-89 Text inserted. CAL-90 Edits made; paragraph replaced. Re: last paragraph of comment: text added on regional wetland impacts. The biological assessment text uses the plant community names in the original field study prepared by P&D Technologies. The current assessment is based to a large degree upon their report, with major sections having been revised only minimally or not at all. The descriptions of habitat in particular were left basically un- changed, although there were some combination of habitats and elim- ination of habitats not impacted by the Corridor in the discussion. P&D's original analysis was based on a slightly different alignment than the current alignment. In addition, they did not limit their analysis to the Corridor line of disturbance, but extend out to 0.25 mile on either side of the centerline. As a result, the assessment includes habitat such as saltwater marsh that are not directly impacted by the present alignment of the Corridor, but are discussed in the text because they may have been impacted by the old alignment. To maintain consistency with the P&D report, the original names for the plant communities, and accompanying descriptions were retained in the biological assessment. For the EIR/EIS, the plant communities were condensed to reduce the amount of overall text. Some communities, such as saltwater marsh, are not affected by the current alignment, and therefore were not discussed in the text. Others, such as the cultural disturbance, plantation and urban cultural altered, were combined into one cate- gory. Developed areas were included in the disturbed area cate- gory, because for purposes of analysis it was not essential to analyze different types of disturbed areas separately. The graphic was prepared from the original work by P&D. Therefore, plant com- t 1 I 1 I 1 1 u 1 07/24/9O(TCA9O1A\RESPONSE.CMT) 8 1 I i I 1 I u 1 1 1 11 1 1 I 1 1 Comment No. Response munity names match.P&D text,.but not the condensed text provi-ded in the EIR/EIS. Therefore, more plant communities are mapped than are described. CAL-91 Replaced previous definition with commentor's definition.. CAL-.92 Text revised. CAL-93 No change in text per June 25, 1990, meeting. SHPO letter covers. , CAL-94 Text revised by adding the maximum annual eight hour CO levels. The 1-989 monitored air qual-ity levels have just recently been pub- lished by SCAQMD and will be added to Table 2. The 1986 data will be deleted, and discussion of data has been.mod'ified accordingly: CAL-95 The assumptions for temperature and sigma theta are listed in Ap- pendix A. They have been listed with the meteorological conditions shown on page 18. CAL-96 , Comment noted; text revised. CAL-97 The discussion. of CO levels decreasing refers to improved vehicle emissions which will benefit CO,1-evels.: Text has been revised to clarify that despite increasingly stringent automobile emission controls, CO levels still exceed the State's eight hour standard. CAL-98 Comment as'noted. Text has been revised to provide more details regarding the background CO measurements. The background CO levels were determined by Caltrans. CAL-99 Comment noted; text revised. CAL-100 Comment noted; statement added. CAL-101 Comment noted; text changed. 2.16. CAL-102 Comments incorporated into text. I07/24/9O(TCA9O1A\RESPONSE.CMT) 9 Schools do not fall under Section I Comment No. Response CAL-103 See revised checklist. Per June 25, 1990, meeting, added chapter subsection reference, not page numbers. CAL-104 Checklist item 4 has been eliminated from the geotechnical discus- sion. CAL-105 See Wetlands - Checklist item No. 13. Reference to checklist items added to Biology and Wetlands Sections (4.6 and 4.7). CAL-106 Checklist revised. CAL-107 New Chapter 5 created as discussed at June 25, 1990, meeting. CAL-108 Redone. CAL-109 Checklist has been revised. CAL-110 Item No. 21 remains unchanged. Refer to CAL-H. CAL-111 Text has been revised to include mitigation measures for slope instability ; however, a measure has not been provided for seismi- cally induced failures because the Geotechnical Report indicated that such events are not expected to impact cut and fill slopes. CAL-112 Information regarding faults and slides is provided in Section 3.2, Affected Environment. In an effort to avoid duplication, this in- formation was not repeated in Section 4.2, Impacts. Also, as dis- cussed in Section 3.2, the local faults are not readily visible from the surface and, therefore, cuts may expose faults or fault zones. Therefore, a mitigation measure is provided to avoid such areas, where feasible. CAL-113 The sentence referred to in the comment has been omitted. The issue is dealt with in the following paragraph. The intent of the sentence was not to state that seismic activity is not a concern, but rather that with appropriate mitigation (i.e., standard design practice), the maximum credible ground acceleration rates are not expected to impact cut and fill slope stability. This statement is made in the following paragraph, as well as the statement that 07/24/90MA901ARESPONSE.CMD 10 I IComment No. Response without mitigation, seismic groundshaking may also induce liquefac- tion or'settlement. CAL-114 The impacts that 'are considered potentially significant- include liquefaction, settlement, compressible soils, soil instability due to expansive soils, and cut and fill, slope instability due to existing landslides.. All can be mitigated to"a level consistent with design standards; therefore, there are no remaining signifi- cant impacts. -Text revised.to clarify this point. CAL-115 Comment noted. Text revised throughout section. CAL-116 Comment noted. Text revised. CAL-117 Comment noted. In general, the .project contains several types of geotechnical problems, but we have listed mitigation for only those problems which would not be mitigated by normal engineering prac- tice per Caltrans District direction. For example., compressible/ expansive soils, or landslides, require and will receive engineer- ing attention using design or construction measures which typically solve the problem. Seismic has been singled out for mitigation because although design and construction measures do a good job of mitigati-on, there remains a hazard -which -could (under the catastro- phic event) cause a loss of revenue for the tollroad. It is very unlikely that the other problems would have this effect. CAL-118 Comment noted. Mitigation Measure 2-1 has been revised.. CAL-119 Streambed modifications, Section 4.3 - The Floodplain. Hydraulic - Study, TM 3-22 (April 1990), has been performed based on, FIRM maps and the preliminary Corridor alignment available at that time. The floodplain impacts presented in the report were classified as Sig- nificant otherwise,, based on a qualitative assessment of the pre- liminary information and CFR guidelines. The data available does not lend itself to perform a detailed, quantitative analysis, using computer programs such as HEC-2. Detailed fl.o.od water surface computations (for the 100-year flood or the greatest flood of re- cord, whichever is higher) will be performed -by the final design engineers utilizing both the pre- and post -project conditions. 07/24/90MA901A\RESPONSE.CNT) 11 Comment No. Response CAL-120 CAL-120a Drawings (Figures 6 through 12) in the Floodplain Hydraulic Study (TM 3-22) show the extent of encroachment of the project into the floodplains. This is based on a qualitative assessment only. CAL-120b The Floodplain Hydraulic Study (TM 3-22) identifies the three floodplains as having a significant encroachment as defined by the Code of Federal regulations (CFR); i.e., encroachment into the floodplain is considered significant because of its impact on the natural/beneficial values. This is based on a qualitative analysis of the potential encroachment of the Corridor. When the exact limits of the Corridor and structure details are known, detailed hydraulic calculations will be performed to determine the extent of impact on the floodplain. This will be part of the final design phase of the Corridor. However, Table 3 in the Conceptual Drainage Report, TM 3-16 (June 1990), lists approximate velocities, water levels, and 100-year peak flows at the major drainage crossings along the Corridor. CAL-121 As stated on page 4-9, there are no modifications to the streambed at I-5 and as indicted on page 4-12, minimal (non -significant) en- croachment in the floodplain with the Demand Management Alterna- tive. No text revisions required. CAL-122 A meeting will be held with Dave Bhalla. No text revisions neces- sary. CAL-123 Text revised in Floodplain Assessment. CAL-124 Text revised. CAL-125 Streamflow data is unavailable. No revisions made. CAL-126 Comment noted. Text revised to indicate that only one build analy- sis was modeled. CAL-127 The correct CO valve is 9.5 ppm. CAL-128 Comment noted. Table has been revised. 07/24/90MA901AWSPONSE.CMD 12 I � I 1 I �i I I I IComment No. Response CAL-129 Table 4.43 values were not the most recent modeling predictions; Table 4.43 revised. CAL-130 Comments noted; the following revisions have been made; • Table 4.43 has been amended. • Sample runs of EMFAC7PC have been included in Appendix A. • The basis for toll plaza emission factors has been included in the Appendix. CAL-131 Comment noted; ma receptor has been revised. P P CAL-132 Comment noted; text revised. CAL-133 Comment noted. CAL-134 Comment noted; discussion of hot and cold starts has been added. CAL-135 Comment noted; all one hour CO levels are reported as whole num- bers. CAL-136 See response to comment CAL-129. CAL-137 Noise barriers at these locations are not recommended. because of topography that would not provide a minimum of 5 dBA noise reduc- tion and would not reduce the traffic noise to below 67 dBA. CAL-138 Checklist items 19 and 20 revised to indicate no significant impact. CAL-139 Comment notes; report title revised. CAL-140 Correction made as noted. CAL-141 Corrections made as noted. CAL-142 Receptors 42 through 47 added to Figures 11 and 4.5.1 as noted and renumbered as suggested. 07/24/90(TCA901A\RESPONSE.CMT) 13 Comment No. Response CAL-143 Last two sheets for Conventional Alternative are missing. CAL-144 Checking on stations. CAL-145 Comment noted; map replaced. CAL-146 The predicted 2010 noise levels are reported for the Conventional Alternative that would result in the highest traffic noise levels. Text revised to make this clear. CAL-147 Comment noted; report and graphics have been revised. Asterisks deleted as noted. CAL-148 Existing noise level for R11 is 64 dBA. The predicted noise levels for R11 and R15 are traffic noise from the Corridor only and do not include existing background noise levels. The predicted traffic noise has been adjusted as follows to account for the additive ef- fect of the background noise: • R11 - Leq=66 dBA • R15 - Leq=73 dBA CAL-149 The barriers at the ROW were considered and found to be more effec- tive at the edge of pavement. CAL-150 Comment noted. CAL-151 A ten foot barrier is recommended as noted. CAL-152 The mitigation section does include recommendation for soundwalls. Statement added to existing mitigation measure. CAL-153 The text has been revised per the comment. CAL-154 Comment noted. CAL-155 Revision in text made per comment. CAL-156 The statement regarding Caltrans' policy on not providing mitiga- tion to commercial land uses has been deleted. 07/24/90(TCA901A\RESPONSE.CMT) 14 i 1 I iComment No. Response CAL=157 The limitation on barrier height does not refer to Caltrans policy. j As a practical limit, noise barriers on structures would be imprac- tical above a height of six feet. The 16 foot barrier height Is a maximum limit based on achieving the Caltrans criteria of 5 dBA or more reduction. CAL-158 Comment noted. Map not continued because no other sound walls were required. CAL-159 Added text to cross-reference Section 4.18 (Construction Activi- ties) for discussion of fugitive dust and fire hazards. Discussion on p. 4-67. CAL-160 Moved text to Section 3.6. CAL-161 Changed table title. CAL-162 Moved to Section 3.6. CAL-163 Discussion of road kills has been modified to reflect the inclusion of fencing along the Caltrans right-of-way. CAL-164 Disagree with comment. Sensitive species information is important, as reflected in Caltrans' comments 166, 89 and comments from other agencies. CAL-165 Per June 25, 1990, meeting, agreed to keep in guidelines on mitiga- tion site selection for public information. CAL-166 Per June 25, 1990, meeting, Gene Foster to write letter to TIC indicating TCA's support of study on gnatcatcher. CAL-167 Explained in June 25 1990 meeting that deer would tend not to use tunnel with no natural light/visibility. No text revisions neces- sary. CAL-168 Checklist is consistent. CAL-169 Text added to address regional impacts to wetlands. I07/24/90MA901A\RESPONSE.CMT) 15 1 U 1 1 Comment No. Response I CAL-170 Footnote amended to reflect PHR acreage impacts. CAL-171 No response necessary. CAL-172 Text revised. CAL-173 TCA has initiated consultation with the Army Corps, the U.S. Fish and Wildlife Service, and the California Department of Fish and game with respect to wetlands mitigation. Although preliminary wetlands mitigation plans have been developed, no final plan has been prepared or approved by the resource agencies. (Nossaman, Guthner, Knox & Elliott) Generally, detailed wetlands mitigation plans are not developed until final project design. The basic requirements are set forth in the environmental documentation. Details that are site specif- ic, such as amount of grading required, soil amendments, etc. are not known until final site selection and project design. Similar- ly, coordination on final mitigation plan design with wildlife agencies cannot be completed until site selections has been made and necessary detail worked out. Therefore, the detailed mitiga- tion plan and USFWS agreement cannot be achieved for the Draft document. This is consistent with team discussions. (LSA) CAL-174 Same comment as CAL-168. CAL-175 Unavoidable losses of wetland are those sections of wetland habitat that will be lost due to Corridor construction. The loss is un- avoidable because no practicable alternative exists which would avoid all the wetlands. CAL-176 Refer to Biological Technical Studies document. Alternatives An- alysis discusses avoidance alternatives previously evaluated (28 route alignments evaluated in EIR No. 267). Separate section from Biological Assessment. Refer to Response to Comments FH-81 through FH-83. CAL-177 No major text revision. Minor editing completed. Due to complex land use issues, impacts need to be discussed in the context of land use setting. O7/24/90MA901A\RESPONSE.CMT) 16 1 I Comment No. Response CAL-178 Checklist has been revised. CAL-179 Map has been deleted. CAL-180 No response needed. CAL-181 Per June 25, 1990, meeting and per Caltrans District direction, a Housing and Business study was not needed for Draft EIR/EIS. CAL-182 See final chapter included in Appendix I. See response to comment CAL-181. CAL-183 Text modified. CAL-184 Checklist revised. CAL-185 Vandalism deleted per FH-24a. Mitigation measure added to address bl asti.ng. CAL-186 Text revised. CAL-187 Text revised. CAL-188 If available,, letter will be included. CAL-189 Waiting for direction from Caltrans/SHPO regarding eligibility of archaeology sites for the National Register. If they are eligible, they will be included in 4(f) section,. Caltrans to provide example of this type of discussion (if needed). CAL-190 Figure will -remain as is per TCA, June 25, 1990'. CAL-191 Comment noted, text revised. However, the first sentence has not been eliminated. It is an important introductory -statement.,'' CAL-192 Comment noted; text revised. CAL-193 Comment noted; mitigation measure revised. The location of a majority of these sites may be displaced by either alternative and I07/24/90(TCA901A\RESPONSE.CMT) 17 n Comment No. Response some of these sites have incurred leaks and improper maintenance over time. For these reasons, tabular information remains intact. CAL-194 Table changes requested have been made. However, the table has not been eliminated. Hazardous waste is not a significant issue at this time; however, that conclusion is only based on the ISA and CAL-195 may be revised after the PSI has been conducted. Comment noted. However, mitigation measures have not been elimi- nated. They are applicable considering that the PSI has not been conducted and, therefore, the full extent of hazardous waste is not known at this time. CAL-196 Confirmed by TCA. CAL-197 Second sentence relocated to end of sixth paragraph. CAL-198 Tables A and B have been deleted as well as discussion of aesthetic principles. The information in Table B has been added to the dis- cussion. The existing discussion of views from the Corridor has not been expanded, per the June 25, 1990, meeting. CAL-199 Text modified. Per June 25, 1990, meeting, mitigation measures 15- 1 to 15-8 remain unchanged. Added "some cut slopes" to Measure 15- 16; subheadings deleted in Mitigation Measures section. CAL-200 Text modified. CAL-201 Photographs are now located in Appendix J. CAL-202 Text was not modified. This comment will be incorporated into design specifications for the Corridor. CAL-203 Text modified. CAL-204 Text modified. CAL-205 See CAL-25. CAL-206 Text modified. 07/24/90MA901A\RESPONSE.CMD 18 Comment No. Response CAL-207 It is not the intention of the TCA to designate the Corridor as a State Scenic Highway. CAL-208 Figure J-5 has been added to clarify -views of the Corridor, however the June 25, 1990, per meeting, no other changes will be made. CAL-209 Text modified. Summary provided of West (North.) End Study. CAL-210 These measures are appropriate and remain in document. CAL-211 Per discussion with Leha Tran, no revisions necessary. CAL-212 Per discussion with Leha Tran, no revisions necessary.- CAL-213 Per discussion with Leha Tran, no revisions necessary.' CAL-214 Per discussion with Leha Tran, no revisions necessary. CAL-215 Per discussion with Leha Tran, no revisions necessary. CAL-216 Per discussion with Leha Tran, no revisions necessary. CAL-21 7 Per June 25, 1990, meeting, covered by SHPO letter. CAL-218 Edits made. CAL-219 Edits made. CAL-220 Will be not added, per direction at June 25, 1990, meeting. CAL-221 Attachment has been placed in the correct order. CAL-222 The existing photo does not take into consideration the effect of realignment of the I-5 due to Corridor construction. CAL-223 Content consistent with T.A. and comments received. CAL-224 Exposure of figure corrected. CAL-225 Exposure of figure corrected. 07/24/90MA901A\RESPONSE.CMD 19 - 1 Comment No. Response CAL-226 Text modified to be consistent with Chapter 2.0 - Project Description. CAL-227 Comment acknowledged. CAL-228 Text modified. CAL-229 Figure modified. CAL-230 Maps have been provided in Attachment A of Appendix A. CAL-231 No change to format of avoidance alternatives discussion per June 25, 1990, meeting. See CAL-232 for mitigation measure format. CAL-232 Text modified. CAL-233 Text modified. CAL-234 Text modified. CAL-235 King Thomas to follow up on list. Additions made to list. CAL-236 Index has been expanded. CAL-237 Text revisions made per June 25, 1990, meeting. CAL-238 Text revisions made per June 25, 1990, meeting. CAL-239 Text revisions made per June 25, 1990, meeting. CAL-240 Text revisions made per June 25, 1990, meeting. CAL-241 Text revisions made per June 25, 1990, meeting. CAL-242 Glossary has been moved to the appendix, per June 25, 1990, meet- ing. CAL-243 Title and figure number are on right hand side. Per Ed Sheldahl (at June 25, 1990, meeting), do not need to move figure titles. 07/24/90MA901A\RESPONSE.CMD 20 1 1 iComment No. Response CAL-244 Format revised as�necessary. CAL-245 To be provided under separate cover. CAL-246 Text modified where appropriate. CAL-247 Text modified throughout document. CAL-248 A separate section for significant unavoidable adverse impacts has -been prepared (Section 10.0),. MISSION VIEJO COMPANY MV-1 Provided additional clarification. MV-2 Statement added. MV-3 Graphic has been revised with recalculated acreages. MV-4 Please refer to Figure 2.10, which depicts collector/distributor roads and the diamond interchange. No further information can be shown at this scale. MV-5a Mitigation Bank - Aliso Viejo: A discussion was held with Mr. Rich Watson of the Mission Viejo Company regarding the content of the agreement for the Aliso Creek Wildlife Habitat Enhancement Project. According to Mr. Watson, the agreement provides for 50% of the mitigation acreage to be set aside for the County's use in miti- gating wetland impacts of County projects, including providing potential mitigation for the San Joaquin Hills Transportation Cor- ridor. A review of the Aliso Creek Wildlife Habitat Enhancement Project Agreement substantiated this discussion. The Mission Viejo Company has committed to providing mitigation acreage fora number of company projects, including 0.84 acres for the Corridor. The document acknowledges, however, that mitigation for the Corridor may be the primary responsibility of the County of Orange or the r Transportation Corridor Agency. 07/24/90(TCA901A\RESPONSE.CMT) 21 1 Comment No. Response With respect to the County's share of the mitigation acreage, it would appear that there is no commitment of a specific amount of acreage to the Corridor or commitment to provide acreage to any specific project. Therefore, the amount of mitigation acreage for the Corridor that has been accommodated in the Aliso Creek Plan is unknown and cannot be used to determine how much less wetland habi- tat will need to be replaced. MV-5b The wildlife habitat pond along El Toro Road is not part of the Corridor property, nor was it developed as part of the mitigation. The inclusion of this information would not add substantially to the analysis of impacts and mitigation. :01.1 FH-1 Change made per discussion at June 25, 1990, meeting. FH-2 Changes made. FH-3 Text has been revised and reorganized. FH-4a Birch Street added to the figure. FH-4b Text revised. FH-5a Text added. FH-5b Text revised. FH-5c Text added. FH-6 Requested information added to Figure 2.10. FH-7 Text changes and scaled cross section added. FH-8 Text revised. FH-9 Text edited - added reference to consistency determination. 07/24/90(TCA901A\RESPONSE.CMT) 22 t r 1 r 1 1 r� FA 1 Comment No. Response FH-10 Text revised. FH-11 Combined with Areas of Controversy; all major i-ssues listed. FH-12a Provided new table per Caltrans. Previous Table A is now in Chap- ter 4. FH-12b Effects was changed to impacts throughout document. FH-12c Text revised. FH-13 Table 1.3.A has been revised to reflect "pictures" for LOS D & E. FH-14 See response to comment CAL-57. FH-15 Revisions to text made to clarify HOV drop ramp/median relationship (see Section 2.3, HOV/Transit Median). FH-16 Wetlands definition was revised per Caltrans comment #91. Added discussion of the following species to Biological Assessment report: Ferruginous hawk Swainson's hawk Arroyo toad California red -legged frog Spotted bat Greater mastiff bat Pacific pocket mouse Braunton's milk -vetch San Fernando Valley chorizanthe Los Angeles sunflower Aphanisma Prickly poppy Dense reed grass' Viscid dudleya Heartleaved pitchersage San Diego button bush 07/24/90MA901A\RESPONSE.CMT) 23 I 1 1 Comment No. Response I FH-17 Comment noted. Per June 25, 1990, meeting direction, no additional analysis was completed. There is no additional information to report in Section 4.12 from what was presented in Section 3.11. Upon completion of the PSI, more definitive information will be available. FH-18a Table 3 in TM 3-16 contains all of the pertinent hydraulic and hydrologic information asked for here. FH-18b A complete discussion of proposed modifications in the major water- shed channel sections are given in TM 3-16, Section 3. FH-18c FIRM maps in TM 3-22 show the extent of encroachment of the Corri- dor into the floodplains. Refer to response to comment CAL-119. FH-18d TM 3-16 gives detailed discussion of these retarding basins. FH-19 Comment noted. Text in second part of comment has been added to the section. Added statement regarding TIP conformance. FH-20 It is agreed that noise levels and the frequency characteristics of stop and go traffic are different from free flow. However, when the percentage mix of vehicles is predominately autos, traffic noise levels will be higher at 55 mph than under the conditions of acceleration and deceleration at a toll plaza. FH-21 The grading impacts to the two plant species noted in the comment were related to activities by the Mission Viejo Company. These impacts were not a part of the Corridor project. The discussion of impacts to sensitive species in the EIR/EIS is confined to impacts that will result from the construction and operation of the Corri- dor. Impacts resulting from past activities, such as those on the Aliso Viejo project, are not considered part of the current project and are not identified in the EIR/EIS. As discussed in the Biological Assessment report, impacts to the San Diego horned lizard include the loss of individuals, as well as the loss of habitat. Text changed per last paragraph of comment. 07/24/90MA901AWSPONSE. CMD 24 1 1 Comment No. Response 0 FH-22 FHWA's position on replacement acreage over 1:1 is noted and will be considered as part of the mitigation. plan process. The plan process for the SJHTC will include meetings with resource agencies and will determine the required amount of replacement through dis- cussion/negotiation with those agencies. FH-23 Comment incorporated into appendix. FH-24a Text revised. Table revised by The Chambers Group. FH-24b Text revised to reflect coordination. Studies over last ten years not listed; not considered necessary information. SHPO response letter to date included in Appendix G. FH-25 Text revised according to comment. FH-26 Edits made/index expanded. FH-27 Text modified. FH-28 Text modified. FH-29 Letters and summaries incorporated into text. FH-30 It is acknowledged that where it is determined that a substantial impairment or constructive use of a Section 4(f) will occur, FHWA will have final review of the Draft before distributed for public review. FH-31 Table modified.. FH-32 Text modified. FH-33 Text modified. Notwithstanding the reservation of space for the Corridor in conjunction with identification of open space uses for the Sycamore Hills area, the "cooperative planning" argument, by itself, cannot support the exclusion of the Sycamore Hills open space from potential 4(f) status. In the factually similar situa- tion litigated in the Devil's Slide case (Sierra Club v. United States Department of Transportation (N.D. Cal. 1988)), the court 07/24/90MA901A\RESPONSE AMT) 25 Comment No. Response held that cooperative planning did not remove the designated park- land from 4(f) consideration, although the park was planned in contemplation of the highway. By including an analysis of the Sycamore Hills site in the 4(f) discussion, the EIR/EIS reduces the risk of litigation based on Devil's Slide. (Nossaman, Guthner, Knox & Elliott) FH-34 Text modified; letters received are included. FH-35 Text modified. FH-36 See CAL-230. Index map has been added in Appendix J. FH-37 Table of Contents and Index modified. FH-38 See CAL-230. FH-39 Text modified, where appropriate. FH-40 No text revision, facilities deleted as 4(f) resources. FH-41 Text revised where appropriate; some text deleted. FH-42 Text revised. FH-43 Text revised. FH-44 Text not revised. Location has been removed as 4(f) resource. FH-45 Figure B-6 deleted; Bonita Creek Park shown on Figure B-6 deleted as a 4(f) resource. FH-46 Impact to 4(f) properties has been revised based on comparison of the No Build noise level to the build noise levels to determine if the change is more than 3 dBA. FH-47 Comment noted. Table A has been revised. FH-48 Text modified. 07/24/90MA901A\RESPONSE.CMD 26 I I 1 I Comment No. Response FH-49 Numbering clarified in text. FH-50 Aliso/Wood Canyons Regional Park deleted from 4(f) due to lack of substantial impairment of viewshed and noise. FH-51 Discussion of wildlife dispersion deleted. FH-52 There is not substantial impairment due to noise impacts. However, the resource has been retained due to significant impairment of viewshed quality. Text modified regarding No Build. FH-53 Yes, Table 'C represents the impacts of the feasible alignment al- ternatives to the build alternatives. FH-54 Table D modified. FH-55 See CAL-230. FH-56 Attachment C has been retained in its entirety as discussed on June 25, 1990. FH-57 See FH-29. FH-58 Refer to specific site discussion which follows. FH-59 San Juan School deleted as a 4(f) resource. FH-60 Text modified. FH-61 Goeden Trail deleted as a 4(f) resource. FH-62 Arroyo Trabuco Trail deleted as a 4(f) resource. FH-63 Northwest Park deleted as a 4,(f) resource. FH-64 Oso Creek deleted as a 4(f) resource. FH-65 Niguel Equestrian Trail has been retained as a 4(f) resource due to substantial impairment due to noise. 07/24/90(TCA901A\RESPONSE.CMT) 2 7 1 Comment No. Response FH-66 Text modified. Substantial impairment due to noise from Corridor. FH-67 Comment acknowledged; text concurs with comment conclusion. FH-68 Aliso/Wood Canyons Regional Park has been deleted as a 4(f) re- source. FH-69 See FH-52. FH-70 Crystal Cove State Park deleted as 4(f) resource. FH-71 Pursuant to consultation with City of Irvine, Corridor will result in a substantial impairment of viewshed from Bommer Canyon Park, thus resulting in a constructive use of this resource. Bommer Canyon Park retained as 4(f), mitigation added regarding berm to reduce visual impacts. FH-72 MacArthur trail deleted as a 4(f) resource. FH-73 San Diego Creek deleted as a 4(f) resource. FH-74 Bonita Creek Park deleted as a 4(f) resource. FH-75 The Wetlands Assessment has been removed from the Draft EIR/EIS and will be included in Final EIR/EIS. FH-76 Table revised. FH-77 Table revised. FH-78 Table revised. FH-79 Partly informational. Mitigation measure added to address blast- ing. FH-80 Text has been revised as appropriate. FH-81-83 The Section 404 alternatives analysis for the Corridor relies on both the Phase I and Phase II alternatives analyses to demonstrate 07/24/90(TCA901A\RESPONSE.CMT) 28 F1 I Comment No. Response the lack of practicable alternative alignments having lesser wet- land impacts than the proposed project. The Phase I analysis, incorporated by reference in this EIR/EIS, evaluated 28 alternative route segments in four Corridor. sectors. This range of alterna- tives addressed all technically feasible alignments for the Cor- ridor meeting the project objectives: The alignment selected for further consideration in Phase II was environmentally superior to other Phase I alternatives, and was refined during Phase II to further reduce wetland impacts. Because the full range of techni- cally feasible alternatives was considered in the existing alterna- tives analysis, no single "Avoidance Alternative" was prepared for the Section 404 analysis. The Section 404 guidelines permit the use of alternatives analyses prepared under a separate planning process (40 C.F.R. 230.10(a)(5)). Section 1.0 of the EIRtEIS identifies the need for the project to include relief of existing and projected future congestion on the regional transportation network. As demonstrated by the traffic analysis summarized in the EIR/EIS, a smaller facility would be unable to serve the projected traffic demand. FH-84 Comment acknowledged. No revisions necessary at this time. CITY OF SAN JUAN CAPISTRANO SJC-1 No response needed. SJC-2 All interchanges are being designed and built to accommodate pro- jected traffic. Since the Corridor is a planned roadway facility, the Orange County Master Plan of Arterial Highways (MPAH) accommo- dates off -Corridor needs. (CDMG) SJC-3 Comment noted. Other potential mitigation measures have been in- cluded. The Roston Montessori School does qualify as an interior land use activity under the FHWA regulations. An analysis of the interior traffic noise levels at this location has been prepared. The houses along Spotted Bull Lane are categorized by FHWA as exte- rior land use activity and as such would only qualify for noise barriers as mitigation. 07/24/90MA90IAVESPONSE. CMD 29 1 Comment No. Response SJC-4 Information only. SJC-5 No text changes. Views from residential areas have been discussed, views from I-5 will not differ greatly from existing. Also, refer to Figure J-5 for illustration of general areas that will poten- tially have views of Corridor. SJC-6 All interchanges programmed are necessary. Most development along the Corridor is either under construction, or is approved and can proceed without the Corridor. The section does not conclude that the project will prematurely attract demand. Existing and Commit- ted Land Uses make up 98.5% of area. Conclusions of growth -induc- ing section do not warrant further assessment of interchanges or phasing of improvement. SJC-7 Referenced figures corrected; moved to Appendix J. SJC-8 All visual graphics have been placed in Appendix J. COUNTY OF ORANGE CO-1 A master landscape plan is currently being developed. A policy of using drought-resistent vegetation has been adopted. CO-2 Incorporated language on BMPs for water quality mitigation. CO-3 Text revised throughout the Water Quality Technical Study and in Section 4.3. CO-4 Plans for Narco Channel improvements show the Corridor embankment. The D-load of the storm drain pipes in this watershed crossing the Corridor will be checked for adequacy when the final design of the Corridor is completed. CO-5 Both TM 3-16 and TM 3-22 give 18,500 cfs as the 100-year discharge in Trabuco Creek at the crossing. 07/24/90MA9O1A\RESPONSE.CMD 30 1 I I I I �i 1 IComment No. Response CO-6 The monitored CO levels indicate that despite more stringent vehi- cle emission standards, CO levels continue to exceed the 8 hour State and federal standards. CO-7 The projections of the Growth Management Plan and OCP-88 are com- pared in the discussion of housing, population and employment con- tained in Chapter 6 of the EIR/EIS. The projections are suffi- ciently similar that the Corridor would need to include the same number of lanes to adequately serve projected traffic demand based on either demographic projection. CO-8 Text modified. CO-9 Comment noted, text has been revised by deleting the sentence. CO-10 See CAL-246. A time delay benefit analysis, although informative / Y � 9 is not a necessary analysis for the EIR/EIS and has not been in= cluded. CO-11 Source was added to Figure 1.5.1 which is now Figure 1.3.1 Sub- stantial roadway improvements over the next twenty year's are ex- pected to affect trip distributions County -wide, therefore some arterials may experience a decrease in ADT in 2010. CO-12 Though some facilities are expected to realize, minor increases in traffic with the Corridor, projected 2010 traffic on Moulton Park- way, Aliso Creek Road and Paseo de Valencia is expected to be 40% to 50% less with the Corridor than without: As shown in Table 1.53 (now Table 1.3.C), 75% of arterials show a reduction in ADT with the Corridor. CO-13 I-5 HOV connection is not a part of this project; however, the project design allows for that in the future. CO-14 Text modified. CO-15 Preparers of Traffic Technical Study concur. CO-16 The revised MPAH is being used. I07/24/9OUCA9O1A\RESPONSE.CMD 31 Comment No. Response CO-17 Labeling has been improved. CO-18 Section 4(f) analysis has been substantially revised in response to FHWA comments. CO-18a Aliso/Wood Canyons Regional Park has been deleted as a 4 f re- source in accordance with FHWA direction. CO-18b Text modified. CO- 18c Mitigation measure added to Section 4.17 Construction Impacts. However, the last sentence of proposed mitigation has been omitted, it was not felt that it was appropriate for construction section. Note: substance of this measure is covered by other measures. CO-18d Comment noted. CO-19 Informational. CO-20 Revised County's estimates and corrected Growth Section. Percent- ages have been further refined since comment was made. CITY OF LAGUNA NIGUEL LN-1 No text change. Roadways parallel to the Corridor such as Crown Valley and Golden Lantern should have fewer traffic demands with the Corridor. Perpendicular roadways may realize increased traffic demands in the immediate vicinity of the Corridor as they accommo- date local access to the Corridor. The traffic impacts of southerly Greenfield ramps on Crown Valley between Greenfield and I-5 are being investigated. (CDMG) LN-2 More traffic is expected to use local streets for these movements in Option 1. Roadway configurations assumed in the South End Study are currently being reviewed. 07/24/9O(TCA9O1A\RESPONSE.CMT) 32 I I I Comment No. Response Traffic assignments in the South End Study are currently being reviewed. LN-3 Please refer to response to comment CAL-44; see text revisions included in Chapter 2.0 (not included in Introduction); Figures have been revised. LN-4 No text change. Discussion of light rail has been revised. LN-5 Text unchanged. This section has been prepared per Caltrans' di- rection regarding specificity. L'N-6 This is EIR/EIS format. LN-7 Consistent with Caltrans/FHWA direction. LN4 Assessment of the Corridor's impacts on the City of Mission Viejo r is provided in the EIR/EIS. LN-9 . Format is per Caltrans/FHWA. LN-10 This issue is not within the scope 'of the environmental document and will be addressed separately by the TCA. LN-lla Objectives do not list specific development areas other than UC Irvine. LN-11b Text revised; see Section 11.2. LN-11c No additional assessment is needed, The analysis provided illus- trates the magnitude of visual impact in this area. Also, see Figure J-5 for illustration of that general areas will potentially have views.of Corridor. LN-12 No text change. LN-13 No text change. LN-14 Text revised. 07/24/90MA901A\RESPONSE.CMD 33 Comment No. Response LN-15 Figures have not been revised. Due to differences in information being presented, cannot be shown at same scale. Text modified in Demand Management Alternative discussion to reflect both possible I-5 connections. LN-16 Refer to Chapter 5, Traffic and Circulation. LN-17 See revisions to Section 2.11, Park and Ride and Chapter 5, Circu- lation "Park and Ride" section. LN-18 No response necessary. LN-19 I-5 direct connection is not part of this project. LN-20 Text not modified. Figures 2.11 and 2.12 modified. LN-21 Text has not been modified. LN-22 Text modified. Light rail is not a part of this project. LN-23 An interchange at Crown Valley Parkway would be too close to I-5 to maintain mainline operations. Frontage roads along Greenfield Drive are unwarranted. LN-24 Text not modified. Future multimodal use is provided for in design and discussed in text. LN-25 Text has been revised to be consistent with graphic. LN-26 Comment noted. Measurement sites have been depicted on Fig- ure 3.5.1. LN-27 The land uses at these receptors are discussed in Section 4.5 of the EIR/EIS. LN-28 Figure 3.7.1 revised to include residential uses east of the Corri- dor, in the City of Mission Viejo. LN-29 Text additions on Mission Viejo/I-5 commercial Corridor. 07/24/90(TCA901A\RESPONSE.CMT) 34 I � 1 IComment No. Response LN-30 Table 3.73 deleted. LN-31 Text revised. Window will accommodate either alternative. LN-32 No change. Section per Caltrans/FHWA. LN-33 Text added. LN-34 Text added. LN-35 Fig 3.12.1 has been modified to add names to trails;, impacts are identifiable based on Corridor -base on graphic; impacts discussed in Section 4.13. LN-36 Printing problem; will be fixed. LN-37 No change needed in document. Informational comment. LN-38 Streambed modification is shown. Realignment is the "after" condi- tion. Figures 4.3.1 and 4.3.2 have been revised -to clarify re- aligned condition. LN-39 For purposes of this EIR/EIS, the facility is considered a part of the project, and the location is a potential location, not a final location. LN-40 Text edited. Will, confirm with CDMG that facilities in Mission Viejo and Laguna Niguel would be affected by Corridor. LN-41 The TCA will coordinate with affected cities as part of the mitig,a- tion monitoring program for the Corridor. LN-42 Items 1, 2, and 3 at pages 4-39/40 describe the infeasibility of HOV implementation during the first stage of the project. Traffic demand during the initial years of theproject is estimated to be too low to provide congestion incentives for HOV use, but too high to allow reduction in the initial number of general purpose lanes. Lacking sufficient HOV demand, the HOV lanes would not provide sufficient toll revenue to support the construction costs. The text has been revised. 07/24/90(TCA901A\RESPONSE.CMT) 35 Comment No. Response LN-43 Figure 4.5.1 revised. LN-44 The recommendation of a noise barrier and the design of its height and location are intended to mitigate (reduce) the traffic noise by more than 5 dBA to below the FHWA criteria of 67 dBA. Text has been added in Visual Analysis section that addresses visual impacts of noise barriers within subareas along the Corridor alignment. The visual impacts of individual barriers will be addressed, as necessary, during Preliminary Engineering/FEIS when the design of the barrier, selection of construction materials and location are completed. LN-45 Fig. 4.7.1 shows only potential mitigation site for Oso Creek wet- lands impacts. Descriptions of the proposed mitigation sites will be included in the draft mitigation plan to be prepared prior to project construction. The mitigation sites figure has been taken out per Caltrans. LN-46 Text edited to include local agencies. Coordination with local agencies will occur through the mitigation monitoring program. LN-47 Refer to LN-45. The ongoing mitigation plan process for the SJHTC will determine the appropriate amount and locations of replacement acreage for wetlands impacts per the approval of the resource agen- cies. LN-48 LN-49 LN-50 LN-51 Conflicting policies removed from text. No response needed. Not an issue for environmental document. TCA to address in differ- ent context. 1 5 I I � I � �1 Table has been revised with correct jurisdictions. Note: table moved to Appendix I. I LN-52 Comment noted; however, the relocation opportunities will be ad- dressed by Caltrans at a future time. Gobar study not part of this EIR/EIS. 07/24/90(TCA901A\RESPONSE.CMT) 36 I 1 I I t Comment No. Response LN-53 The Impacts section only mentions specific trails in Jamboree/ MacArthur area due to the complexity of connection with existing and future trails in that area. LN-54 Grading exhibit available for review at TCA. Also please refer to TIC-18 for explanation. LN-55 Figure J-5 has been added to clarify visual impacts of the Corridor. LN-56 No additional text 'has been added., Figure J-5 in Appendix J ade- quately illustrates the Corridor's visual impacts in the vicinity of Greenfield Drive/Crown Valley Parkway .which is not significantly different from the discussion regarding Crown Valley Parkway. LN-57 Text modified. LN-58 Toll revenue not an environmental issue. Toll sensitivity analysis briefly described in Chapter S. LN-59 Not related project. LN-60 Printing problem; corrected. LN-61 Text modified to include discussion and appropriate mitigation measures. LN-62 Area of benefit is determined by the TCA. LN-63 This type of analysis is outside the scope of this EIR/EIS. LN-64 Tables and Figure revised; a good faith effort was made to update the list of cumulative projects. However, all of Mission Viejo and portions of Laguna Niguel were omitted because the information was received late or was not in the requested format. LN-65 Specification of location of business takes is inconsistent with, the general wording format of this section; refer to Section 4.9. LN-66 Text added. 07./24/90MA901A\RESPONSE.CHT) 37 I � Ii Comment No. Response LN-67 Text added. .■ LN-68 No change. Facility deleted from Section 4(f). Impacts to facility discussed in other sections of EIR/EIS. LN-69 No specific changes requested. LN-70 See FH-29. LN-71 TCA to work with John Anderson regarding trail location. LN-72 The Rancho Viejo Road Bike Trail and Oso Creek Corridor are separate independent facilities which serve different recreational demands. The Rancho Viejo trail is intended to serve demand easterly of I-5 while the Oso Creek Corridor lies westerly of I-5. It is not a reasonable solution to move the trail to the west side of I-5 and expect it to serve the residential uses easterly of I-5. Perhaps the Rancho Viejo Road could ultimately be aligned easterly along Trabuco Creek and still serve the residents, but clearly this is beyond the scope of the Corridor since the creek is not improved. LN-73 Tables revised to include Country Village and Colinas de Capistrano and others. LN-74 No change in text because Mission Viejo across freeway from the Corridor is currently built out. LN-75 Text revised to state that this will be done through Development Agreements already entered into between the County and developers. LN-76 Per team direction, will not go into further detail. LN-77 Text deleted. LN-78 Several issues covered by technical report, other changes per com- ments made by others. LN-79 Corrections made as noted. No comment regarding AMTRAK not part of project. 07/24/90(TCA901A\RESPONSE.CMT) 38 IComment No. Response LN-80 No comment regarding AMTRAK; not part of project. LN-81 The regional and microscale air quality analyses includes the HOV lanes at Avery Parkway. LN-82 The DTIM was modeled for the Conventional Alternative only. The Demand Management includes HOV lanes which cannot be assessed by the DTIM model. Comparison between Conventional and Demand Manage- ment alternatives was based on differences in average vehicle speed and ADT's. LN-83 Not an issue for this EIR/EIS. LN-84 Assessments for each project cover that project and any related projects to extent needed for CEQA/NEPA and to extent other project is known. LN-85 Informational. LN-86 The park and ride lot mentioned is located on Greenfield Drive adjacent to Crown Valley Parkway and has been referenced as the Crown Valley Parkway lot. Either name may be used interchangeably to reference the lot. LN-87 Beneficial uses of Oso Creek in Corridor area have been clarified. LN-88 Related facilities have been addressed to the extent they are known at this time. LN-89 The classification system shown on pages. 13-14 was used by the US Fish and Wildlife Service to designate the relative importance of various habitat types and the goals for preservatilon and/or re- placement. It was intended as information and as a basis for de- termining the level of significance and mitigation for habitats impacted by the Corridor. It was not felt necessary to repeat this information. The classifications provided on page 36 are the same as those used on pages 38 & 39. These classifications are repeated as appropri- I07/24/90(TCA901A\RESPONSE.CNT) 39 Comment No. Response ate in the text on pages 37, 48, 49, & 50. It was not felt neces- sary to repeat the information in the graphics and remaining text. LN-90 Refer to Response to Comment LN-47. LN-91 The Oso Creek forested wetland is included under the discussion of water resources/wetlands. The discussion of significant wood- land/habitats on page 68 addresses upland vegetation. As a wet- land, the habitat in Oso Creek is considered to be significant and would require mitigation. LN-92 The description provided on pages 3-4 of the appendix to the tech- nical report is sufficiently detailed to define the habitat charac- teristics. As stated above, all wetland habitats are considered to be significant. LN-93 No response needed. LN-94 Available for review at TCA; copies cannot be provided to all at reasonable cost. LN-95 The resultant contours with the noise barriers are not required by FHWA. See comments LN-44 and LN-57 regarding visual impacts. In all cases, the approval of the local community is required by FHWA before a noise barrier is constructed. LN-96 No response necessary. LN-97 I-5 connection alternatives addressed in Chapter 2. LN-98 Both Conservative and Optimistic HOV splits are provided for the Demand Management Alternative in the Traffic and Circulation Tech- nical Study. Cost/benefit discussion not appropriate for EIR/EIS. LN-99 Estimates of bus traffic on the SJHTC are too small to present in this table (e.g., 60 buses per day in 2010). LN-100 All HOV vehicles will not use HOV lanes. 07/24/90 MA901AVESPONSE. CK) 40 1 Comment No. Response LN-101 Some congestion may occur with the Demand Management Alternative if ' Optimistic HOV splits are not realized. LN-102 See LN-98. LN 103 Greenfield is not expected to serve large volumes of traffic. LN-104 Refer to South End Technical Study, Austin -Foust Associates. LN-105 Figure S.1 has been revised in EIR/EIS to include requested"infor- mation. Refer to FH-6. LN-106 The Avery Parkway Extension and the Corridor were found to have,no impact on each other. LN-107 Refer to LN-92 and CAL-44. Avery ramps to the Corridor in Option 2 would be general purpose ramps. LN-108 South End Technical Study is currently being revised. LN-109 See LN-108. LN-110 See LN-108. LN-111 See LN-108. CITY OF SANTA ANA SA -la Text revised under "Mass Transit." SA -lb Text modified. City's support of the project is acknowledged. SA-2 Per Caltrans/TCA, this section will not be expanded. BILL OLSON BO-1 Text is consistent with Caltrans'direction. Need Caltrans' concur- rence regarding 4(f). 07/24/90MA901A\RESPONSE.CK) 41 Comment No. Response BO-2 The noise methodologies for both the ETC and SJHTC are both consis- tent with Caltrans' policy. BO-3 See LN-57. BO-4 Contour grading will be implemented at the appropriate locations and soil conditions. This will be determined during final design. BO-5 TCA is lead agency. TCA will coordinate with County; however, they will not submit for approval. BO-6 No response needed. BO-7 No response necessary; conclusionary statement of previously iden- tified issues. THE IRVINE COMPANY TIC -la Text modified. TIC -lb The objectives were not expanded to include RMP; not a good fit with structure of section. However, RMP text added to chapter in Section 1.3 (Background and Authority for proposed project). TIC -lc Text modified regarding recreational and UCI objectives as well as Coastal Act consistences and objectives. TIC-2a RBF alignment study referenced in Section 4.15, Visual Resources. TIC-2b Text not modified. Discussion of planning history is located in various places in the document. TIC-3 No text revision. Jamboree Flyover versus alternatives will con- tinue to be explored in preliminary design. MacArthur realignment is being coordinated with plans for MacArthur widening by Newport Beach. 07/24/90(TCA901A\RESPONSE.CNT) 42 IComment No. Response Pelican Hill Road impacts are being addressed in the affected sec- tions through traffic control plans in preliminary design. Laguna Canyon Road improvements are being incorporated with Cal - trans. TIC-4 See response to comment CAL-44. 'Text modified. TIC-5 Text edited. Requested information is part of ongoing study. TIC-6 Discussion of related transportation projects added. TIC-7 Additional sites have been identified for those areas noted in the comment. Analyses of these sites has been included in the LIR/EIS. -TIC- 8 The SJHTC mainline, collector -distributor roads and ramps will be coordi-nated with Caltrans' plans for Laguna Canyon improvements and will be sensitive to flood prone areas. (CDMG) TIC-9 Wetland sites - (per JLH 6/5/90 meeting) added paragraph on general identification of potential sites; public open space areas and parks which may be available for wetland mitigation; [deleted Figure 4.7.6] Wetlands sites which are objectionable to TIC have been removed on graphics. TIC-10 Wildlife crossings will be coordinated with all property owners upon consensus between TCA/Fish and Game/LSA. TIC-11 Text has been revised to reflect RFP for Ford Road EIR. TIC-12 See LN-55. No additional analysis provided. Graphics in final printing will be better. TIC-13 OCTAM II was not approved for use in this study and is still' being refined. Consequently, providing a detail analysis of OCTAM II in the EIR/EIS is not required and would be confusing to the reader. The TCA has prepared an analysis entitled "OCTAM I -I Traffic Fore - I07/24/90(TCA901A\RESPONSE.CMT) 43 1 I Comment No. Response I cast Sensitivity Analysis" which compares lane requirements and air quality and noise levels, and which is summarized in the EIR/EIS. TIC-14 No change to document. Due to reduction of west (north) end text, no appropriate location for statement. TIC-15 To be provided by CDMG. TIC-16 See SJC-6. TIC-17 Text modified. I TIC-18a The grading limits for this project have been established. How- ever, maps which illustrate this line have not been included in the DEIR/EIS. To include such maps in the document, illustrating grad- ' ing limits would be too cumbersome for the document. Rather the grading limits are available for review at either TCA or Caltrans. Also, the construction impacts section of the document does provide an estimate of excess material of 4.25 million cubic yards. Note: per Gene Foster, TCA, exhibit being prepared for EIR/EIS. TIC-18b A discussion of potential disposal sites is provided in the con- struction impacts section. However, it should be noted that spe- cific disposal sites have not been identified at this time. TIC-18c Park and Ride lots are not dealt with separately from a grading standpoint but rather are included within the overall grading plans. TIC-18d Blasting/ripping and erosion are addressed in the Construction Impacts Section (4.17) of the DEIR/EIS. TIC 19 Requested information would be informative; however, is not crucial for adequacy of analysis. TIC-20a Per direction from the June 25, 1990 meeting, the discussion has not been expanded. TIC-20b The analysis for each visual resource adequately describes the effect of the mitigation measures. 07/24/90MA901AVESPONSE.CMD 44 D I IComment No. Response TIC-20c The text does differentiate between public and private views through discussion and graphics. The difference is not explicitly identified but is inferred such that the reader will understand the difference. TIC-20d Our analysis has determined that there are .no areas that the.al'ter- native cross sections generate significantly different visual im- pacts. Please refer to discussion in Section.4.15. TIC-20e See 20c. In accordance with Caltrans' guidance, the document fo- cuses on significantly impacted areas only. Also refer to Secti-on 4(f) Appendix A for a discussion of significant impacts on publicly owned recreational resources. TIC-20f The County of Orange currently has not determined a defin.itive route for this trail in the vicinity of the Corridor. Without a definitive location of the trail, the visual impacts of the Corri- dor on the trail cannot be analyzed. TIC-20g See TIC-20c. It should be noted that wherever the Corridor travels through the hills, the visual impact is considered significant. Note: Figure J-5 added showing areas with views of the Corridor. TIC-20h The discussion analyzes the proposed project, the variation suggested is not under consideration at this time. However, the scenario is the worst case and the variation suggested would probably have less impacts than the configuration under consider- ation. Also, the Figure does conceptually illustrate a longer bridge span. This .bridge span is longer than in previous environ- mental documentation to address previous concerns regarding hydrology and fills within the Canyon. TIC-21a Text added regardi,ng regional open space preservation. TIC-21b Sub -area habitat impacts are discussed- in terms of specific wetland (drainage) areas affected by the Corridor. TIC-22 Text has been revised to include "worst .case." Note:, park and ride lot information moved to one place. 07/24/90MA901A\RESPONSE.CMD 45 1 Comment No. Response In -text Comments (The Irvine Company) Page 18 The ICDA will not be taken or substantially impaired by the Corri- dor due to its distance from the Corridor and intervening topogra- phy and vegetation. Page 22 Text modified. Page 30 Text modified. Table A Text modified. 4-166 Text revised. CITY OF IRVINE IRV-la Change not made. Format is consistent with FHWA. IRV-2a Figures reflect standard orientation. IRV-3a Added to Table A. IRV-4a No changes requested. IRV-5a Approach consistent with Caltrans /FHWA direction. IRV-6a Toll operation is discussed in Chapter 5, Traffic and Circulation. IRV-7a Limit of work is not Birch ramp connectors; rather, partial improvements all the way to I-405. IRV-1 Comparison of volumes is in Figure 1.3.1. IRV-2 Not added per Caltrans direction not to duplicate text. IRV-3 Requested information does not add significantly to document. IRV-4 Inconsistent with Caltrans/FHWA direction. However, the requested information is discussed in several locations in the EIR/EIS. 07/24/9O(TCA901A\RESPONSE.CMT) 46 F IComment No. Response 1 u 1 IRV-5 Text provides requested information. IRV-6 Change not made. 1RV-7 Table changed/moved per other comments. IRV-8 To be provided at a later date; does.not yet reflect information in this EIR/EIS. IRV-9 Text modified, see Section 1.3, Roadway Capacity Deficiencies. IRV-10 Only selected links are summarized in Tables. 1.5.A and 1.53 (now 1.3.8 and 1.3.C). Differences,in volume estimates on SR-1 are due to network access not shown on Figure 1.5.1. IRV-11 Table 1.5.A (now 1.3.8) revised. IRV-12 I-5 widenings'as well as all other -programmed improvements in the County are considered in all analyses. IRV-1.3 The text has not been modified; however, the comment will be incor- porated into the TCA design specifications for the Corridor. IRV-14a Reference to AVI'speed is meant to include -mainline and toll plazas where the sight distance may dictate a speed limit less than main- line speeds. IRV-14b Heavy vehicle traffic was considered in all analyses. IRV-15 Statement is true. Cal trans has not expressed.interest in partici- pating in these lots. Text revised regarding median widths: Also, see CAL-50. IRV-16 HOV lanes are part of the Operations Plan for the Corridor. TMS and TSM are mitigation measures (refer'to Chapter 5.0). IRV-17 Text revised. IRV-18 See response to comment IRV-17. 07/24/90(TCA901A\RESPONSE.CMT) 47 Comment No. Response IRV-19 Text revised. IRV-20a Text revised. IRV-20b Text revised. IRV-21 Turtle Rock and UCI Housing will not be impacted by traffic noise from the Corridor. IRV-22 City trails have been added to text. Sand Canyon Avenue is men- tioned in the third paragraph as a future arterial which will be crossed by the Corridor. IRV-23 Comment noted. The Air Quality Section has been reformatted and the Technical Study will be available for review. IRV-24 A wildlife undercrossing in the Shady/Emerald Canyon area is pro- posed with the current SJHTC. Design does not provide usage for trail users due to the priority of designing the most effective crossing for mammals across the project alignment. IRV-25 Mitigation added. IRV-26 The discussion of the mainline toll facility has been modified to include a discussion of its impact on Turtle Rock. IRV-27 Revised text added; see TIC-13. IRV-28 Figure 5.2 presents toll operation ADT estimates (that require updating with current information), and Figure 1.3.1 presents toll free ADTs. IRV-29 Text revised per traffic Technical Study. IRV-30 Text revised per Traffic Technical Study. IRV-31 Text revised per Traffic Technical Study. IRV-32 Corridor toll free ADT estimates are higher than toll ADT esti- mates. Since more traffic will load onto MacArthur, toll free ADT 07/24/90MA901A\RESPONSE.CNT) 48 1 �J Comment No. Response estimates for MacArthur Boulevard are also higher.. Note that de- sign is based on peak hour estimates expected to be of similar magnitude for both toll and toll free operation. Refer to TIC-17 above. IRV- 33 Comment noted. The Summary has been revised to reflect new analy- sis presented in the Technical Studies. IRV-34 Reference to Figure 2.13 added. IRV-35 The visual analysis discusses the worst case impacts at Bommer Canyon, which is adequately depicted in Appendix J. The Corridor's relationship to habitat areas, open space and bicycle/equestrian trails in the vicinity of Bommer Canyon -are discussed in Sections 4.6, 4.8 and 4.13, respectively. IRV-36 Expansion of discussion in EIR text would be contrary to Caltrans' ' direction. All design options are discussed in Wildlife Crossing Tech. Memo in Technical Studies Document No. 5. IRV-36b Alternative "R" as examined in DEIR No. 494 'has been incorporated into the currently proposed project for both the Conventional and Demand Management Alternatives. IRV-37 Checklist Item No. 11 refers to water quality and quantity of sur- face water. The EIR/EIS states (p.4-22) that water quality impacts would be reduced to below a level of significance with successful ' implementation of the mitigation Runoff Management Plan (RMP). The EIR/EIS states that certain streambeds/water courses would be significantly affected due to required realignments and/or place- ment of fill. No significant unavoidable adverse impacts were identified for quantity of water. IRV-38a The proposed buffer area designated by the City of Irvine will be impacted by the Corridor. The buffer area is a City of Irvine designation and is not a wildlife habitat as such, although it contains wildlife habitat. Therefore, impacts to the buffer zone are not specifically included in the biologica-1 section, although impacts to the habitats in the buffer area are identified and miti- 07/24/90MA901A\RESPONSE.CMD 49 1 1 Comment No. Response gation provided. With regard to analysis requested is provided i No. 267 which is incorporated by j n wetlands impacts, the alternative ' summary on page 4-80 and in EIR reference. IRV-38b The Phase II alternatives discussed in the Draft EIR No. 494 have subsequently been modified. Alternatives R and U are no longer discussed as separate alignments. Alternative R has been incorpor- ated into the currently proposed alignment for analysis in the EIR/EIS. IRV-39 A discussion of the impacts to wildlife habitat is included on page 4-64. In addition, impacts of habitat loss for sensitive wildlife species are identified under the Sensitive Wildlife Species head- ing. The cumulative effects of these losses are described under the Loss and Fragmentation of Wildlife Habitat with respect to relocation and crowding. Species compatibility cannot be assessed except in the general terms of predator/prey relationships and agonistic encounters. The text has been modified to include this in the analysis. IRV-40 Revised text to reflect partial undergrounding of channel. IRV-41 Requested change would be inconsistent with Caltrans/FHWA format. IRV-42 On page 4-68, the negative impact on nocturnal species is identi- fied. Impacts to diurnal species are not considered significant because most wildlife will probably avoid the road during the day, and light and glare are generally not operative during the day. The text incorrectly state that the level of impact is not consid- ered to be significant. The text has been changed accordingly. The available information on light and glare effects on wildlife is virtually nonexistent. Only anecdotal evidence and untested hy- potheses are available regarding wildlife reactions to nighttime lighting. IRV-43 Checklist item has been changed. IRV-44 Edits made. 07/24/90(TCA901A\RESPONSE.CMT) 50 1 1 1 1 1 I 1 11 Comment No. Response IRV-45 Edits made. IRV-lb The introductions are different in the way the text has been para- graphed. The information is consistent with the air quality re- port. IRV-2b The technical report is prepared -for reviewers with sufficient knowledge of noise to understand the fundamentals of different noise descriptors. IRV-3b The noise prediction sites are the same as the noise sensitive receptors. Receptors are selected where existing noise sensitive land uses or future planned uses are located.. At these sites, future traffic noise levels are predicted. IRV- 4b Comment noted. I IRV-5b Comment noted. Analysis of an additional noise receptor site in Irvine has been added. IRV-6b Aircraft noise from John Wayne Airport effects sites R45, R46, and R47 (see Figure 6). The aircraft noise levels were added to the traffic noise at these sites. IRV-7b An increase of 5 dB or more is considered noticeable, 3 dB is con- sidered perceptible hence the characterization of 3.8. dB as barely noticeable. IRV-8b The recommendations are consistent with the stated height limita- tions. IRV-9b Comment noted.. IRV-lc Traffic movements through toll plazas will result in worst case CO levels due to reduced vehicle speeds and queuing at the toll gates. IRV-2c The measured CO levels are background concentrations that are not due to a particular source or roadway. these values are added to ' the CO concentrations of a roadway to determine compliance with I07/24/90MA901A\RESPONSE.CMD 51 I Comment No. Response state and federal standards. Background levels are not usually compared with State and federal standards. IRV-3c The map is current. IRV-4c The discussion on RMP and GMP consistency can be found in the Growth Inducement Section of the document. RMP consistency is also discussed in Chapter 1, Purpose and Need. IRV-5c The other 88 percent are considered not stable vehicle that have been in operation for more than 505 second or 3.59 miles. IRV-6c The additional map (Figure 5) showing the Park and Ride locations is not required but is helpful to the reader. IRV-7c There are no violations of the State or federal CO standards, therefore, mitigation would be normal dust control procedures which is stated in the Construction Impacts Section. IRV-ld Refer to LN-47. IRV-2d The TCA will coordinate with local agencies as part of the mitiga- tion monitoring program. Responses to The Irvine Company's Comments on Biology Assessment Section The following points are acknowledged regarding open space dedication areas and their relation to each other, to development projects, and to overall mitigation for development projects. • The assemblage of large blocks of open space (exclusive of active use parks, golf courses, landscaped greenbelts between develop- ments, etc.) avoids for the most part the fragmentation of plant communities and wildlife habitat that results from piecemeal plan- ning and attendant mitigation. • The practice of dedication in trade for development opportunity is, under certain circumstances and carefully defined conditions, an acceptable form of mitigation. 07/24/90 MA901AVESPONSE.CMD 52 1 I � 7--1 I� I. 1 IComment No. Response The following points are made regarding the open space dedication areas and their relation to the Corridor. • The assemblage of large blocks of open space areas was done as mitigation for the adjacent or surrounding development projects. None of the dedication agreements specifically identify the Corridor as part of the mitigation agreement for the open space dedication, nor is there provision for acreage amounts as mitiga- tion for the Corridor. ' The proximity of the Corridor to large open space areas, and the relationship of these open space areas with each other, will - be taken into consideration in the evaluation of impacts of the Corri- dor. The cumulative impacts of the Corridor and the approved de- velopment associated with the open space dedication areas will also be taken into consideration in the analysis of impacts. • Despite the existence of adjacent open space areas, there will be a net loss of habitat and a decrease in wildlife populations as a result of the construction and operation of the Corridor. This net loss of habitat and wildlife is l'arg.e and is regionally signifi- cant. In regards to the other items: • The division of impacts by subarea i's in, conflict with previous Cal -trans' directions. CITY OF COSTA MESA CM-1. Additional information is being provided (see response to comment CM-2). Traffic on existing SR-73 would increase 45,000 to 55,000 vehicles per day. CM-2 Figure 1.5.1 has been revised to provide information on SR-73 and I-405 north of SJHTC, and analysis included i-n the text.. Previous ' studies ind-icate.no change in volumes on 1-405 north of SR-73. The SR-73/I-405 interchange may need modifications based on traffic flow. 07/24/9O(TCA9OIA\RESPONSE.CMT) 53 1 Comment No. Response CM-3 Text revised. Was reference to S-1; now figure is moved. CM-4 Table 2.8.A has been revised based on information shown in revised Figure 1.5.1. CM-5 TCA has committed to funding, and the TCA Board has passed a resol- ution to this effect. CM-6 See response to comment CM-2. Figure 1.5.1 has been revised. CM-7 See response to comment CM-2. CM-8 See response to comment CM-2. CM-9 See response to comment CM-2. North of the I-405/SR-73 inter- change, there is no difference in volumes on I-405 with or without the Corridor. CM-11 The Traffic and Circulation Study TM 2-60 is being revised to pro- vide the additional information discussed in response to comment CM-2. GAIL SHIOMOTO LOHRIBILL OLSON 1 Revised text to include reference to transportation improvements are assumed with No Build Alternative. 2 Details of improvements are included in Traffic Technical Study. 3 Text not modified. 4 Text not changed; Gail Shiomoto Lohr to coordinate with OCTD. 5 See 4 above. 6a Existing text is consistent with comment. 6b Traffic Technical Study addresses this issue. 07/24/9OMA9OIA\RESPONSE.CMD 54 1 1 1 1 1 1 1 1 i 1 1 1 1 1 1 1 1 1 1 Comment No. Response 6c Text on future transit revised. See response to comments CAL-59 and CAL-60. 7 Existing text covers HOV demand; no information available on AVR for No Project. 8 Text revised to reflect RMP treatment of transit. 9 Addressed in Traffic Technical Study. 10 This point is made in various discussions in the EIR/EIS. 11 Crosschecking is completed. 12 See Traffic Technical Study. Modifications made to clarify status of forecasts. 13 Made minor revisions to text to clarify this issue. 14 Format changed into a table; numbers clarified. 07/24/9O(TCA9OIA\RESPONSE.CMT) 55 �I February 20, 1991 TRANSPORTATION CORRIDOR AGENCIES Re: Response to Comments Document for Environmental Impact Report/Environmental ImImpact Statement TCA EIR EIS 1 for the San P / William Woollen, Jr., Executive Director Joaquin Hills Transportation Corridor Dear TCA EIR/EIS 1 Commentator: Foothill/Eastern Corridor Agency Enclosed is a new set of cover pages for the San Chairman: Joaquin Hills Transportation Corridor SJHTC P (SJHTC) Oaddi Vasquez Environmental Impact Report (TCA EIR 1) Response to Supervisor, 3rd District Comments Documents ,you recently received. These replacements for the covers that new covers are re P Members: Anaheim were on the documents when you received them. Irvine Mission Viejo The reason for relacin the covers is to clarify g y Orange San Clemente that the Response to Comments Documents you San Juan Capistrano recently received pertain only to the California Santa Ana Environmental QualityCEQA clearance for the Act ( ) Tustin Yorba Linda SJHTC project. The public hearing to consider the County of Orange EIR for certification (CEQA portion of the environmental process) is scheduled for March 14, 1991. San Joaquin Hills Corridor Agency The Environmental Impact Statement (EIS) portion of Chairman: the SJHTC environmental document was prepared to John Cox satisfy the requirements of the National Newport Beach Environmental Policy Act (NEPA) . A Final EIS will Members: be prepared in cooperation with the Federal Highway Costa Mesa Administration (FHWA) and the. California Department Dana Point of Transportation CALTRANS . � ) IrvineP Laguna Niguel Mission Viejo If you have questions regarding the SJHTC EIR Newport Beach ResResponse to Comments Documents or regarding the P g g San Clemente San Juan Capistrano substance of this letter, please contact King Santa Ana Thomas of my staff at (714) 557-3298 extension 530. County of Orange Thank you for your attention to this matter. oVetru rs, RECEIVEu d'Y PLANNING DEPARTMENT CITY OF NEWPORT BEACH rly5 1991 Environmental Impact AM FEB 2 PSI 718191101ut1211121314A 6 345 Clinton Street, Costa Mesa, CA 92626 7141557-3298 FAX 7141557-9104 a SCH. M0: 9001 0230 12-ORA-73 P.M. 0-15 E.A. 102540 PROPOSED CONSTRUCTION OF STATE ROUTE 73 EXTENSION BETWEEN INTERSTATE ROUTE 5 IN THE CITY OF SAN JUAN CAPISTRANO AND JAMBOREE ROAD IN THE CITY OF NEWPORT BEACH KNOWN AS THE'SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR AND I-5 WIDENING BETWEEN SR-74 ORTEGA HIGHWAY AND THE CORRIDOR AND RAMP IMPROVEMENTS BETWEEN JAMEOREE-ROM-AND BIRCH STREET ON EXISTING STATE ROUTE 73 LOCATED IN ORANGE COUNTY, CALIFORNIA FINAL ENVIRONMENTAL IMPACT REPORT/TCA EIR 1 VOLUME II - COMMENTS RECEIVED'ON THE DRAFT EIR/EIS (1-1 TO 4-21) SUBMITTED PURSUANT TO: (State) Division 13, Public Resources Code BY THE San Joaquin Hills Transportation Corridor Agency Orange County, California The following persons may be contacted for additional information concerning this document: Steve Letterly San Joaquin H.i'lls Transportation Corridor Agency 345 Clinton Street Costa Mesa, CA 92626 (714) 557-3298 x297 -SCH. N0. 9001 0230 12=0RA-73 P.M. 0-15 E.A. 102540 PROPOSED CONSTRUCTION OF STATE ROUTE 73 EXTENSION BETWEEN INTERSTATE ROUTE 5 IN THE CITY OF SAN JUAN CAPISTRANO AND JAMBOREE ROAD IN THE CITY OF NEWPORT BEACH KNOWN AS THE SAN JOAQUIN'HILLS TRANSPORTATION CORRIDOR AND I-5 WIDENING BETWEEN SR-74 ORTEGA HIGHWAY AND THE CORRIDOR AND `:AMP IMPROVEMENTS BETWEEN JAMBOREE ROAD AHD SIRCH'STREET ON EXISTING. STATE ROUTE 73 '. ' LOCATED IN ORANGE COUNTY, CALIFORNIA FINAL ENVIRONMENTAL IMPACT REPORT/TCA EIR 1 VOLUME II - COMMENTS RECEIVED ON THE DRAFT EIR/EIS (4-22 TO 8-36) SUBMITTED PURSUANT TO: (State) Division 13, Public Resources Code BY THE San Joaquin Hills Transportation Corridor -Agency Orange County, California The following persons may be contacted for additional information concerning this document: Steve Letterly San Joaquin Hills Transportation Corridor Agency 345 Clinton Street Costa Mesa, CA 92626 (714) 557-3298 x297 SCH. N0. 9001 0230 12-ORA-73 P.M. 0-15 E.A. 102540 PROPOSED CONSTRUCTION OF STATE ROUTE 73 EXTENSION BETWEEN INTERSTATE ROUTE 5 IN THE CITY OF SAN JUAN CAPISTRANO AND JAMBOREE ROAD IN THE CITY OF NEWPORT BEACH KNOWN AS THE SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR AND I-5 WIDENING BETWEEN SR-74 ORTEGA HIGHWAY AND THE CORRIDOR AND RAMP IMPROVEMENTS BETWEEN JAMBOREE ROAD AND BIRCH STREET ON EXISTING STATE ROUTE 73 LOCATED IN ORANGE COUNTY, CALIFORNIA FINAL ENVIRONMENTAL IMPACT REPORT/TCA EIR 1 VOLUME III - RESPONSE TO COMMENTS . SUBMITTED PURSUANT TO: (State) Division 13, Public Resources Code BY THE San Joaquin Hills Transportation Corridor Agency Orange County, California The following persons may be contacted for additional information concerning this document: Steve Letterly San Joaquin Hills Transportation Corridor Agency 345 Clinton Street Costa Mesa, CA 92626 (714) 557-3298 x297 February 14, 1991 San Joaquin Hills Transportation Corridor EIR Hearing Statement of City of NeWort Beach Mr. Chairman and members of the Board I am Benjamin Nolan, Public'Works Director for the City of Newport Beach,, Mayor " Sansone was unable to attend due to a conflict and asked me to ' present the City's position today. The City of Newport Beach supports acceptance of the EIR and supports construction of the San Joaquin"Hills Transportation Corridor, with implementation at the earliest practical date. A Council resolution expressing this position together with comments on the project is being provided to your secretary. We feel that the project related -environmental impacts can be mitigated, and that the impacts which would result from a "no project" alternative would be unacceptable. If the Corridor is not constructed, existing traffic congestion on Pacific Coast Highway, other arterials, and on I-5 and I-405 will become even worse; resulting in more delays, air pollution, and bypassing traffic on local streets. If we the public don't provide for our transportation needs in a reasonably planned fashion, the -long range consequence will be the need for future projects such as the Santa Ana Freeway widening project -- with displacement -of many hundreds of homes and businesses, costs in the billions, and truly horrible total impacts. We urge that the Corridor be built.'' Thank you. RESOLUTION N0. 90- 108 A RESOLUTION OF THE CITY COUNCIL OF THE CITY.O.F.NEWPORT BEACH EXPRESSING THE CITY'S COMMENTS ON THE SAN JOAQUIN HILLS TRANSPORTATION CORRIDOR ENVIRONMENTAL IMPACT REPORT; ENVIRONMENTAL IMPACT STATEMENT (TCA EIR/EIS 1) AND THE CITY'S POSITION ON CORRIDOR RELATED -FACILITIES -AND ISSUES WHEREAS, the approved Master Plan of Streets and Highways of the Circulation Element of the Newport Beach General Plan incorporate the proposed San Joaquin Hills Transportation Corridor; and f WHEREAS, the City Council of the City of Newport Beach has previously expressed support for the San Joaquin Hills Transportation Corridor as a way of directing traffic around portions of Newport Beach and as a facility which will accommodate traffic needs in the nearby area; and WHEREAS, a draft Environmental Impact Report Environmental impact Statement (TCA EIR/EIS 1) for the proposed San Joaquin Hills Transportation Corridor (hereafter "CORRIDOR") has been prepared by the Transportation Corridor Agency; and WHEREAS, the City Council has previously considered comments and recommendations from interested parties; and WHEREAS, there is a need to express the CITY's comments on the draft EIR/EIS and to -set forth the CITY's current position on CORRIDOR related facilities issues in accordance with the latest information available; NOW, THEREFORE BE IT RESOLVED that the City Council of the City of Newport Beach expresses the following comments in response to the draft EIR/EIS and as a statement of the CITY'S- CURRENT POSITION ON' corridor related facilities and issues: 1. The CITY supports acceptance of the EIR/EIS and continues to support construction of the San Joaquin Hills _ - Transportation Corridor,^ with implementation at, the earliest practicable date. 2. The CORRIDOR and related facilities should be designed to distribute traffic to the arterial street system in a balanced fashion, in which the interests and concerns of all affected areas are recognized equally. 3: The City support both the Conventional Alternative and the Demand Management Alternative, with p`eference for the Demand_.Management Alternative. 4. The CITY supports the Ford Road connect�-on to the CORRIDOR; subject to realignment of existing Forl Road northerly of its present location, preparation of a traffic cir ul,>;;tion plan for San Miguel Drive intended to minimize through traffic, and supports the relocation of the proposed,Ford Road/Bonita Canyon Road Park and Ride facility to a location easterly of the CORRIDOR. 5. The connection of San Joaquin Hills Road to Pelican Hill Road shall not occur until Pelican Hill Road (Newport Coast s Drive) is fully operational between Coast Highway and MacArthur Boulevard. The extension of San Joaquin Hills Road east of Pelican Hill Road (Newport Coast Drive) to the Corridor shall not occur. 6. An additional mitigation measure should be included to provide for review by local agencies of construction phasing, traffic control plans, and detours. These items should be structured to minimize impacts on the existing street system during construction. 7. Transparent noise barriers should be considered for use where views may be affected. 8. Design features and construction specifications should be structured to minimize any potential siltation impacts on Newport Bay. 9. The CITY supports incorporation of design features intended to minimize grading impacts and to result in an aesthetically pleasing scenic highway route. These features should include slope rounding and blending, variable slope ratios, contouring, split-level roadways where feasible, and fully landscaped slopes and medians. 10. The City supports the construction; at an early date, of the missing connector ramps (NB to WB and EB to JB) at the SR-73/SR-55 Interchange. 11. The mitigation program should be identifed and implementation of these mitigation measures required, rather than being classified as recommended when feasible. This resolution supercedes Resolution 88-89 ,Adopted this 13th day of November , 1990 MAYOR ATTEST: CITY CLERK I RON—